Consultation Statement

Local Plan: Consultation Statement (Regulation 22)

June 2017

Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017

Contents

1 Introduction 2

2 Regulation 18 - Consultation 4

3 Regulation 18 - Main Issues Raised 9

4 Regulation 19 - Consultation 93

5 Regulation 19 - Main Issues Raised 96 Appendix 1 - Specific and General Consultation Bodies 108 Appendix 2 - Newletter and Leaflet Examples 117 Appendix 3 - Press Release and Public Notice Examples 126 Appendix 4 - Display Board Examples 132 Appendix 5 - Sample of Media Coverage 136 Appendix 6 - Reg 19 Consultation Supporting Material 142 2 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

1 Introduction

Introduction

1.1 This Statement of Consultation has been prepared in accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012. It explains how Sedgemoor District Council has engaged with residents, businesses and other stakeholders to inform the Proposed Submission Local Plan (regulation 18 consultation), including the main issues raised and how they have been taken into account. It also provides details of summary of the main issues raised by representations following publication of the Local Plan (regulations 19 and 20). The legislation sets out that the submission documents should include a statement setting out:

i. Which bodies and persons were invited to make representations under regulation 18; ii. How those bodies and persons were invited to make representations under relation 18; iii. A summary of the main issues raised by the representations made pursuant to regulation 18; iv. How any representations made pursuant to regulation 18 have been taken into account; v. If representations were made pursuant to regulation 20, the number of representations made and a summary of the main issues raised in those representations; and vi. If no representations were made in regulation 20, that no such representations were made.

1.2 The statement has therefore been prepared to support submission of the Council's Local Plan to the Secretary of State. It follows and expands on the previous consultation statement (January 2017) that was prepared to support publication of the proposed submission Local Plan. In addition to legal compliance with the regulations the statement of consultation forms part of the evidence base for demonstrating the soundness of the Local Plan, in terms the plan being justified and taking forward the most appropriate strategy when considered against reasonable alternatives.

1.3 This statement explains how consultation has been carried out for the preparation of the Local Plan, including who was invited, the methods used to engage, the main issues raised and how these have been addressed in the Local Plan. In addition to formal consultations outlined in this statement, there has also been extensive ongoing and informal discussions and correspondence with key stakeholders. These have included discussions with adjoining authorities, infrastructure providers, community groups and representatives of the development industry. This extensive ongoing dialogue has helped to inform the preparation of the Local Plan and satisfy Duty to Co-operate requirements. The Council has also prepared a separate Duty to Cooperate Statement setting out how the plan satisfies Duty to Cooperate requirements as set out in the Localism Act 2011. This explains how liaison with neighbouring authorities and other relevant bodies has taken place and the outcome in terms of informing the Local Plan.

1.4 Internal engagement has also been important in shaping the Local Plan. This has included consultation with officers in other Council functions where their remit is relevant to the Local Plan. Examples include, Economic Development, Major Projects, Affordable Housing and Parks & Open Space Teams. Engagement with Councillors has also been a key component in the preparation of the plan through a cross party Local Development Framework Working Group. Working Group meetings have been held on a regular basis throughout the preparation of the plan. The main purpose of the group is to consider evidence, weigh up different options, feedback views, review consultation outcomes and make recommendations on the strategic direction of the plan. The Members Working Group does not have any decision-making powers but is able to make recommendations to the Council’s Executive and Full Council when the Local Plan is reported at relevant stages in its preparation. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 3

Introduction 1

Statement of Community Involvement

1.5 Consultation and engagement has been undertaken in accordance with the Council's Statement of Community Involvement (SCI). The Sedgemoor SCI, adopted in April 2007, sets out how consultation on Local Development Document, which includes the Local Plan, will be undertaken. It sets out the different groups of people and possible methods and techniques for consulting. Consultation and engagement has been undertaken in accordance with the Council's SCI.

1.6 The SCI was produced in accordance with the statutory/procedures required at the time of writing and since the SCI was adopted there have been some legislative changes in terms of the stages involved in the production of Local Development Document. The SCI should therefore be read in the context of the stages for plan preparation that are now relevant, as set out in the Town and Country Planning (Local Planning) (England) Regulations 2012. These can also be viewed on the Council's Local Development Scheme, available on the Sedgemoor Council website. Despite these changes the principles set out in the SCI are still considered relevant and important in ensuring effective engagement in plan making. It has been a main aim for preparation of the Local Plan to accord with and follow the principles set out in the SCI. 4 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

2 Regulation 18 - Consultation

Overview

2.1 The following section provides details of who has been invited to make representations during the Regulation 18 stages and how they were consulted. Throughout the process the Council has used a variety of methods to consult with stakeholders and interested parties, including Town and Parish Councils, residents, businesses and landowners.

Consultation Periods

2.2 Two formal Regulation 18 public consultation periods were undertaken, these included:

Local Plan Review Stage 1 Consultation - Scope and Approach

2.3 This consultation was undertaken for 12 weeks between the 26th October 2015 and 18th January 2016 (extended from the original end date of 18th December 2015). This was the main Regulation 18 consultation period consulting on what the new Local Plan ought to contain and sought views on a range of alternative options and the scope and content of the plan in general.

Local Plan Review - Additional Consultation

2.4 This second additional consultation period was undertaken for 6 weeks between 27th June and 8th August 2016. Following further sustainability appraisal work and consideration of stage 1 consultation responses this consulted on updated development options for land at East Bridgwater, to seek more views from the local community of potential development in this area. Refined development options for Burnham-on-Sea and Highbridge, Cheddar and North Petherton were also consulted on based on further consideration of sites options and land promoted to the Council.

2.5 Even discounting one week for the 2015 Christmas period overall we have therefore held public consultation over a total of 17 weeks, providing significant opportunity for the Sedgemoor community to input and comment on the emerging Local Plan.

Who were invited to make representations?

2.6 Throughout the preparation of the Local Plan the Council has invited key stakeholders and the wider public to have their say on the different options considered and what the Local Plan should contain, in accordance with the Regulations and the SCI. These included:

Specific Consultation bodies - These are the bodies listed in the legislation, including adjoining Councils, Parish/Town Councils, agencies such as the Environment Agency and Natural England, and utilities providers. In preparing the plan the Council has invited specific bodies that it considers may have an interest in the plan. A full list is provided in Appendix 1. General Consultation bodies - This includes voluntary groups and other organisations which represent local and national interests and the interests of hard to reach groups. Examples include religious groups and organisations representing disabled people and racial, ethnic, and business interests. A list of organisations invited is provided in Appendix 1. The General Public - including residents, visitors, commuters and local businesses. Developers - including landowners, housebuilders, agents and organisations that represent them, such as the Home Builders Federation.

2.7 The Council has set up and maintains a consultation database to ensure relevant people are notified by post or email at the start of consultation events. Anyone who has an interest in preparation of the Local Plan for Sedgemoor can register to ensure that they are kept up-to-date on progress with the Local Plan or other Local Development Documents, including being added to our newsletter Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 5

Regulation 18 - Consultation 2 mailing list. The Council also seeks to ensure the database is kept up-to-date with the contact details on any relevant new organisations who may have an interest in plan makings. The database also includes persons who have commented previously on Local Development Documents and have indicated that they wish to be kept up-to-date and be notified of future consultations.

Comments received

2.8 Discounting duplicate and blank responses a total of 1,776 written comments were received for the stage 1 consultation from 402 respondents. For the following additional consultation which focused only on Bridgwater, Burnham-on-Sea, Highbridge, Cheddar and North Petherton 276 written comments were received from 187 respondents. All comments were acknowledged as soon as possible following the consultation period finishing. In preparing the proposed submission Local Plan all comments received were reviewed and taken into account in preparing the Proposed Submission Local Plan. Specific comments made against different parts of the consultation documents can be viewed on the Council consultation portal:

http://sedgemoor-consult.limehouse.co.uk/portal

2.9 Section 3 summarises the main issues raised during the Regulation 18 consultation periods and how the they have been taken into account in the Proposed Submission Local Plan.

How were they invited to make a representation?

2.10 The Council used a number of methods to invite representations during the Regulation 18 consultation stages. The Council's Statement of Community Involvement describes some of the various benefits and drawbacks of different methods that can be used, for example in terms of their ability to reach different audiences and achieve adequate response rates. The Council has therefore taken the approach of using a range of different methods to publicise the Local Plan and seek to reach as wider audience as possible to inform preparation of the plan. Different methods that were used are summarised below:

Newsletters

2.11 The newsletter is one of the main methods used to keep those with an interest in the Local Plan (and Sedgemoor plan-making more generally) informed of its preparation. Newsletters were used throughout the preparation period to provide information of forthcoming consultation events, the release of new evidence base documents and to provide general feedback on the comments received. An example of the planning policy newsletter is included in Appendix 2.

Consultation Documents

2.12 For the formal consultation stages (Regulation 18) consultation documents were prepared. These set out the range of different options being considered for the Local Plan, for example in terms of levels of growth, spatial strategy, different site allocations and approaches to District wide policies. Where appropriate the document put forward suggested approaches that the Council were considering and set out questions asking what the Local Plan should contain across the full range of topics considered.

2.13 To ensure they were accessible to as many people as possible consultation documents were made available in a number of forms, including as online webpages, as a electronic .pdf documents, and as hard copy versions. This included hosting it on a dedicated Local Plan webpage on the Council's website and making the use of the Council's consultation portal, where people people can register and comment directly on specific parts of the document online. Hard copies of the documents 6 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

2 Regulation 18 - Consultation

were also made available for inspection at the Council offices and at libraries across the District. Whilst commenting online via the Council's consultation portal was encouraged the consultation document also highlighted that comments could be sent by email or post using either a separate comments form or as a freehand response.

Letters and Emails

2.14 To invite comment on the consultation material the Council sent out emails to people/organisations registered on the consultation database. This set out the length of the consultation period and where the consultation document could be viewed and commented on. The Council acknowledges that access to the internet is variable. To ensure sections of the community were not excluded letters were therefore also sent out to invite comment where this had been indicated as their preferred method of communication.

Leaflets

2.15 While the Council sought to ensure the main consultation documents were kept as short as possible a balance had to be struck between keeping the document concise whilst still including enough detail to ensure effective engagement. To improve understanding and reach a wider audience the Council therefore produced leaflets summarising key aspects of the document and how to comment. Leaflets were distributed at consultation events and where possible were made available at community facilities. A example of the leaflets used is included in Appendix 2.

Press Releases

2.16 A press release was prepared to ensure media coverage during the consultation period and reach as wider audience as possible. An example is available in Appendix 3. This resulted in a range of media coverage during the consultation period, including articles in the Bridgwater Mercury, the Burnham and Highbridge Weekly News, Burnham-On-Sea.com and the Cheddar Valley Gazette. Examples of some of the articles are included in Appendix 5.

Public Notices

2.17 In addition to the more general media coverage public notices were also placed in local newspapers for two weeks. This included the Bridgwater Mercury, Burnham and Highbridge Weekly News and Cheddar Valley Gazette. Notices included details of the period for consultation and where people can go for more information and to view and comment on the document. A copy of the public notice is included in Appendix 3.

Exhibitions/Drop-in Events

2.18 An extensive range of exhibitions/drop-in events were held across the District during the consultation period. Events held during the week were typically held from early afternoon into the evening to provide the opportunity for people to attend after work. Where possible events were also held on the same day and in the same venue as the Parish/Town meetings to allow members of the public or Parish/Town Councillors to see the information provided before the evening Council meeting where it was further presented and discussed.

2.19 Details of events were posted on the Council Local Plan website and included as part of the press release. Posters were also used to advertise specific exhibitions/drop-in events. These were sent to relevant Parish and Town Clerks, and displayed by Council staff in local shops and community facilities. A list of the consultation events held is provided below. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 7

Regulation 18 - Consultation 2

Stage 1 Consultation - 26th October 2015 to 18th January 2016

Saturday 31st October 2015 (9am - 3pm) - Burnham-on-Sea Food and Drink Festival

Tuesday 3rd November 2015 (1 - 6:15pm) - Berrow Village Hall

Wednesaday 4th November 2015 (3 - 7pm) - Chilton Trinity Village Hall

Friday 6th November 2015 (9:30am - 2pm) - Bridgwater Angel Place

Monday 9th November 2015 (1 - pm) - Nether Stowey Village Hall

Tuesday 10th November 2015 (1 - 8pm) - Highbridge Community Hal

Thursday 12th November 2015 (8:30am - 1pm) - Economic Development Conference

Saturday 14th November 2015 (9:30am - 2pm) - Bridgwater Angel Place

Monday 16th November 2015 (5 - 7pm) - Wembdon School Hall

Tuesday 17th November 2015 (1 - 6pm) - North Petherton Community Centre

Wednesday 18th November 2015 (1 - 7pm) - The Council Room, Wedmore

Friday 20th November 2015 (2 - 7pm) - Cannington Village Hall

Tuesday 24th November 2015 (1-6pm) - St Andrews Church Rooms, Cheddar

Thursday 26th November 2015 (2 - 8pm) - East Brent Village Hall

Tuesday 1st December 2015 (2 - 8pm) - Edington Village Hall

Wednesday 2nd December 2015 (2 - 8pm) - Westonzoyland Village Hall

Tuesday 8th December 2015 (1 - 7pm) - Woolavington Village Hall

Thursday 10th December 2015 (1 - 7pm) - Church Hall Rooms, Puriton

Monday 14th December 2015 (1 - 6pm) - Town Hall, Axbridge

Additional Consultation - 27th June to 8th August 2016

Monday 27th June 2016 (2 - 7pm) - Princess Theatre, Burnham-on-Sea

Thursday 30th June 2016 (2 - 7pm) - St Andrew Church Rooms, Cheddar

Monday 4th July 2016 (3:15 - 7pm) - St John and St Francis School, Bridgwater

Wednesday 6th July 2016 (2 - 7pm) - Community Hall, Highbridge

Tuesday 12th July 2016 (1:45 - 6:45pm) - Community Centre, North Petherton 8 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

2 Regulation 18 - Consultation

2.20 Officers were available at all times during the events to answer questions and encourage comments. In addition to encouraging people to comment in detail on the main consultation document, during the regulation 18 events general feedback was also collected on 'post-it notes' and notepads. These have informed the main issues raised that are discussed in the next section of this document (Section 3).

2.21 Display boards were erected at these events. This provided information on:

Background information on the planning context and role of the Local Plan; Different options for the levels of growth, distribution of development and other policies across the District; Specific information on relevant policies that are being considered that affect the settlement where the event is being held (e.g. Site allocations options); and Information on how to respond to the consultation, including website and postal addresses.

2.22 Examples of display boards used are available in Appendix 4.

Presentations, Meetings and Workshops

2.23 In addition to the main exhibitions a range of other events were also organised. This included early engagement at Parish training and cluster group meetings prior to formal consultation commencing. Presentations and Question and Answers sessions were then also held at individual Parish and Town Council meetings throughout the consultation periods, usually following the exhibition events listed in the tables above. Events were also held with representatives of the business community and other local interest and hard to reach groups. At the events material was presented to increase awareness of the consultation and promote discussion on the different options being considered. Opportunity was provided for people to discuss the options and for officer's to answer any queries raised. Where appropriate individual meetings have also been held with specific stakeholders (e.g. infrastructure providers) throughout the preparation of the plan.

Online and Social Media

2.24 In addition to the Council's own website use was also made of other ways to promote the consultation period online. This included asking Parish and Town Councils to include details of events on their websites and where possible making use of Facebook and Twitter to raise awareness.

Other One-to-One Engagement

2.25 In addition to the events discussed above direct telephone, email and postal details of the Planning Policy Team were included on all consultation material. Officers were therefore available to discuss over the phone any queries raised on the content of the consultation document or the consultation process in general. In instances where people wished to discuss issues face-to-face officers where also generally available to answer queries where they visited the Council Office reception in person. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 9

Regulation 18 - Main Issues Raised 3

Regulation 18 - Main Issues Raised

3.1 The section below sets out the main issues raised during the Regulation 18 consultations and how they have been taken into account and addressed in the preparation of the proposed submission Local Plan. Summaries are separated into the different topic areas/sections, mirroring the structure of the two consultation documents. Given the number of individual comments received this section does not list every comment or try to capture comments on detailed textural points in all instances. All individual comments are available to view in full on the Council's online Consultation Portal.

Local Plan Review Stage 1 Consultation - Scope and Approach

Spatial Portrait

Summary of issues raised How it has been addressed

The need for more reference to tourism in the The Spatial Portrait refers to the significance of the spatial portrait and the impact that Burnham-on-Sea area and Cheddar as tourist development proposals would have for the destinations in the District (paragraph 2.3). The tourism industry, especially in impacts of alternative spatial strategies and Burnham-on-Sea. development options on tourism and other economic objectives have been considered through the sustainabilty appraisal process.

Flood risk from tidal and other sources is a The extensive areas of Sedgemoor that are at flood major factor and there is concern that no detail risk from different sources of flooding are discussed is provided on how such risks are to be in the Spatial Portrait (paragraph 2.17). eliminated or reduced for new development. Consideration of flood risk in terms of avoidance and reducing flood risk through new development is addressed in policy D1.

More detail needed in the Spatial Portrait Reference to this concern and the link between regarding the need to address key public obesity and lack of physical activity is included in health issues. Addressing low activity and paragraph 2.19 of the spatial portrait. obesity levels requires measures to incorporate physical activity into everyday life; through walking and cycling route improvements, which also tackles growing motor vehicle congestion.

Concern that not enough attention has been Paragraph 2.20 of the spatial portrait refers to the paid to the availability and affordability of challenges faced by the District in terms of limited public transport and cycle routes. access to public transport and the need for continued investment in walking and cycling.

Concern there seems to be little consideration Paragraph 2.21 refers to the developing peak rush for the substantial increase in traffic that hour periods in the District's main settlements. The current residents will be subjected to with the challenges that the network will face during Hinkley building of Hinkley Point C, the Bristol Airport Point C construction and the need for new expansion and increased housing. development to deliver necessary transport infrastructure are also discussed. 10 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Unemployment is not adequately discussed The challenges faced in terms of the higher than and priority should be given to encouraging average levels of unemployment are discussed in employment opportunities to provide jobs for paragraph 2.11. This has informed Policy D16: local people. Economic Prosperity in terms of local labour agreements.

That Bridgwater needs to offer the population The challenges facing the town centre in terms of a wider variety of shopping, entertainment and providing adequate leisure and shopping activities restaurants. is discussed in paragraph 2.12. Policy B20 (Northgate) and the policy framework of Policy D19 (retail hierarchy) seeks to address these deficiencies.

No reference to a second reservoir at Cheddar While the development is consented, funding for or its impacts. the reservoir is yet to come forward. It is therefore not considered necessary to refer to the project in the spatial portrait which aims to set out the strategic context for the Local Plan.

Differences in transport in areas of the Districts The connectivity offered by the M5 corridor along considered to need more discussion. The M5 with the challenges in terms of transport faced in corridor serves the area well allowing easy rural locations is discussed in paragraph 2.20 of access, but other areas are more rural and the Spatial Portrait. roads are narrower which has to be a major consideration when planning further development.

AONB areas not given enough prominence in Reference to nationally important landscapes has the spatial portrait. Reference to the Quantock been included in paragraph 2.16 in the Spatial Hills should not only be ‘diverse and unique’ Portrait. but ‘nationally’ important landscapes.

The Bridgwater and Taunton Canal is barely Reference to the importance of waterbodies mentioned despite providing a very good providing multi-functional benefits on issues such example of cross boundary, multi-functional as flood risk, amenity and ecology has been green infrastructure, and should be recognised included in paragraph 2.16. for the positive benefits it brings to the district.

Concern there is no mention of higher Whilst not specifically discussed in the Spatial education at Bridgwater College or a university Portrait support for Bridgwater & Taunton College in Somerset. in terms of providing for additional, extended or enhanced education needs is addressed in Policy D30 (education).

More detail needed regarding lifetime home The need to address the housing needs of specific standards and the need to focus on the age groups and deliver adaptable and accessible homes extremes by delivering specialist and is discussed in paragraph 2.15 of the Spatial affordable housing. Portrait. The need for affordable housing is discussed in paragraph 2.14. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 11

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

More detailed consideration needs to be given The importance of Hinkley Point C is discussed in to Hinkley Point C - not discussed enough in paragraph 2.5 of the Spatial Portrait and has its the document despite its importance and own specific policies in the Local Plan under the impacts. Major Infrastructure Projects section.

Vision

Summary of issues raised How it has been addressed

Suggestion that climate change will lead to This section of the Vision considered Met Office UK “hotter and drier summers” should be Climate Projections that indicate warmer and wetter changed, as evidence is not clear exactly winters and hotter and drier summers. how our climate in Somerset will be affected.

Vision should be aspirational, but also Agreed, the drafting of the Vision and Local Plan more realistic and deliverable. generally has been with the aim of meeting these principles. The Council has sought to meet the development needs of the District and ensure proposals identified are realistic and deliverable.

Reference to prioritising brownfield We disagree that the Local Plan is inconsistent with development should be removed from the the NPPF. The Vision is consistent in meeting the Vision. It is not consistent with NPPF (para requirements of the NPPF by stating; ‘The reuse of 17 and 111). brownfield land will be prioritised wherever possible…’.

This meets the NPPF para 17 that states;

‘encourage(ing) the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value;’

In addition the NPPF para 111 states;

‘Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.’

It is vital that the previous Vision of “where This is retained in the Rural vision. there has been change, rural communities will have retained their unique character, sense of identity and social cohesion” remains. 12 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

The Port of Bridgwater (Dunball) is a unique The plan recognises the importance of the Port facility in the region and should be in the through specific protection under Policy B17. Vision to support/develop a sustainable future.

Health improvement within the plan should Both the vision and detailed policies through the plan aim for walking, cycling and public transport promote walking and cycling to promote healthy to be the first choice forms of transport. lifestyles.

Consideration should be given to ensuring Noted. This is a detailed point that is included in the Isleport is readily accessible by cyclists from adopted SPD as well as generic Local Plan policies Burnham. promoting cycle links.

Concern that there is no focus within the Policies BH11 and D18 both support investment in strategy to promote the businesses in Brean. tourism in the area whilst the Local Plan also supports appropriate small scale employment in rural areas.

Disagreement that there should be further Bridgwater remains the most sustainable location for large housing developments within the growth although the plan recognises constraints and Bridgwater boundary as the infrastructure is provides greater opportunities in rural areas for growth at breaking point. than the Core Strategy. Policies set out the requirement for infrastructure and the need for any proposals to be supported by an infrastructure delivery plan.

Addition under the ‘living sustainably’ section Both Policy D2 and D6 provide guidance on this and for homes to be accessible and built to life set out the Councils expectations. time homes standards.

To continue to look for a dedicated business The previous proposals in the Core Strategy are not zone and office cluster close to the town considered to be deliverable but the identification of centre of Burnham. land at Isleport provides opportunities for a range of new business space. The Highbridge Enterprise Centre also provides a range of business space.

All proposed Tier 1 settlements should be Agreed. The Vision includes specific sections on addressed in greater detail, therefore Cheddar and North Petherton whilst the Local Plan Cheddar and North Petherton also need to includes detailed place-making policies for each be discussed in detail rather than just settlement. Bridgwater and Burnham-on-Sea and Highbridge

Should reflect the three dimensions of It is considered that as the Local Plan is a review of sustainable development, as set out in the the Core Strategy the overall structure of the plan NPPF. should remain largely unchanged. New Policy S1 addresses sustainable development specifically and the whole plan has been subject to a sustainability appraisal using these themes.

The Vision could be improved further, Completion of flood defences form part of the Vision. developing the whole stretch alongside the The Bridgwater Vision itself sets out in greater detail Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 13

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

river with flood defences and 3, 4, 5 storey the aspirations for regeneration and remains a buildings with a mixture of retail and leisure material consideration. units and a promenade.

Important that the tourism industry and the Tourism is referred to in the vision whilst specific visitor economy are supported throughout policies including D18 support tourism. the new Local Plan, particularly within the Plan’s Vision.

It should be made clear in the Vision that The Vision clearly states that the right type of housing the needs for housing is the full objectively will be provided to meet a range of needs. Policy S2 assessed needs as set out in a robust addresses in detail the strategy for accommodating SHMA the OAN (as a minimum) based upon the updated SHMA.

Concern that the Vision does not reflect the The Vision refers to a diverse economy whilst policies importance of small businesses; should be in the Local Plan support a range of business amended to promote the growth of the opportunities, both large scale and smaller economy where it is most likely to occur enterprises, particularly in rural areas.

The Vision should not be largely transferable The Visions refers to specific outcomes that are to another local authority area, it is close to unique to the District as well as some more general being generic. aspirations that other places might also aspire to deliver.

The Vision should reflect the need to The specific text has been retained whilst Policy D20 conserve and enhance the AONBs and their addresses AONB's. AONB's are also afforded settings and should retain the text which protection through the NPPF. states “a living and working countryside that contributes to the overall prosperity and well-being of the District and conserves and enhances its natural beauty”

Conservation and enhancement of historic This has been included, the Vision states under; environment needs to be incorporated into ‘Enjoying and Achieving…By 2032 the natural beauty the Vision. , biodiversity and heritage of Sedgemoor will have been protected and enhanced for its enjoyment by future generations.’

Objectives

Summary of issues raised How it has been addressed

Major roads (A370, A38, Queens Drive) in The specific transport requirements will be Burnham need to be upgraded to dual developed through transport impact assessments. carriageways before development is started. There are no current plans for dualing existing roads.

The importance of the visual landscape needs Noted and agreed - this is addressed in Policy D34. to be emphasised with the preservation of 14 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

green wedge areas and areas of visual rural beauty.

Need to improve sustainable transport links. Noted, transport priorities and policies in the Local Plan emphasise investment in alternative modes of travel.

Emphasis should be placed on the re-use of Policies in the plan support and encourage re-use brown field sites before building on green field of brownfield sites but given the nature of the district sites, particularly those on flood plains or low and the diminishing opportunities, meeting the OAN lying ground. will require greenfield sites. The strategy seeks to minimise development within FZ3a but where this is not possible, appropriate strategic flood defences will be delivered.

Objectives for living sustainably and economic Noted, the plan sets out infrastructure requirements wellbeing will be achieved if the infrastructure for allocated sites and an overall infrastructure is in place to access work places and for the policy. The updated IDS will provide more detailed delivery of goods. information on specific requirements.

Amend “create more sustainable communities” The visions are high level statements but it is clear to “sustainable communities and active the detailed policies of the plan support this. environments”.

The existing Core Strategy objectives could Noted although the current priorities broadly seek be updated to reflect the need for affordable the same outcomes. Specific policies in the plan housing by stating; “to provide everyone with seek to ensure new development does this through the opportunity to live in a decent and provision of the right type, size and tenure home. affordable/accessible home” and “to create more sustainable, inclusive and mixed communities”.

A northern relief road option would be a useful The current transport strategy does not require a addition. northern relief road, however, in the longer term this may be a priority.

Concern there is no reference to the tourist It is accepted that this is implicit rather than explicit industry or visitor economy within the although policies in the Local Plan provide more objectives. robust and detailed support for this sector.

Concern that despite positive objectives Thee will inevitably be cases where compromises already existing, developments are going need to be made and where competing objectives ahead that go against the good intentions of need to be balanced. However, annual monitoring the framework sets out in detail performance against the plans priorities and policies. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 15

Regulation 18 - Main Issues Raised 3

Levels of Growth

Summary of issues raised How it has been addressed

Concerns that the Objectively The Council has comprehensively updated its evidence Assessment Need has not been based base of Objectively Assessed Need with a Strategic on a robust assessment. Evidence Housing Market Assessment recently completed jointly base should be fully update to identify with other Somerset authorities. This has been undertaken the scale of new homes that need to fully in line with Government policy and guidance on be planned for. establishing objectively assessed need and incorporates latest available data on demographic projections.

Concerns raised that the scale of new In determining the housing need for the Local Plan the housing growth is either too high and Council has followed best practice in using demographic is exaggerated, or is too low and the projections as the starting point and then making Council should be more ambitious. appropriate adjustments to take into account factors such Infrastructure will not cope and it will as market signals. The analysis and how the final have detrimental effects, for example objectively assessed housing need as been arrived at is on the local economy, environment and reported in the Strategic Housing Market Assessment. In farm land. line with the NPPF and Council has taken a positive approach and is seeking to meet the identified housing needs in full.

Concern that the higher end forecasts The new work undertaken in the Strategic Housing Market will leave lots of people unemployed, Assessment that has informed the Local Plan included especially with 2 or more working analysis to establish if there was an imbalance between adults per household where population growth is projected to occur and where the jobs might be provided. This concluded that across the District there can be expected to be a good balance between jobs and the population to take up employment opportunities. In any case the plan takes a positive approach to the delivery on employment sites to seek to safeguard economic prosperity into the future.

Concern that the demographic While there may be some criticisms of ONS projections projections used by ONS are not the Goverments Planning Practice Guidance sets out clear adequate. For example it does not take steps for how local authorities should determine housing into account that population growth will need, which includes using demographic and household reduce as the 'baby boomers' get older. projections as the starting point.

Concern that more homes are being The plan allocates a site for employment in Cheddar (Policy built by Cheddar but are not matched C4), in addition the District wide Policy (D16) supports new by employment or transport. small scale employment development and the retention, remodelling and expansion of existing businesses.

A detailed trajectory of the Council’s An updated Strategic Housing Market Assessment has supply from 2015/16 onwards and a informed the proposed submission Local Plan. The housing fully updated SHMA should be provided trajectory is published annually as part of the Council's as part of the Council's evidence base Annual Monitoring Report.

The growth forecasts for new homes The analysis in the latest Strategic Housing Market and jobs is an underestimate as Assessment uses a longer base period as a reference for 16 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

calculations based on the average projections, this base period extends to periods before the annual housing delivered is not recession. This analysis therefore ensures that accurate as the majority of these years recessionary trends regarding household formation, were during the recession. migration and other factors and not carried forward in determining housing need up to 2032.

Concern that the housing target is too Hinkley Point C has been considered in the Strategic low and does not accurately model the Housing Market Assessment. Overall, the analysis did not impacts and housing needs associated identify any need to increase housing provision above the with job delivery from HPC. Figures sort of levels suggested by demographic-based projections need to be recalculated taking into in order for there to be a sufficient labour force. account the jobs created at Hinkley Point C

Strong agreement that in order to meet Agree that greenfield sites will need to be identified if the housing targets, greenfield sites need Council is to meet its identified housing need up to 2032. to be identified given that the majority The Strategic Housing Land Availability Assessment of major brownfield sites in the District identified a range of opportunities within settlement already have consent. boundaries, including some which are on brownfield sites. The approach of the Local Plan is to maximise these opportunities.

To meet the forecast economic growth Tourism policies in the Local Plan (particularly Policy D18) for the tourist and leisure industry, provide a positive policy framework to support tourism. continued investment is required for the sector.

Concern that numbers for new housing Vacant homes have been taken into account in the analysis is overestimated; analysis should also undertaken by the Strategic Housing Market Assessment. include unoccupied dwellings.

Concern that these figures do not take The objectively assessed need for housing is a 'policy off' account of other evidence such as analysis undertaken by the Strategic Housing Market fundamental overriding policy Assessment and does not consider wider planning constraints; flood risk in particular. constraints such as flood risk. In translating this into housing requirements in the Local Plan the Council has to take into account the National Planning Policy Framework which sets out that local authorities should ensure their Local Plan meets the housing needs in full unless this is inconsistent with other policies set out in the framework. The Council has taken into account flood risk as part of the Sustainability Appraisal of the plan and has taken a sequential approach to where it has allocated development. Where there is no alternative but to locate development in flood risk areas it has been ensured these are in locations where they can be made safe over their lifetime, for example through off site flood defence improvements. This overall approach is considered to be consistent with policies set out in the National Planning Policy Framework. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 17

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Building should only be on brownfield Analysis undertaken indicates that there is not enough sites, not in greenfield areas which capacity to rely on brownfield sites alone in meeting the displaces wildlife and ruins the rural district's housing requirements. The various implications character of the area. of developing on greenfield sites has been taken into account including through the sustanability appraisal process for the plan in determining the most appropriate sites to allocate for development.

Land Supply

Summary of issues raised How it has been addressed

A range of additional sites were Sites promoted during the Regulation 18 consultation have been promoted for development as part assessed through an update to the Strategic Housing Land of the Stage 1 consultation. Availability Assessment and Employment Land Review. This is available online as part of the evidence base supporting the proposed submission Local Plan. These informed both the additional consultation undertaken in 2016 and the proposed submission Local Plan.

Distribution of Development

Summary of issues raised How it has been addressed

Different options for distribution of The Local Plan's spatial strategy seeks to get the right development across the District were balance between the different approaches to how ranked very similarly. Option A (existing development could be distributed. It retains a principally urban focus) most preferred by a slight urban focus whilst also allowing an appropriate scale margin. Option D (Dispersed Development) of development to support the District's rural least preferred. communities.

Concern that Options A (existing urban Flood risk is a key constraint on development and is it focus) and B (BS&H urban focus) place important that it is taken into account in the plan making the majority of housing on floodplains, in process. Through the sustainability appraisal the particular in Burnham-on-Sea and Council has sought to steer as higher proportion of Highbridge. Some considered that development as possible to low flood risk areas. Some floodplains should be totally avoided and development in flood risk areas is however unavoidable highlighted that these locations already if other sustainability objectives are not to be have significant transport constraints. compromised. In allocating sites in flood risk areas the Council has taken into account current or planned flood defence infrastructure to ensure development remains safe over its lifetime. In relation to transport the plan identifies a number of road schemes and junction improvements and sets out transport assessment requirements for new development.

Transport infrastructure must be in place, The Local Plan sets out a range of policies to address concentrating on public transport and easy transport, both in terms specific transport improvements access to major road networks. in the Place-Making section and what the expectations 18 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

are for planning application to address transport impacts (Policy D15). Policy S3 sets out that required infrastructure should be delivered in time to meet the needs that arise from new development. The overall strategy is to direct the majority of development to settlements which have good access to major road networks.

That if employment opportunities can be Agree that Burnham-on-Sea and Highbridge is a created in Burnham and Highbridge, it sustainable location with good connectivity. would best cope with housing expansion Employment opportunities have been identified through as it has access to services and is the Isleport Extension Supplementary Planning connected to the wider region which is Document. The new Local Plan identifies some critical for sustainable growth. allocations for housing development and there is also a significant amount of committed development with planning permission that is yet to be built out. Larger scale housing allocations previously consulted on have not been allocated given the need to where possible steer development away from flood risk areas.

A number of responses agreed with The plan seeks to direct the majority of new promoting better self-containment in terms development to the district's urban areas where there of where people live and work to minimise are the widest choice regarding sustainable modes of vehicle pollution, so developments in transport. Bridgwater and Burnham-on-Sea and Highbridge should be encouraged.

Disagreement of large scale housing Significant additional employment land has been developments in Burnham-on-Sea as there allocated at Isleport that will provide local job are no employment opportunities, therefore opportunities. However, the overall level of growth increasing the numbers of commuters. identified for the town reflects both physical constraints and current commitments.

Development should be along the A38 The Local Plan identifies employment sites along the north of Dunball to take advantage of the A38 Bristol Road and additional land has been main road and motorway junction, as well allocated at Isleport through a previous SPD. as businesses including Isleport which could help to keep traffic out of Bridgwater ad Burnham.

Strong agreement that a change is needed The spatial strategy and revised settlement hierarchy to the current distribution because rural provides more support for appropriate scales of areas in the District have been starved of development in the district's rural communities. new development which compromises vital local services and facilities in rural communities.

Option C and D would shift the focus away This concern also emerged from the sustainability from urban areas and direct development appraisal of different options and is one of the reasons Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 19

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed to all settlements as a proportion equivalent why a principally urban focused distribution is being to their existing size and population. taken forward in the Local Plan. Concern however that this would impact negatively on key assets, such as areas of AONB, rural character, and put development in areas with relatively constrained infrastructure.

It is strongly recommended that the Council The potential impact of Isleport 2 on the strategic road includes the Isleport 2 growth within the network are identified in the now published Isleport emerging traffic modelling, to inform the Extension SPD. This includes transport assessment potential impact of the development plan requirements to take into account impacts on the on the Strategic Road Network. Strategic Road Network.

The principle of delivering growth via a The Local Plan makes provision for smaller scale sites large number of smaller sites would help through either neighbourhood planning or a subsequent to limit risks that occur on larger sites, and site allocations document ( for Tier 2 settlements), or are therefore more deliverable. for the release of sites to meet local housing need (Tier 3 and 4 settlements). However it is considered larger scale sites also need to be allocated to meet the District's identified housing need.

Countryside and habitats needs to be It is considered that taking this approach District wide preserved not built on, instead of large would not meet the District identified housing need up development sites should focus on to 2032. This approach is however being taken for the providing for the needs of each settlement. District smaller settlement (Tier 3 and 4).

Prioritisation of brownfield land over The plan does not specifically prioritise brownfield land greenfield land should be deleted from the over greenfield land, in terms of taking a sequential plan as it is not consistent with NPPF approach. It does however seek to maximise brownfield (paras 17 and 111). opportunities in addition to identifying additional greenfield sites to meet housing requirements up to 2032.

That an urban focus should be retained, This is essentially the approach that is being taken in but with some growth also being directed the Local Plan and is considered the most sustainable to sustainable rural settlements. strategy after considering reasonable alternatives.

Option D preferred by some as it would It has been determined that if Option D (dispersed give greater opportunities for development approach) was taken significant scales of new across the district in sustainable development would need to be identified in the District's settlements. smaller settlements. This is not considered to be the most appropriate strategy and would lead to negative effects across a range of sustainability objectives. The Local Plan does however plan for appropriate scales of development in sustainable rural settlements.

Some raised concerns that Option D This is to some extent true given the Core Planning conflicts with sustainable development Principles described in the NPPF. While some further principles and Government policy. growth is being directed to the most sustainable rural 20 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

settlements a fully 'dispersed' approach is not considered to be the most appropriate strategy and is not being taken forward in the Local Plan.

Settlement Hierarchy

Summary of issues raised How it has been addressed

Disagreement that Cheddar should become The Council agree that Cheddar is in a rural location a Tier 1 settlement. It is a rural location and and is an important tourist attraction. Assessment is an important tourist attraction, managing has highlighted the particular environmental to retain a rural feel. limitations (e.g. proximity to AONB) and more limited transport infrastructure and connectively compared to the main urban areas. This has informed the scale of growth that is directed to Tier 1 settlements when compared to the main urban areas.

Concern that Cheddar is already overcrowded It is considered that Cheddar does have a good and does not have the infrastructure or range of services and facilities, as identified in the services to cope with current residents, and role and function evidence base. In determining the is not comparable to Bridgwater or place in the settlement hierarchy consideration has Burnham-on-Sea and Highbridge as Tier 1 been given to connectivity in terms of transport settlements. That too much weight has been infrastructure. For this and other reasons the Council given to certain local services as opposed to therefore agree that Cheddar is not comparable to infrastructure such as transport connections the main urban areas. To reflect this the spatial and proximity to well serviced urban areas. strategy has identified Burnham-on-Sea and Cheddar is not on par with Burnham-on-Sea Highbridge in its own tier (Market Towns), above and Highbridge, it's transport network is Tier 1 settlements. inadequate for large scale growth. The M5 corridor is more appropriate for development.

Concern that Cheddar is placed in Tier 1 as Supporting and strengthening Cheddar as a tourist it is still a place of outstanding natural beauty destination and protecting and enhancing ecological and the Council needs to prioritise its role as sensitivities are identified as objectives for this tier a natural asset and tourist destination. (Policy T1). The proximity to an area of AONB has been taken into consideration in the sustainability appraisal and has informed the scale and location of growth that can be accommodated at Cheddar. Cheddar's environmental constraints are identified in the role and function work and were taken into account in identifying it as a Tier 1 settlement.

Cheddar does not have the employment offer In identifying its Tier 1 status the role and functional to support the scale of housing development work has identified that Cheddar does benefit from proposed. It's Tier 1 status is therefore not large scale employment (500+ jobs). The Local Plan justified. also allocates additional employment land and support small scale employment coming forward. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 21

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Some support for Cheddar and North The Spatial Strategy describes that Cheddar and Petherton as a Tier 1 settlement from those North Petherton benefit from a good range of promoting development in the area. It is services and facilities serving not only their argued they currently provide a broad range settlement but the wider area as well. of facilities and plays an important role in Sedgemoor’s economy.

Some disagreement over whether North It is considered that this imbalance has been Petherton should be identified as Tier 1. addressed by moving Burnham-on-Sea and While located close to Bridgwater it is not Highbridge out of Tier 1 and into their own higher comparable in terms of services to the other Tier (Market Towns). Whilst North Petherton is Tier 1 settlements. considered to have less services and facilities when compared to Cheddar its proximity to Bridgwater, major employment areas and the motorway network are considered to justify its Tier 1 status.

Some representations considered that It is considered more consistent with Government Biddisham, Badgworth and Stockland Bristol Guidance to identify these locations as settlements, should not be placed in Tier 5 and should rather than retaining a blanket "countryside" policy. retain their “countryside” designation. Given there limited services the Local Plan is still clear that they are not considered to be sustainable locations for development.

Considered by some that Shapwick and Services are certainly more limited in Tier 4 Bawdrip do not have the amenities/facilities settlements such as Shapwick and Bawdrip and they to warrant Tier 4 and should remain in Tier 5 are to some degree reliant on nearby higher tier or Countryside. There are also some local settlements for services. However the NPPF is clear drainage problems in Shapwick that should regarding the need to maintain the vitality of rural be taken into account when considering future communities and the Local Plan allows small scale development. housing development justified based on local affordable housing need that is appropriate to the size and character of these settlement (Policy T10). Policy D1: flood risk has been strengthened with regard to surface drainage and will ensure such constraints are adequately taken into account.

Some views considered that the assessment The scoring matrix has been the starting point of ‘Role and Function Review of our settlements defining the settlement hierarchy. In finalising the services and facilities’ provides a robust hierarchy account has also been given to other assessment of the facilities and services in sustainability considerations, such as transport each settlement, providing a scoring system connectivity and environmental constraints. that identifies the settlements most appropriate to focus new development.

Consideration could be given to a number of To support a plan led approach in rural areas a villages that do not presently have a significantly larger number of settlements have been designated Settlement Boundary, in order to provided with boundaries when compared to the support rural sustainability. existing Core Strategy. These are shown on the Policies Map. The exception is Tier 5 settlements where it is considered not appropriate to define 22 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

settlement boundaries given that they are not sustainable locations for development.

Some strong support for the recognition that The strategy steers 60% of the District growth the Local Plan should include the delivery of requirements to Bridgwater, relying on some strategic greenfield allocations at Bridgwater. development on greenfield sites as allocated in the Local Plan.

Disagreement that Brean should be placed Whilst the role and function scoring matrix as a Tier 3 settlement; should remain as Tier highlighted the significant range of services and 2. facilities in Brean this is principally because of its role as a tourist destination, rather than the size of the village. Given the serious environmental challenges in terms of coastal erosion and flood risk it is considered it's Tier 3 designation is justified.

Disagreement for Wembdon to be Tier 2 as Wembdon as been identified as Tier 3 in the Local it does not have the required infrastructure Plan following further consideration and an update and fits much more comfortably into Tier 3. to the role and function evidence base.

The need for affordable housing to achieve In relation to local need housing in Tier 3 and 4 ‘local support’ adds an additional burden and settlement the policy wording requires robust and should be removed; schemes should be meaningful consultation with the Parish and local granted wherever possible to meet identified community (Policies T5 and T10). This is considered local needs. appropriate and reflects the expectation the schemes will usually be community led.

Chilton Trinity is not considered in the Whilst this strategic development option is not being hierarchy, yet the plan considers this area an taken forward in the Local Plan it is considered acceptable place to build 1,200+ new homes. appropriate to identify Chilton Trinity in Tier 5.

Proposals should not ignore issues around This has been taken into account in determining the accessibility and road constraints when settlement hierarchy. determining the settlement hierarchy.

Concern that justifications do not consistently The Council has updated it's role and function take into account quality or availability of the evidence base following previous consultation. It is services and infrastructure in place. acknowledged that the availability and quality of services in individual settlements may vary over time however it is considered the evidence base provides as up-to-date picture as possible to inform the Local Plan.

Hierarchy and scale and location of This has been taken into account in determining the development needs to take into account the hierarchy in the Local Plan, including key historic form and character of settlements. designations such as conservation areas.

Concern that Berrow is incorrectly Agree. Following a further review of the role and categorised as Tier 2. It is reliant on the function of settlements Berrow has been identified facilities at Burnham and is at flood risk. as a Tier 3 settlement in the Local Plan. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 23

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

General agreement that some small Agree. In accordance with the NPPF the Local Plan settlements have been neglected and their has sought to support the vitality of rural inclusion in Tier 4 is welcomed (e.g. Chedzoy, communities and identified a range of Tier 4 North Newton). settlements.

Facilities, services and employment in The transport impacts arising from new development Edington yet roads considered to be totally would need to appropriately assessed at the inadequate, particularly for pedestrians using planning application stage. This is addressed in the roads. The existing situation for Policy D15 in the Local Plan. Whist there may be pedestrians in Edington and Catcott is physical constraints in terms of how the villages have therefore very poor and makes it difficult to historically developed this presents the opportunity use the local facilities. Any developments for new development to improve the existing situation needs to improve this existing situation. where necessary to make the development acceptable.

It has been argued that based on the facilities Tier 3 takes a similar policy approach to the current and services Pawlett should instead be Core Strategy 'Key Rural Settlement' category. categorised as a Tier 2 settlement, and that Therefore it is considered that Pawlett has not been the sites at Keward Farm would be a suitable downgraded. The Council has refreshed it's role and location for sustainable housing and function evidence and it is considered that Pawlett employment growth. Its current status as Tier being identified as a Tier 3 settlement is justified. 3 is a 'downgrading' compared to the existing Core Strategy (key rural settlement) and will limit required growth.

Compton Bishop has no facilities and is The approach applied to Tier 5 settlements is not located in and adjacent AONB. It should considered to open the door to inappropriate remain as countryside to prevent development. The approach is clear that these inappropriate development. Development settlements are not considered to be sustainable should not be allowed and Tier 5 would open locations for development. Relevant District wide the door to this. policies (e.g. D20, landscape) also ensure AONB is protected and enhanced.

With regard to Cheddar's Tier 1 category The Council has considered this in the refresh of it's concerns that the evidence base that has role and function work and it is considered that the informed the hierarchy is flawed, there has scoring used for different services and facilities is been disproportionate loading placed on appropriate. Additional facilities only score additional certain facilities (e.g. public houses). This has points up to a capped level, to prevent a cluster of skewed the weighting for Cheddar leading to similar facilities skewing the scoring. For example its inappropriate Tier 1 category. for the Cheddar score of 103 only 6 points of this is due to public houses.

Some support for Woolavington being As well as a range of services Woolavington is well considered as Tier 3 rather than a Tier 2, served by the A39, is close to Bridgwater and has addressing just local need housing. While few environmental constraints. It's identification as aware of the need for new properties in the a Tier 2 settlement is therefore considered justified. village there is a need to be conscious that Whilst it is appreciated that village facilities may have village facilities are diminishing. Significant diminished to some extent in recent years it is affordable homes have already been considered that new development provides an delivered and the approach to delivering opportunity to improve this situation. 24 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

housing for local people is appropriate. It should therefore be recategorised as Tier 3 rather than Tier 2. Representations promoting development options have also made cases as to why it should remain a Tier 2.

Some support for dropping Brean from Tier Agree. Brean has been identified as a Tier 3 2 to tier 3 based on flood risk but also to settlement. reduce recreational pressures on this part of the coast, which is an important consideration for the HRA.

Some support for Moorland, Fordgate and This has been considered through the role and Fiddington being identified under tier 5. function evidence base. It is considered appropriate to identify Fiddington and Moorland as Tier 5 settlements.

Some support for identifying Bawdrip as Tier The Plan has identified Bawdrip in Tier 4 and 4, reinstating a settlement boundary and reinstated a settlement boundary. allowing some exceptional development outside of the settlement.

Infrastructure Delivery

Summary of issues raised How it has been addressed

Infrastructure must be completed prior to Policy S3 (Infrastructure Delivery) requires that development rather than as an afterthought. infrastructure is provided at a rate, scale and pace It needs to be in place before development to meet the needs expected to arise from happens and address the impacts in the development. surrounding area.

In areas of flood risk, flood appraisals and The NPPF sets out clearly the instances where flood necessary works need to have occurred risk assessment are required to support planning before any development takes place applications. It is not considered necessary of the Local Plan to duplicate these policies.

Agreement that “robust viability testing” is Policy S3 retains the approach of taking into account critical to ensure planned development viability considerations in determining the nature and contributes fairly to infrastructure scale of planning obligations. requirements whilst still being deliverable, and to ensure viability is not used as an excuse to minimise contributions to infrastructure.

Support to re-examine the CIL and various Agreed. As detailed in the Local Plan and Local policies in the Local Plan relating to Development Scheme the Council intend to infrastructure when assessing the overall undertake a review of CIL following the outcome of plan and viability. the Government review. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 25

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Public transport, especially the rail and bus Public transport and sustainable modes of transport services must be prioritised. Specific are prioritised throughout the plan, particularly policy attention needs to be paid to pedestrian and D14 (Sustainable Transport and Movement). The cycle links as part of the overall infrastructure Infrastructure Delivery Strategy also details commitments. completed and planned improvements.

Flood prevention especially in areas of large Agreed. Flood defence improvements are prioritised new developments. in the Local Plan and discussed in the accompanying Infrastructure Delivery Strategy. Policy B16 also safeguards an area for delivery of the Bridgwater Barrier.

Education needs to be prioritised as already Agreed. Education is a key priority in the plan, under strain with children having to travel to including the allocation of new sites for education school rather than walk, as well as the lack facilities. Policy D30 and supporting text also supports of a Somerset University. aspirations regarding a University for Somerset.

Medical facilities and healthcare needs Agree that the appropriate provision of healthcare attention with people struggling to get facilities is important. Policy D31 (Health and Social doctors’ appointments within 2-3 weeks and Care) is clear that new development that creates a an ageing population increasing demand. need for additional facilities will be expected to meet any identified shortfall.

Open spaces and play areas are required. The saved Local Plan policies have been reviewed, updated and incorporated into the new Local Plan (Policies D36 and D37) to ensure the retention of existing spaces and provision of new play areas and open spaces.

Concern there is no mention of infrastructure A Cheddar bypass is not proposed in the Local Plan. improvements for Cheddar to include a There is not considered to be any prospect for a Cheddar Bypass, improvements to the magic bypass during the plan period, particularly given roundabout, addressing the narrow roads, current funding constraints. A range of transport and parking in the village centre. improvements are identified for Cheddar and it is considered that development can collectively fund these.

With regard to Bridgwater a Northern Relief A longer term transport strategy will be developed in Road could also include part of the barrage parallel with delivery of the Local Plan. Potentially development and flood defences as well as new roads such as this might form part of that longer provide a bypass for Hinkley and holiday term strategy. In the short term the emphasis is on traffic further adding benefits to the whole of improvements to the existing network. The potential West Somerset for a northern bypass has also been considered as part of the appraisal process for the future flood defence barrier, to capture what benefits/savings co-location may have. 26 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Poor sewage systems raised as an Where necessary development would need to infrastructure constraints in some of address any deficiencies in infrastructure, including Sedgemoor's rural settlements (e.g. Mark, sewerage. This requirement is set out in Policy S3. Wedmore).

Sustainable Development Principles

Summary of issues raised How it has been addressed

General support for policy approach. Policy has been included in the Local Plan.

Agree the approach is appropriate, but Policy S1 and Policy S4 accords with the requirements of the wording of each principle should the NPPF. be revisited to ensure it is aligned with the 12 points of the NPPF.

The rural nature of the area and the The protection and enhancement of AONBs is covered desire of many residents to protect within Policy D20 and supporting text that complies with and enhance AONB should be the requirements of NPPF, Natural England and relevant strengthened. AONB Advisory Committees.

Concern that proposing an ever The District Council is acutely aware of development increasing list of criteria will only viability issues and the Local Plan facilitates and impose unreasonable burdens upon encourages development in the appropriate areas. This is development, and are likely to be used identified through land allocations, settlement hierarchies to resist rather than encourage and appropriate Strategic, Place Making and District Wide development. Policies.

Suggestion to include a sustainable Policy D1 (Flood Risk and Surface Water Management) development principle relating to flood and supporting text is the first policy contained within the risk. Living Sustainably section of the Local Plan. Flood risk is also addressed in Policy S5 (Mitigating the Causes and Adapting to the Effects of Climate Change).

Concern that the role of transport in Policy D14 Sustainable Transport and Movement and sustainability is insufficiently supporting text is considered to comprehensively address documented. this concern.

The priority for brownfield sites in the The Local Plan is consistent with the NPPF. The Vision Local Plan needs to be strengthened meets the requirements of the NPPF by stating; ‘The reuse to reflect the Government’s current of brownfield land will be prioritised wherever possible…’. priorities. This meets the NPPF para 17 that states;

‘encourage(ing) the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value;’ Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 27

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

In addition the NPPF para 111 states;

‘Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.’

Principles on the infrastructure already Overall the Local Plan evidence base takes into account in place; motorway links, rail links, bus existing infrastructure and through this work identifies services and cycle paths should be settlements that are sustainable and suitable for included, particularly for rural areas development. which will always have to rely on cars.

The energy efficiency of all The following Local Plan Policies and supporting text all developments is a major factor. support energy efficiency in development.

Policy D2 (Promoting High Quality and Inclusive Design)

Policy D3 (Sustainability and Energy in Development)

Policy D4 (Renewable or Low Carbon Energy and Heat Generation Projects)

Policy D5 (Renewable or Low Carbon Energy and Heat Generation in New Developments)

Climate change needs to be taken into The issue of Climate Change is addressed in several areas account under sustainability. within the Local Plan including; Vision and Priorities, Strategic Priorities and District Policies. Specifically Policy S5 and supporting text address Climate Change Mitigation and Adaption.

Climate Change

Summary of issues raised How it has been addressed

Generally strong support of the Policy has been included in the Local Plan. suggested approach to mitigating the causes and adapting to the effects of climate change.

Insufficient detail as to how the Council The Local Plan addresses tidal, fluvial and surface water plans to protect the tidal flood plains. management. Specific projects related to Bridgwater strategic flood defence are detailed in Policy B16 and supporting text. Policy D1 and supporting text 28 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

comprehensively addresses Flood Risk and Surface Water Management in the District.

The approach could be strengthened to The Natural Environment section includes Policy D23 reflect more recent policy and clearly Trees and Woodland and supporting text that specifically recognise the value trees and woodland reflects recent and up to date guidance on the value of can provide, particularly as components Trees and Woodland. of green infrastructure. The Green Infrastructure section of the Local Plan is comprehensive and references that a Trees and Woodland Strategy will be prepared in due course.

Concern that the siting of solar panels Policy D4 and supporting text addresses Renewable and and wind turbines in rural and tourist Low Carbon Energy generation specifically identifying areas will surely have a detrimental that high regard will be given to visual impact issues on effect, especially when viewed from landscape character areas. AONB and should instead be restricted to industrial developments and offshore.

Concern that the impact on existing The Local Plan addresses tidal, fluvial and surface water properties in areas of high flood risk is management. Specific projects related to Bridgwater not considered. strategic flood defence are detailed in Policy B16 and supporting text. Policy D1 and supporting text comprehensively addresses Flood Risk and Surface Water Management in the District. Specific consideration has been given to existing residential areas that may be impacted upon as a result of new development through the sustainability appraisal process and residential land allocations reflect this.

Settlement Boundaries

Summary of issues raised How it has been addressed

General support for the principle of retaining Boundaries have been retained in the Local boundaries. Plan.

Confusion caused by not showing committed To provide clarity significant committed development as falling within the boundaries, this development has now been shown on the should be made clearer. Policies Map for information purposes. For the reasons set out in the settlement boundary review paper it is not considered appropriate to draw settlement boundaries around committed development until it has been substantially built out. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 29

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

A range of alterations suggested either related to Full details and justification of the approach the inclusion of specific sites or so that the to defining settlement boundaries, including boundaries better reflect the extent of the consideration of suggested alterations, is set settlement. out in a settlement boundary review paper available in the evidence base section of the Some concerns raised that the boundary have not website. been extended, therefore limiting much needed development potential for the new plan going The boundaries are not considered to be forward. overly restrictive given that detailed criteria policies indicate where development outside Some objections to using settlement boundaries. of settlement boundaries will be considered. Argued that it is not consistent with the NPPF and that sustainable development should go ahead without delay.

The Local Plan should not have overly restrictive settlement boundaries or other policies that place blanket restrictions on what would otherwise be appropriate locations for development.

Concern that the boundaries are only acceptable if The settlement boundaries only seek to define they are respected by the local planning authority, the current built form of settlements. In taking when considering development outside the a positive approach to delivering local boundaries. affordable housing need and other priorities it is considered appropriate to set out criteria whereby sites outside of the settlements boundaries will be considered for development.

Bridgwater Objectives

Summary of issues raised How it has been addressed

Concern that there is not much detail about There are specific polices (MIP) that address the impact of HPC. impacts of HPC. Additionally annual monitoring reports on impacts whilst there is also an agreed mitigation strategy set out through the DCO.

The Place-making Policy for Bridgwater should Noted and visual impact from AONB is a be amended to make reference to new consideration that has helped shape the green development in Bridgwater “responding infrastructure components of allocations to the west sensitively to its AONB backdrop”. and south of the town.

Concern that we should not build on greenfield The Local Plan does not seek to meet the land to house Hinkley Point workers. accommodation needs of construction workers, this is set out in the accommodation strategy in the DCO. Allocations in the plan are required to meet the objectively assessed housing needs of the 30 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

district that exclude temporary accommodation needs.

Concern that Bridgwater cannot sustain future Noted and the overall development levels and growth at the same rate as in the last 5 years specific allocations take into account transport unless the transport strategy is sorted out, as constraints. The plan is supported by traffic the road network in Bridgwater is insufficient modelling and requirements to mitigate significant to take the current volume of traffic adverse impacts.

Building too many houses for the HPC The plan does not seek to provide temporary construction period will cause major workers accommodation. devaluation of property once complete, unless it is ‘student-like’ accommodation which can be altered to plan for higher education facilities

Bridgwater Vision

Summary of issues raised How it has been addressed

The developments proposed at Cokerhurst The site north of Chilton Trinity is not included in the Farm and Chilton Trinity are too large and Local Plan, partially due to the need to address the don’t have the infrastructure planned infrastructure requirements. The Western Extension will deliver a range of necessary infrastructure to support development.

Agreement, provided that the funding for Much of the infrastructure on strategic sites will be the projects is coming from developments secured through specific S.106 agreements. Priorities within the area itself, and not being pulled for community infrastructure levy spend are set out in in from the whole district to fund the Councils R.123 list that is reviewed annually. Bridgwater alone

The Bridgwater Vision should refer to Noted. The Bridgwater Vision is an aspirational specific strategic sites once they are document which does undergo periodic refresh and is determined and recognise the contribution only referenced within the Local Plan rather than being that these sites will make to the Bridgwater controlled by the Local Plan. Vision

Flood protection needs to be prioritised Agreed and it is through the R.123 list. Delivery of the Bridgwater Barrier is currently being progressed with an end date of 2024. The Local Plan safeguards potential sites for the barrier.

Improvements to the Bridgwater and Bridgwater docks are included within the Bridgwater Taunton Canal should be included along Vision projects. Opportunities to improve the canal are with work to improve the general dependent upon funding and will be kept under review, environment at Bridgwater Docks particularly as the Bridgwater Barrier implementation progresses. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 31

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Brownfield sites need to be prioritised Brownfield sites are encouraged but opportunities are finite and limited. Retention of employment within the town is also an objective.

Bridgwater Housing

Summary of issues raised How it has been addressed

Overall in terms of ranking, Option E (Land South Noted, the plan needs to includes all of these of Dawes Farm) and Option C (Land East of options in order to meet the OAN's of the Bower Lane) most preferred. Option A (Western District. Extension) least preferred.

Strong objection to any proposal to develop the Land to the west of Bridgwater is sequentially land on Cokerhurst Farm, as an over development preferable in flood risk terms and the Cokerhurst of 1,200 houses will lead coalescence and Farm site is included as a preferred greenfield Wembdon losing its village identity, and an site in the Core Strategy. The illustrative inevitable increase in local traffic making it unsafe. masterplan seeks to protect the identity of Wembdon, provide large areas of greenspace Objection to Option A as the site is currently prime and requires the traffic impacts of the agricultural land which is a haven for wildlife and development to be appropriately mitigated. has extensive views to the Quantock Hills which will be destroyed. Detailed design will seek to maintain views of the AONB and provide appropriate ecological Objections to Option A on the basis that it is not stepping stones and corridors through the in keeping with the size and character of extensive inclusion of green infrastructure. Wembdon. Opportunities associated with delivering a northern relief road should be given far high priority than development in the Cockerhurst Farm area.

Objection to Option E South of Dawes Farm as There will be a need to provide a transport there are concerns about the proposed access impact assessment to support development. road and Junction 24 However, Huntworth Roundabout has now been upgraded providing capacity improvements.

Concern that the proposed development at the Noted. This site is not allocated although there land North of Chilton Trinity/South of Dunball is remains future potential. However, promoters in Flood Zone 3 and is liable to surface water will need to demonstrate how flood risk and flooding, which will add to the developers costs other infrastructure can be delivered. The to raise ground levels. Bridgwater Barrier and associated downstream flood bank improvements will also need to be It will destroy an attractive countryside amenity taken into account. area and habitat/wildlife, and will result in increased car use. Required infrastructure is not Detailed ecological surveys and mitigation would in place. The development should therefore be be required if this area was developed. opposed. 32 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

It could also have an impact on the Steart Whilst the site is some distance from Steart, the Marshes which is very close and could affect the site is within the zone of influence. This would purpose of the project to create an area for birds need to be fully assessed as part of any and wildlife. proposal. The site is not allocated in the Local Plan as there remain many detailed technical However some support for option B if its achieves issues that need to be more fully understood. delivery of a link road to the A39, allowing traffic in west Bridgwater easier access to the motorway.

Option C promoted for development alongside Noted, the Local Plan allocates these sites. Option D as an available, achievable and deliverable site to meet Bridgwater's housing The southern extension of the distributor road needs. It can include appropriate access, a noise is not being promoted as it has limited benefit bund, biodiversity corridor and high quality green and is engineeringly challenging to deliver. space.

Development includes a new crossing of the railway. Close consultation with network rail therefore required on design and funding.

Alternatively, the higher ground between Durleigh This land has not been promoted or otherwise and North Petherton would be an excellent place identified through the SHLAA or consultation. for new development in the longer term

Agreement a barrage near Dunball would keep The current flood defence scheme is for a tidal the Parrett water fresh through Bridgwater, sluice rather than exclusion structure. The improving the appearance for tourists Parrett will remain tidal and the barrier only operated at times of very high tide or to assist with upstream fluvial flooding. There may be potential in the future to operate it differently but there are considerable environmental impacts in a permanent penning structure.

The construction of HPC will only have a limited Agreed. The Local Plan does not plan temporary effect on the demand for housing for 8-10 years worker accommodation. The OAN's are for so any new housing proposal should not be permanent housing to meet demographic influenced by it. change and migration.

Housing development in Sedgemoor should only Accessibility to the M5 is only one consideration be considered nearer to and with good access to but sites to the east and south of the town do the M5, with minimal effect on the traffic routes in have relatively good connections. Bridgwater

Concern that the infrastructure will not be The Western Extension will support the improved to support the relocation of Haygrove provision of a new school at Queenswood Farm School, and traffic cannot use the A39 alone along as part of the comprehensive planning of the with Hinkley traffic area. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 33

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Development should use sustainable materials Policies in the Local Plan including S5 promote and renewable energy to have a limited impact sustainable construction and provision of on the environment renewable energy.

A bypass from Dunball to Cannington is needed A longer term transport strategy will be developed in parallel with delivery of the Local Plan. Potentially new roads such as this might form part of that longer term strategy. In the short term the emphasis is on improvements to the existing network.

The transport modelling work need to assess the Noted. This forms part of the evidence base. potential impacts arising from strategic development in the Bridgwater area, including impacts on the strategic road network and the scale of mitigation that may be required.

Housing Renewal Areas

Summary of issues raised How it has been addressed

Hamp and Eastover could both be Opportunities for redevelopment are supported but the rationalised and rebuilt upwards to relieve focus is on improving the local environment for existing pressure on Greenfield communities, not delivering high density high rise housing that does not meet their needs.

Bridgwater - Employment

Summary of issues raised How it has been addressed

Objections to Option L Huntworth J24 employment The site is well related to the M5 and would site. Argued that the land is Greenfield and has avoid commercial traffic having to travel through considerable flood related issues. the town. There are no significant flood issues given that the site is not at flood risk. In terms It is also identified as Minerals safeguarded area of mineral extraction there are no intentions to in the Somerset Minerals Plan. actively extract minerals from this area.

Concern that Option L would greatly increase the Question why commercial traffic would want or level of traffic, particularly lorries on the C class need to use this route when there is easy road leading from Huntworth to Burrowbridge, access to the strategic road network. However, which is already a danger to cyclists and traffic management can be put in place to avoid pedestrians along the stretch of road from this if needed. Huntworth to Moorland 34 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Option L Huntworth J24 promoted as a strategic The Local Plan allocates this site for location for commercial development, including a employment uses. It is not considered an new motorway service stations. Also promoting appropriate location for additional residential an element of residential development between development. the new commercial area and already established residential properties at Huntworth.

There are many sites still vacant without using The approach has been to maximise brownfield greenfield areas which are used for food opportunities. However, there are finite and production and grazing limited sites that are available and commercially attractive and therefore a requirement to consider greenfield sites.

Support of the proposed allocation of Option I This will realistically be considered in a future following the cessation of use as an associated plan review given that construction of HPC has development site in connection with the Hinkley only recently commenced. The site is unlikely Point C project, however the parcels of white land to be available for several years at the earliest. within the dashed area of site I should also be identified as having potential for future development

Sites G and L should be kept and considered for Site G has been allocated for mixed-use that housing due to its location outside the floodplain includes about 300 dwellings. Site L is considered the best located site for new employment uses given the location at J.24.

Concern that Option G does not show a secondary The allocation is now for a mixed use scheme access which was secured as part of Bridgwater and specific reference is made to the secondary Gateway phase 1 and which will be essential for access, this is also shown on the illustrative plan any additional development in Appendix B.

Without exception all the proposed sites would All allocated sites will need to be supported by impact upon the A38 corridor and junctions 23 a transport impact assessment. For large sites and 24 of the M5, Dunball and Huntworth the impacts are likely to cover a wide area. The Roundabouts; need to consider sustainable travel methodology and scope of any assessment will options including rail improvements to support be agreed with the Highway Authority. these sites

The Somerset Bridge development should include Noted, the allocation includes a requirement to improvements to the Canal Towpath to ensure it integrate with existing development through the can be used as an attractive, off-road sustainable provision of public footpaths and cycle ways. transport route

Sites G, K and L could all benefit from the Noted. The need to integrate with existing committed improvements for the cycle and walking development through provision of public network on the southern side of Bridgwater footpaths and cycle ways is included in policy wording. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 35

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

The provision of the Colley Lane access route This is included under Policy B17. would be a big bonus

Bridgwater - Education

Summary of issues raised How it has been addressed

Disagree with the relocation of Haygrove The Western Extension will provide access to School due to the vehicle entrance from the Queenswood Farm. Realistically this is the only site very busy A39, unless traffic can be rerouted available for a new secondary school. Haygrove via a Northern Relief Road Academy Trust remain supportive of this opportunity.

Building large developments to justify new A new primary school is currently under construction schools is not going to solve the identified in the centre of Bridgwater to cater for existing and current shortfall; new primary schools should forecast needs. New development is not required to be located where there is an existing need address existing deficiencies but does need to meet any needs directly associated with new housing.

Haygrove does not need to be relocated, as There is a lack of sports pitches on the existing it can be built upwards/or a 5th school could Haygrove site. It is questionable whether it is either be built in the town, as the school will ruin possible or desirable to build upwards given the another greenfield site accessibility issues. If a 5th school is to be built this inevitably will be on a greenfield site.

Bridgwater - Flood Defence

Summary of issues raised How it has been addressed

Support of the suggested approach to Noted, Policy B16 does this. safeguard the extended area for the barrier

Suggestion to consider a wider area for The safeguarding area reflects the current preferred safeguarding locations following detailed assessment of site options by the Bridgwater Barrier Project Team.

Suggestion to install a barrage in the River The barrier is primarily a flood defence structure Parrett just South of Dunball instead, with a that will be delivered by 2024. The location will bridge to take a bypass road to Cannington need to be the best in terms of flood risk which will reduce the volume of traffic, open management. There are currently no plans for a up land for future development, reduce the northern by-pass or funding for such a scheme. high cost of ongoing maintenance of the River The decision has been taken to ensure delivery of Parrett and create a fresh water river the flood defence scheme given its critical role in protecting existing and planned development. 36 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Generally strong support for early delivery of Noted. Opportunities for wider benefits can be the barrier. Wider benefits, such as impounding considered in the future and the design of the the water for recreational use for recreation barrier will ensure flexibility in operation. and navigation benefits should be considered.

How will infrastructure cope with any Land allocated on land at west Bridgwater (Policy development to the west. There are already B3) will be subject to detailed Transport Impact queues down the A39. Assessments that will identify the existing A39 improvements if any that are required.

Bridgwater - Transport

Summary of issues raised How it has been addressed

An indicative cycle network at 200-400m Significant progress has been made in developing centres should be developed serving all the cycle network, particularly from the south. Further significant trips with particular provision for investment has been secured through the HPC project cyclists along the C182 and A39 that will see investment on the A39 and A38.

Concern that there is no mention of Noted. Junction improvements secured through HPC improvement to the western part of the A39, will minimise the impact of construction traffic. New which desperately needs traffic planned development will be required to mitigate improvements especially with the huge significant impacts identified through a transport increase related to HPC impact assessment.

Strong agreement that a northern Bridgwater These options are likely to be developed further as bypass or an Eastern Distributor Road, or part of the longer term transport strategy fo the town. even both, would be necessary The Eastern Extension will provide for improvements to Bower Lane that will both serve new development and provide wider improvements between the A372 and A39.

Rather than new roads better value for The overall strategy of the plan is to encourage and money would be obtained by facilitating the support modal shift whilst recognising that in a rural modal shift by significant capital investment district such as Sedgemoor there will remain a high in walking, cycling and public transport dependency on the car. New investment is identified therefore in both new roads and new walking and cycle routes.

Traffic is already awful leading to standstill The plan includes a number of new road schemes this needs to be addressed before we have and junction improvements. more development. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 37

Regulation 18 - Main Issues Raised 3

Bridgwater Town Centre

Summary of issues raised How it has been addressed

More leisure facilities are needed to Noted, the Meads Park will continue to be developed along improve health and wellbeing with wider walking and cycling opportunities. The plan includes policies to secure new public open space and contributions to outdoor sports facilities.

Support but 3, 4, 5+ storey buildings Within the town centre few opportunities exist for new with flats and retail uses below should development on the river front. However the Eastover SPD be considered along the waterfront specifically identifies a site suitable for 3 / 4 storey buildings. The Bridgwater Vision also recommends that future river front development can accommodate larger scale buildings. Future potential development opportunities will be approached on a case by case basis through the planning application pre-application process.

Concern that the continuation of retail The policies have been revised to provide for greater frontage policies of the 1970s and 80s, flexibilities and to reflect recent changes in use classes. which impose a restraint rather than The policies reflect the changing nature of town centres support flexible development, will and are intended to support dynamic town centres. repeat the mistakes of the past that have led to dead frontages

Shops need to be improved. Need to Retail is facing challenging times with increasing use of encourage larger chain stores and online purchasing for example. The Local Plan supports better quality shops to the town centre. new retail investment and there are commitments for significant new floorspace at the Retail Park and on Northgate.

Tier 1 Settlements

Summary of issues raised How it has been addressed

It is acknowledged that there is a shortage of Noted, the local plan allocates two greenfield sites suitable sites within the existing built up area of in the Highbridge area. Burnham, and therefore sites need to be identified outside the existing boundary

Most attention should be paid to infrastructure The plan identified a range of infrastructure and self-sufficient containment requirements. Significant additional employment land has also been allocated through the Isleport SPD that will attract new jobs and potentially reduce out-commuting.

More attention should be paid to infrastructure Place making policies for Cheddar set out a range and sustainability before development takes of infrastructure projects that will be delivered place, particularly in Cheddar through new development. Additionally the PC 38 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

will have CIL receipt from new development to spend on local priorities.

Disagreement that Burnham-on-Sea and Agreed. The plan now treats them together as a Highbridge should be treated separately in market town but still retains specific policies for planning terms when it is a single parish the two centres reflecting differing issues and priorities.

Concern that the objectives are too generic for The Tier 1 objectives refer to only Cheddar and progress to be measures against, instead a set North Petherton. There are place specific policies of specific objectives for each Tier 1 settlement included in the plan. Both Tier 1 villages are should be in place developing their own neighbourhood plans that will include more detailed visions and objectives.

Sustainability issues should be addressed These issues have all been considered and including; flood risk, protected open spaces, assessed through the plan making process. The green belt, attractiveness to tourists and sustainability assessment sets this out in sustainable transport links considerable detail.

The objectives do not include support for the Policy BH1 now includes strengthening the areas tourism industry, even though the town of tourism role as one of the objectives for the town. Burnham-on-Sea is recognised as a key visitor location within Sedgemoor

Retain clear boundaries between these The plan retains settlement boundaries and settlements and other adjacent ones policies that seek to generally avoid coalescence of settlements.

Some queries as why there are different The plan now separates Burnham and Highbridge approaches to Tier 1 settlements, some with from the other Tier 1 settlements. Retail policies primary and secondary retail frontages, some seek to support and enhance existing centres with District Centres. The approach need to be whilst providing greater flexibility recognising more flexible and positive and not overly retrain changing shopping habits. development, accepting that centres need to change with the rise of internet shopping etc.

Burnham-on-Sea Housing Options

Summary of issues raised How it has been addressed

Some considered development Options D and E are There are significant transport and flood risk the most sustainable locations for development issues to resolve. The plan refers to potential because they can also provide significant additional future opportunities or growth in this area infrastructure benefits through the delivery of a much should these issues be resolved. needed new relief road. Options E and D should provide a new park and a new primary school adjacent to it to create an island of open space in the middle of the development. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 39

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

More preferable than developing to the east of Frank Foley and Love Lane, which some considered to be the 'hard edge' to the town and development to the east would impact more on landscape and setting to the entrance to the town.

All of the sites at Burnham-on-Sea fall within the flood Sites around Burnham are at risk in the long zone and should never be built upon, as they need term due to rising sea levels. Future technical serious attention to surface drainage and investment studies will identify the most appropriate flood in tidal flood defences defence strategy. The Local Plan therefore does not allocate sites in this area at this time and identifies sites at lower flood risk closer to Highbridge.

Concern that sites D and E remain likely to promote Should development take place at some time unsustainable modes of travel and make limited in the future there would need to be contribution to her promotion of walking and cycling comprehensive provision of walking and cycling infrastructure.

Development proposals of all options will not have Significant additional employment land is the employment opportunities provided, as current allocated through a recent SPD at Isleport. residents already struggle to find jobs

Some support for the location of the site at Love Lane These sites are at flood risk and also have (Option C), given the context of the site in relation to significant surface water constraints that the existing settlement, particularly its location within need a strategic approach to address. The the existing strategic highway network sites are also identified as "countryside around settlements" under Policy D 34. The Some support for site A and site B. Considered by Local Plan does not therefore allocate these some to be the most logical option as the site benefits or other sites at Burnham-on-Sea. from being close to public transport, a Tesco, and is within walking and cycling distance from the town centre and local schools

Transport evidence is needed to understand the Noted and agreed. Large scale housing impacts of growth options on the strategic road growth is not proposed at Burnham-on-Sea. network, and any improvements needed to junction 22 and A38 roundabout.

There are major strains already on education and Noted. New development will need to provide particularly health services in terms of a wait for appropriate new infrastructure needed to doctors appointments. New development will make mitigate any negative impacts. The Local this worse. An extra secondary school would be Plan does not allocate large greenfield sites needed for any new development and King Alfred at Burnham-on-Sea. School will need major development. An adequate number of surgeries, schools, elderly residential care, disabled housing and transport must be included 40 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

More bungalows needed to support the elderly Bungalows can be popular with older persons population and provide an opportunity to downsize. seeking to downsize, often freeing up family sized housing for younger families. Policy D6 refers to both type and size of accommodation and therefore provides the policy framework to seek certain types of housing (such as bungalows) where there is local evidence of need. The policy also seeks an appropriate proportion of new homes to meet accessible and adaptable dwelling standards to allow people to stay in their homes for longer.

Burnham-on-Sea Employment

Summary of issues raised How it has been addressed

Strong support for the proposed extensions to Noted. The Council has an approved SPD for these Isleport Business Park sites and they are effectively treated as commitments in the new plan.

Concern that there will be no major job boost The recent Isleport extension is anticipated to in the area to provide for new homes being deliver significant additional employment in the built, therefore leading to an increased number area. of people commuting

Sustainable communities can be created by Whilst there are no specific mixed-use allocations building mixed use comprising housing and land at Isleport Lane is close to employment employment opportunities. However, employment uses are not always compatible with residential amenity.

The Love Lane site would be ideal to There is no requirement for additional employment accommodate employment opportunities as it allocation in this plan given the allocation of Isleport is connected to the strategic highway network 2. and provides close links to the existing settlement

Suggestion to create more office based Noted. Policies support such proposals but there opportunities to reduce the commuting out of is limited demand for such uses. The Enterprise the town Centre at Isleport has proved extremely successful and is a more attractive commercial location. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 41

Regulation 18 - Main Issues Raised 3

Burnham-on-Sea Town Centre

Summary of issues raised How it has been addressed

Amend to include the following as These streets are included within the town centre and secondary frontages; Regent Street, designated as secondary frontages. However, further Vicarage Street, Abingdon Street, Princess changes based upon detailed local evidence can be Street and the northern most end of Victoria promoted through neighbourhood planning. Street

Increase the boundary to include up to St. The focus for Highbridge District Centre is to Andrews Church, in line with the suggestion concentrate retail uses within Market Street . It is from the Neighbourhood Planning group recognised that there are retail uses including the post for secondary frontage office along Church Street. The emerging neighbourhood plan is an opportunity to present more detailed local evidence to support an amendment.

Burnham-on-Sea Transport

Summary of issues raised How it has been addressed

The plan should promote the J.22 Highways England have responsibility for motorways improvements first before a relief road as and trunk roads. The Council continues to press for there are already access issues and given investment at J.22. Phased improvements and the proposed Isleport extension these must potential improvements to Edithmead roundabout be sorted are identified in the plan and will be progressed through the plan period.

Disagreement that a relief road between Any relief road would reduce congestion on the Coast Stoddens Road and Brent Road will Road but there would still need to be improvements significantly reduce congestion between the to Edithmead roundabout and J.22. The plan does exit at J22 and the roundabout at Edithmead not promote this option and identifies the need to a strategic transport study to identify the full scope of improvements needed should growth in this area be promoted in the future.

Creation of segregated cycleway networks The plan promotes walking and cycling but must be created for Burnham as it is opportunities for segregated routes within the existing currently car dominated built up area are limited. New development can include such routes though.

Additional car parking and improved rail links Noted, the plan has a specific policy referring to this. at the Burnham and Highbridge railway station

Some comments considered that instead of Given the constraints of existing development this is a relief road a more practical scheme would not practicable. However, continued traffic be the widening of the Coast Road between management and completion of footpaths will provide Berrow and Brean. some limited improvements. 42 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Some support for the Queen's Drive There is no realistic prospect of this being delivered becoming a dual carriageway and ease and it is not clear what benefits this might give. congestion in the area.

Burnham-on-Sea Tourism

Summary of issues raised How it has been addressed

The revenue contributed to Sedgemoor created The plan now includes more detailed policies by tourism businesses in Brean, is far more including the introduction of a tourism boundary significant than that of Burnham-on-Sea, and the through Policy BH11. majority of tourists in the town stay in accommodation in Brean, yet does not have its own suggested approach to tourism

It is important to recognise the year round needs, This is recognised and investment in this sector by providing greater indoor leisure facilities for is supported and encouraged. tourists and residents

The needs of water users including residents and The local plan does not specifically refer to this tourists need to be identified and incorporated into sector although it forms part of the wider tourist the tourism vision for Burnham and recreational appeal of the area. The emerging neighbourhood plan may be the more appropriate plan to develop this topic.

The esplanade is currently dominated by the The Local Plan supports investment in the concrete sea wall and needs to be made more public realm and potentially CIL receipts might attractive for visitors be spent on appropriate schemes. The emerging neighbourhood plan may be the more appropriate plan to develop this topic.

Text should be amended to read “the approach Whilst this specific text has not been carried will be to continue to support a range of high through into the Local Plan both the vision and quality new, enhanced existing and redeveloped the place making policies support and tourist accommodation and facilities, while encourage this approach. ensuring that the needs of the local population are also balanced”

Cheddar Housing Options

Summary of issues raised How it has been addressed

Neighbourhood plan work which has been The levels of growth identified are broadly better informed locally indicated around 200 consistent with the draft neighbourhood plan and houses required up to 2027. Any development effectively identify one further allocation to up to 2032 should be proportionate to this. accommodate the additional housing requirements. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 43

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

The Local Plan is however informed by the 2016 SHMA and so is based on a more robust and up to date evidence base.

Neighbourhood plan work identified Options E The Local Plan allocated both of these sites. and C as the most appropriate sites.

Disagreement that all greenfield sites listed The sites listed during the consultation were should be considered for development as there presented as options for development and it was are sufficient infill and brownfield opportunities not the intention to suggest that all sites were within the development boundary which can need. Detailed assessment, consideration of meet Cheddar’s housing needs evidence and consultation responses have informed the identification of the three sites in the Local Plan. There are however only limited brownfield opportunities.

Any development on Site A should be entirely The plan does not allocate this site although in keeping with the existing look and feel of a redevelopment can be considered under the rural village that sits in AONB and attracts rural borwnfield policy. The AONB will be a very tourism important consideration and development should not extend beyond the existing extent of built development.

Some concerns that Site A is too far away from The starting point will be re-use for employment the centre of the village to be considered as a although mixed-use may be appropriate. sustainable location for housing. It should only come forward for commercial development.

Site A promoted for development. The site is As above any proposals for development on this the only brownfield site option presenting in the site will need to be considered against the rural consultation document for Cheddar and priority brownfield policy. should be given to the development of brownfield sites. It is accessible and largely free from constraints.

Concern that Options B and E significantly The allocations include extensive areas of bat threaten the presence of rare species in the habitat and have been subject to preliminary area, including newts and bats assessment under the Habitats Regulations. Any applications will require detailed ecological surveys and confirmation of the appropriate mitigation strategy.

Concern that the Bloor Homes planning Planning permission has been granted for this site. application for the southern portion of Site B However, there remain opportunities to improve ignores the Parish Council wish to keep this Sharpham Road playing fields and the plan refers section for extending and enhancing a sports positively to this. hub in Cheddar

Site B is in an area that the neighbourhood plan The Plan allocated this site but identifies the is looking to identify as a strategic gap. requirements for extensive green space and enhancement of the western boundary. It did not 44 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

meet the criteria and objectives of the countryside around settlements Policy D34.

Site C has drainage problems that will limit There are no technical constraints to delivery but development. the capacity of the site is suggested to be around 100 units in order to retain extensive open space.

Objection to Option G as it is almost entirely Agree, this site is not allocated in the Local Plan within the AONB for this reason and the availability of alternative opportunities.

Option G promoted for up to 200 homes, with As above, the site is within the AONB. There are an initial scheme of 40 homes. In addition to alternative sites allocated in the plan that are not being an sustainable location and providing within the AONB and that will deliver a range of eudcation benefits the site should be allocated infrastructure benefits. to ensure the Council maintain a 5 year supply of deliverable housing sites.

Objections to Option F as it is on the flood plain This site is not allocated in the Local Plan. and is isolated from the rest of the village

Concern that Options B and C will increase A range of transport improvements are required traffic onto an already busy road including improvements to the magic roundabout and new pedestrian footpaths.

Some concerns that Site D is prime agricultural This site is not allocated although there may be land with poor connections to the village. some opportunities for smaller scale self build if local constraints can be adequately overcome,

Land to the West of Draycott Road A371 should Land in this area is identified for employment uses be considered as a potential housing option in although thee are significant constraints due to the Cheddar as it is not subject to any policy presence of bats. The visual impact from the designations, not at risk of flooding and is AONB is also a consideration and residential outside of the AONB development is likely to have greater impacts, particularly in terms of street lighting, noise and disturbance.

In addition to the SHLAA sites identified as This site is within the settlement boundary and it potential Cheddar Housing Options, the site at is assumed that it will come forward for residential Steart Farm should be allocated for housing, development. It is therefore included within the as it connects easily with the existing village overall housing figures, reducing the net number centre and other facilities, including schools of new homes required on greenfield allocations.

Improved cycle and walking links between any Agreed, this is a requirement for all of the proposed new development and services could offer housing allocations. some mitigation to the impact on the local highway network

Support for self-build in Cheddar as it is the Policy D10 provides support for self-build and most sustainable and cheapest form of custom build housing. affordable housing Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 45

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

There should be a bypass from the A38 to the There is no realistic prospect of this. other side of Draycott Oak

The priority for Cheddar must be to enhance Place making polices support the continued its natural beauty and promote tourism by investment and enhancement of the natural and encouraging the appropriate infrastructure built environment.

Improvements should include pavement Policy C5 sets out identified transport widening, traffic calming measures on Upper improvements. The neighbourhood plan may New Road, improvements to the Magic develop these and identify additional priorities. Roundabout and more short term parking in the village centre

In Cheddar there should be a focus on The plan supports investment and enhancement improving the appearance of the lower gorge but given the limited development opportunities for tourism this is likely to be achieved through funding and initiatives outside of the Local Plan.

The sports facilities need to be expanded and The Local Plan identifies opportunities to improve improved as well as the extension of the the Sharpham Road Playing fields and the Strawberry Line Strawberry Line.

The emerging Cheddar Neighbourhood Plan The neighbourhood plan was only published in has received broad support in the community draft form in the autumn 2016, many months after and it is disappointing that the decisions that the local plan consultation. It has subsequently have been made through that Neighbourhood been considered and the local plan allocates the Planning process appear to have been ignored. two preferred greenfield sites identified in the document as well as setting out supporting policies for village centre enhancement.

There are insufficient facilities to cope with the Cheddar has an extensive range of services and scale of development. Junctions are also facilities. Development proposed in the Local Plan inadequate to cope with any extra traffic is similar to the historic levels of growth over the last 25 years.

Site F identified as a Minerals safeguarded area This site is not allocated. in the Somerset Minerals Plan.

Cheddar Employment

Summary of issues raised How it has been addressed

Site A would be a suitable option for employment The Local Plan rural brownfield policy such as high tech or office based businesses, as supports re-use for commercial uses or traffic generated here would not enter the village of exceptionally mixed-use schemes. Cheddar if the key routes were out to the A38 and M5 46 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

If Site A is further developed, it should be well Agreed. This would be taken into account screened as it is at the entrance to the village and through consideration of the District wide close to Cheddar Wood policies in the plan.

Concern that Site H does not meet the tests of Agreed, it has not been promoted for suitability, availability and viability for employment employment uses and is not identified as purposes such in the Local Plan.

Any development at Site A should be linked with Noted, this will be a consideration should improved pavements to the village, improved street there be a planning application for lighting and the construction of a proper roundabout redevelopment in the future. at the magic roundabout

If Cheddar has to accept significant housing or The plan identifies a range of highway employment development, then road infrastructure improvements although it is accepted that must be improved as roads through the village are there is little that can be done to the A371 already heavily congested through the village centre.

Cheddar Village Centre

Summary of issues raised How it has been addressed

Agreement to encourage genuine tourist Noted, the plan includes policy support for this. commercial activity in the Gorge, to add to the appeal for visitors

Disagreement that the centre cannot be There are limited opportunities but detailed expanded as it is physically restricted neighbourhood planning will be able to identify deliverable projects.

The Lanes site should be concentrated on, and This is dependent upon market interest and could be a good site for a development viability. However, the Local Plan provides broad something like that of the Borough Mall in support for such ideas that might be developed Wedmore further through the neighbourhood plan.

Cox’s Mill needs to be restored as good quality Noted, this is dependent upon new investment accommodation/restaurant/bar so that it but would be supported by policies in the plan. becomes an attractive place to visit or stay at within the Gorge

Introduction of time limited reduced rates to Noted, however business rate reduction is not a encourage business, and encourage full local planning issue. If suitable Cheddar employment as well as support businesses with Neighbourhood Plan would be the most funding to enhance shop frontages appropriate level to identify any shop front enhancement support.

The shopping area needs to be redeveloped There are no alternatives for traffic using the and traffic needs to be diverted, as large HGV’s A372. However, in the longer term potential improvements to the A39 may divert some traffic Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 47

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

and motors go through the town centre with that travels through the village to wells. The plan unsafe, narrow footpaths for pedestrians safeguards the route of the A39 Ashcott-Walton bypass.

Cheddar Transport

Summary of issues raised How it has been addressed

Many Cheddar residents commute to Bristol and Noted although this is not a matter that the to reduce congestion better public transport links Local Plan is able to address directly. between Cheddar/Bristol or Cheddar/Worle railway should be made

A bypass is needed from the A38 to A371 past There is no prospect of this within the plan Draycott Park period.

Alterations and improvements to the Magic Agreed, preliminary design and costing have Roundabout are needed as the layout is confusing been prepared and the plan prioritises this. for tourists that are unfamiliar with the area

Bus routes need to be improved with routes to Noted although this is not a matter that the Bridgwater, Weston-Super-Mare and Yatton. Local Plan is able to address directly.

Concern that future improvements cannot Development collectively can fund schemes realistically be funded by future developments, identified in the Local Plan. The Council is also and Cheddar needs a proper transport plan in developing a district wide transport strategy, place however, large scale new road building is unlikely to be deliverable within current funding constraints.

Cheddar Gorge

Summary of issues raised How it has been addressed

Consider the possibility of a park and ride facility to This was run for a number of years in the limit cars through the gorge commercial area 1990's but ultimately was not commercially viable.

Thought should be given to further developing the Noted, the plan positively supports new Gorge as an outdoors/adventure centre investment and attractions to widen the tourist appeal of this area.

The ticket costs to the caves should be reduced, as Noted but this is not a matter for the Local the decline can be pinpointed to when single tickets Plan. were put into a combined ticket 48 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

The area should be opened up by removing as many These detailed ideas should be considered walls, hedges, fences and railings as safely as possible through either the neighbourhood plan or and the garden of fragrance should be demolished and a specific development and design strategy made into an attractive seating area. In conjunction for the gorge. with Bristol Water and Longleat, the idea of enhancing the river view could be considered

Protection of the natural environment and beauty of Agreed, it is offered significant protection the Gorge from insensitive or large scale commercial being within the AONB and also home to development is important many protected species.

Speed controls in the Gorge itself are needed to Noted, this is a matter to be taken up by discourage dangerous driving and ensure pedestrians the County Council. feel safe to walk through the Gorge

Highbridge Housing Options

Summary of issues raised How it has been addressed

Concern that access to Alstone is not good, Noted. This site is not allocated in the Local especially once Brue Farm has been developed and Plan. it is near the important wildlife area on the banks of the Brue/Parrett

Both sites should provide strategic land drainage for An appropriate surface water drainage the area in the form of tidelock storage and direct strategy will be required for the allocated site discharge to the River Brue at Brue Farm.

Objection to either development options as The Local Plan does allocate further land at Highbridge has had enough housing in the recent Brue Farm and this will contribute to past and has benefited very little from it. The sites necessary infrastructure including potentially considered would lead to over development of health facilities if required. Additional growth Highbridge, with no consideration of services, such in the area will help assist in supporting as police, social care and education. Highbridge District Centre.

Consideration should be given to the north of These areas have been assessed but are at Highbridge, such as east/west Poples Bow or even higher flood risk and not deliverable in the west of the railway line short to medium term.

Highbridge Employment

Summary of issues raised How it has been addressed

Strong support for the release of further industrial Noted. Isleport 2 SPD has now been adopted land, however the amount of land suggested is and provides opportunities for a phased release of land to meet current and future demand. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 49

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

disproportional to any anticipated demand and needs to be reduced to an appropriate level.

Agreement that the majority of jobs will be at The Local Plan provides support for Isleport but that should not be all of the jobs employment proposals through BH5 planned. specifically.

Objection to Option E, due to its extent it would be Noted, a reduced area is allocated through the considered an over provision and would have a Isleport SPD. detrimental effect upon the nature of this open greenfield area.

Option C is logical as infill between current This land is now allocated for housing, development and the M5, and allocations should consultation on the Isleport SPD did not support be restricted to land to the east of the A38 only. employment uses here.

The land behind the Co-operative Store off of Policies in the plan would support commercial Market Street should be considered. proposals here although it has not been promoted for such use.

Redevelopment of Market Street and Church Noted although this is dependant upon demand Street shops. and viability. The plan supports investment in the district centre.

The ‘wasteland’ behind the Co-op to the north of Noted. The Local Plan provides support for Market Street would make an excellent car park additional car parking to serve the station and extension for the station. if available this land can be considered.

Highbridge Transport

Summary of issues raised How it has been addressed

General Agreement for the approach Noted. Transport Policy (BH8) included in the plan.

The A38 corridor and mainline rail services Noted and agreed. should be considered as significant opportunities to offer sustainable travel options.

Consider investment in creating a high quality, Within the current financial constraints it is unlikely high frequency bus service to a wider area. that this is achievable. However, the Local Plan includes policy support for alternative modes of travel to the car.

Improvement of cycleway and pedestrian routes, Agreed, Policy BH8 supports investment into especially to link Highbridge to Isleport. walking and cycle routes. Detailed schemes can be promoted through neighbourhood planning. 50 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

North Petherton Housing Options

Summary of issues raised How it has been addressed

Objection to the proposed development site in Noted. The Local Plan does not allocate this Shovel Lane as there is a narrow strip of land site. between the field and the highway owned by a third person who will not sell the land. It is also prime agricultural land. It has been rejected on previous occasions. Site E identified as a Minerals safeguarded area in the Somerset Minerals Plan.

Concern for Sites A and C as they are in the flood Only part of these sites are within the flood zone and will suffer from noise and air pollution from zone and therefore development could be the adjacent M5 motorway achieved. However, the Local Plan does not allocate these sites.

Concern that when proposed developments set their The methodology and scope of any transport traffic plans, they use old traffic flow data and never impact assessment is agreed with the seem to take any other developments yet to Highway Authority. start/outside the area into account and the impact they will have on Sedgemoor.

Options A, B or C should incorporate an Options A and C are not allocated in the plan. improvement to Newton Road which presently has Option B is allocated for about 40 houses issues. and can be accessed from existing roads with minimal impacts.

Facilities need to be increased to cope with a The Local Plan does not propose this level potential increase of a further 1500 to 2000 people of growth at North Petherton. Additional living in the immediate area facilities are planned for housing allocations to the south of Bridgwater.

Option B promoted as being a sustainable location Agreed, the Local Plan allocates this site. with no overriding constraints on development. Up to 40 dwellings deliverable in the short term.

Provision of sufficient school spaces and associated Noted. The plan allocates a site for a new community facilities is essential for any new primary school at Willstock Village that will development. Current provision is under strain or increase school capacity in the area. inadequate, particularly in relation to GP and education provision.

Concerns raised over the treatment of Stockmoor This is not a Local Plan issue as such. The and Wilstock as part of Bridgwater in planning terms. original "South Bridgwater" allocations were They are not marketed as such and communities strategic extensions to Bridgwater, as are consider them to be villages with the North Petherton proposed additional sites allocated in the area. plan. It is a fact that the sites are currently within North Petherton Parish.

Opposition to further development on Option G This site has been allocated for mixed-use (Bridgwater gateway). Will have a huge negative development. It is required to deliver appropriate additional infrastructure. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 51

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

impact on local infrastructure and is out of keeping with the vision for the new villages.

Opposition to site L given the major impacts it will Development of the site will need to include have on Huntworth village which already suffers from appropriate landscaping and mitigation to serious highway problems. Some support however reduce impacts upon existing properties. for relocation of the motorway service area. However the site is well located to the strategic road network and offers commercially attractive opportunities for new employment.

North Petherton Transport

Summary of issues raised How it has been addressed

Consideration should be given to the issue The Local Plan supports management of on-street of parking on the A38 to make it more parking on the A38 and the potential to provide accessible for cycling additional off-street parking.

Transport issues a major concern. New Noted, the transport requirements for the allocations development should include proper provision will be identified through a traffic impact assessment. for parking, access and community transport. Current roads are inadequate.

Plan needs to recognise the severe problems This roundabout has now been upgraded through associated with the A38 and Huntworth the introduction of new lanes and signals. roundabout. This will be future exacerbated in the future during Hinkley construction.

Consideration should be given to This matter was consulted upon during the additional re-evaluating a bypass for North Petherton consultation. Allocations may potentially provide for a new link between the A38 and Newton road and any future consideration of a by-pass will need to be supported by detailed technical transport work. This will be a matter for a future plan. Local congestion may be eased through alternative on-street car parking management in the short term.

Tier 2 Objectives

Summary of issues raised How it has been addressed

The suggestion of Tier 2 developments contributing Noted, the overall level of growth for each to district wide requirements is only acceptable if settlement has been assessed taking into large scale housing development of up to 40 account these and other factors. Development 52 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

houses is matched with improvements to local also offers opportunities for investment in new schools, health and community facilities. infrastructure.

Support of approach but would suggest that no Tier Noted. There is no planning reason for this but 2 settlement should be proposed for more the detailed assessment of the role and development than the smallest Tier 1 settlement. function of settlements and the need for development to be in character means this is likely to be the case.

The impact of wider District needs would have a The suggested growth for Wedmore reflects negative impact on Wedmore and require improved the constraints of the village. transport infrastructure.

Axbridge needs affordable housing if it is to meet Agreed, affordable housing would be provided the district wide need. as part of any housing development in line with the District wide affordable housing policy.

Concern that in respect of Wembdon, the phrase Noted. Wembdon is now identified as a Tier 3 “acknowledging that these settlements can play settlement. their part in helping to meet District wide development needs” is not acceptable given that Wembdon has already absorbed more than its fair share of locality based housing.

Strict design principles must be adhered to so that Agreed, Policy D2 provides detailed design developments are sympathetic to each community guidance.

Tier 2 includes a very diverse group of villages, so Agreed, the Local Plan includes an indication consideration must be given to whether this applies of the different levels of growth reflecting the to all villages in the same way and whether the differing constraints and opportunities of the precise wider role of each village can be made settlements. clearer.

Disagree as it is considered that insufficient The settlements have a good level of services evidence has been presented as to why Tier 2 and provide sustainable development settlements should take on this enhance role. opportunities. However, as above, based on detailed sustainability appraisal work, differing growth levels are identified.

Tier 2 Housing

Summary of issues raised How it has been addressed

Some concerns that it us unclear why the Council would The intention is not to delay delivery delay allocating sites at Tier 2 settlements. Also a criteria and Policy T3 enables consideration based policy does is simply defers consideration to a later of proposals in advance of either a stage, and will create uncertainty. neighbourhood plan or site allocation plan. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 53

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

The policy should be sufficiently flexible to ensure proposals Agreed. are considered on their individual merits.

Some support for combination of site allocations and a Noted. This is reflected in the Tier 2 criteria based policy to be positive and provide certainty, policies. while still ensuring a flexible approach so the Local Plan can respond to rapid change in accordance with NPPF.

Where possible allocations at Tier 2 settlement should be Noted, the Council will prepare a site included. allocations document subsequently and neighbourhood plans are also able to allocate sites.

For Cannington in particular some support for having a Noted. This is reflected in the Tier 2 criteria based approach, and not allocating development policies. sites in Tier 2 settlements. This would be consistent with the approach being taken in the emerging neighbourhood plan, allow a more flexible approach to development opportunities, and ensure locally important issues are addressed.

Axbridge Housing Options

Summary of issues raised How it has been addressed

There are two sites on the reservoir side of Cheddar Road that are The Local Plan does not not included in the plan, that are within the development boundary allocate sites in Tier 2 and suitable for development. settlements but these detailed comments will be considered Concern that developing Site A to its limits would overwhelm the and help inform either area, and instead new homes should be distributed across all sites on-going neighbourhood and carried out by separate local builders. planning work or any subsequent site allocation Site B is not suitable as it is in the flood plain. document. The sites do not appear to be integrated into the town, particularly sites C and D.

Consideration should be given to starter homes for people whose parents live in Axbridge; there are quite a few areas which would be ideal for new starter homes.

All sites have significant highway constraints.

Necessary to increase the capacity of the local school and surgery.

Car parking spaces requirements will need to be carefully considered as well as on road parking. 54 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Public transport needs improving if there will be an increase in people wishing to commute to work outside of the area.

Housing should be dispersed rather than having small estates which There are limited will be unsympathetic to the character of the ancient town. opportunities for infill within the town and development of such sites may also prove challenging in such a historic settlement.

Axbridge is bounded by AONB and is an ancient market town. The The scale of growth proposed scale of development suggested is inappropriate and will further in the Local Plan recognises exacerbate the A38 junction at cross and make it more dangerous. these constraints.

Berrow Housing Options

Summary of issues raised How it has been addressed

Site A has some access constraints; wider highway Berrow is now considered as a Tier 3 mitigation would be required, part could be served off settlement in the Local Plan. In any case Rosetree Paddock but there would probably be issues the Local Plan does not allocate sites in with junction capacity and approach roads Tier 2 settlements but these detailed comments will be considered and help Site B is problematical, and would require detailed inform either on-going neighbourhood analysis of the adjoining road network and junctions planning work or any subsequent site allocation document.

Cannington Housing Options

Summary of issues raised How it has been addressed

The land to the west of the Browning’s and Oak Tree Way The Local Plan does not allocate Estate should accommodate 50-60 homes. sites in Tier 2 settlements but these detailed comments will be Site A should be split into 2 areas; one south of Denman’s considered and help inform either Farm and one for the rest. on-going neighbourhood planning work or any subsequent site The area north to site A, accessed from Denman’s Lane and allocation document. alongside the Brook should be turned into a recreation area/green corridor.

D, E and F are identified as Minerals safeguarded areas in the Somerset Minerals Plan. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 55

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

The completion of the bypass around the village will Noted. Opportunities to be considerably improve environmental traffic conditions and considered in more detail through provide further development opportunities. either on-going neighbourhood planning work or any subsequent site allocation document.

The provision of the Hinkley Park and Ride site provides a Noted. sustainable transport solution for Cannington residents to access Hinkley.

Nether Stowey Housing Options

Summary of issues raised How it has been addressed

Concern that the junction at this point of the A39 is a regular accident The Local Plan does not site and this would worsen with the additional number of vehicles turning allocate sites in Tier 2 on/off the A39. settlements but these detailed comments will be Concern there is no adequate pedestrian link to the centre of the village considered and help from this site; the path along the A39 would need considerable inform either on-going improvement and maintenance. neighbourhood planning work or any subsequent Safety improvements including traffic control and safe pedestrian site allocation document. crossings needed at A39 and near the school.

Housing is needed specifically for the older residents to support independent living for longer.

Puriton Housing Options

Summary of issues raised How it has been addressed

Site D should be considered to be developed only on the The Local Plan does not allocate sites west side of the new road. in Tier 2 settlements but these detailed comments will be considered and help Concern that Site D is the location furthest away from the inform either on-going neighbourhood junction with the A38, without any additional infrastructure planning work or any subsequent site planned which will increase both vehicle pollution and allocation document. congestion through the village.

Site A is considered entirely inappropriate for development as the site’s proximity to the motorway makes it unsuitable due to air and noise pollution. 56 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Sites A and B would result in the loss of greenery at the village entrance and would have an adverse impact on the open and rural aspect of the entrance to the village.

Sites A and B could be developed without any changes to infrastructure and with very little impact to Puriton Village.

Concern that Site C presents a possible restriction to the expansion of the school and access issues.

The area of the west of Hillside, between existing housing and opposite the junction with Cypress Drive, might be considered for housing development.

There is an existing shortfall in the provision of land for affordable housing, housing suitable for older residents and self-build plots.

Downend should be recognised as a sustainable community Downend is included as a Tier 5 and included in the Tier 2 status, whilst maintaining its own settlement reflecting the limited identity, as it is within close proximity to the M5 Junction facilities but also its relationship to 23. Puriton.

Appropriate and high quality expansion of the school Noted. Policies in the plan ensure required to accommodate the additional families. appropriate contributions to increase school capacity where there would be a negative impact.

Improvement is needed to link the village with its hamlets, Improvements in the cycle network will by the provision of a safe pedestrian and cycle overpass be delivered through HPC and it has at Dunball roundabout. been ensured policies in the plan provide support for this.

If the village must accommodate more houses then parking Parking standards requirements have must be addressed. been included in Policy D15 (Managing the transport impacts of development)

The rectification of the drainage problems in the village to Noted, growth may provide resolve the recurrent problems with flooding. opportunities for investment into surface water drainage, with particular reference to surface drainage needing to be addressed through development included in Policy D1 of the Local Plan. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 57

Regulation 18 - Main Issues Raised 3

Woolavington Housing Options

Summary of issues raised How it has been addressed

Option A promoted for development as it is of a size that would allow for significant The Local Plan community benefits and infrastructure to be delivered in a comprehensive mixed does not use development including; employment, education facilities, open space and allocate sites in specialist housing including homes for the elderly and self-build. Tier 2 settlements but Option A would provide the opportunity to be phased whereby the level of these detailed development could be increased to meet wider housing needs of the District in comments will the future. be considered and help inform Concern that option A would need to be matched by greatly improved access into either on-going the A39. neighbourhood Development of option B could result in making worse the dangerous junction at planning work the junction of Vicarage Road/Higher Road/A3141. or any subsequent site Option B promoted for development as a logical site for new housing, defined on allocation 3 sides by existing development. It has no significant constraints and is an document. opportunity to deliver market and affordable housing.

Concern that Site C is very close to the Crocker’s Hill development underway on the other side of the road and will produce unmanageable traffic congestion at peak times.

Support for Site C which can be easily accessed directly from Woolavington Road with nearby services and facilities, providing the opportunity to sustain and enhance services within the settlement.

Option D no longer viable as being used for necessary cemetery extension.

Wembdon Housing Options

Summary of issues raised How it has been addressed

Concern that Option A raises safety concerns regarding access onto the B3339 and Wembdon is that part of the road has no pavements either side of the highway for pedestrians. now classified as Site A is at the highest point in the village of Wembdon and is highly visible from a Tier 3 the surrounding area so new development would be detrimental to the visual aspect settlement of ‘open’ greenbelt countryside. and any further Options B and C would lead to an unsustainable increase in traffic along an already growth would busy narrow residential road. be directly 58 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Site C lies within a higher risk flood zone area and should not be developed when linked to there are lower risk sites available elsewhere. meeting identified There area already major problems with parking and traffic in the vicinity of site C. local needs. It is not a suitable location for development.

Some support for Option B as the site is sustainable in terms of its location, being within walking and cycling distance of local services and facilities which would reduce the reliance on cars for their daily needs.

Additional housing would bring additional custom to the village shop and inn but would generate parking issues at both sites.

A good proportion of affordable housing should be provided.

Any development would have to bring improvements to education and traffic management in the village.

Site A and B identified as Minerals safeguarded areas in the Somerset Minerals Plan.

Wedmore Housing Options

Summary of issues raised How it has been addressed

Concern that the Wedmore retail offer, medical and educational Noted, this is reflected in the facilities could probably service a further 100-150 dwellings in suggested level of housing growth the village over time but not the number suggested. Agreement set out under Policy T3. that there is scope for new housing in the village, but should be of a scale that is in keeping with its character and historical development.

Development cannot be permitted in the village without relief Transport issues have been fully from current volumes of traffic; speed control measures and considered and are one factor for new routes around the edge of the village must form an integral the lower growth identified in the part of the conditions. Local Plan.

The installation of a new pavement system and cycle paths around the village would be an improvement to keep residents/children safe. Roads are congested and unsafe for pedestrians and cyclists.

There is no extra development for employment therefore people This issue has been fully living in new developments will have to commute to work, considered and is one factor for increasing peak traffic, more should be done to encourage small the lower growth suggestion. businesses to locate to Wedmore. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 59

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Wedmore Surgery needs to be expanded as there are currently Potentially new development long waiting times to get appointments. might be able to assist in the delivery of new facilities. Policy D31 provides support for this and the need to meet any identified shortfall.

Concern that much of Wedmore is in a conservation area, so Noted. Protection and must ensure that the character and historic elements are fully enhancement of the historic protected. environment in included in relevant policies in the plan.

New development including accommodation suitable for older Any new development provides residents to downsize, to release homes for families. Some an opportunity to deliver a range support for new affordable housing to keep young people in the of housing types and tenures to area. A higher level of affordable housing is needed in Wedmore meet local needs. as people are often unable to afford to remain within the village and are forced to move away from the area.

Concern that Site A would impact visually on the eastern The Local Plan does not allocate approach to the village. sites in Tier 2 settlements but these detailed comments will be Development on Site B has been refused 5 times, including 2 considered and help inform either Planning Appeals by Planning Inspectors, and is unsuitable for on-going neighbourhood planning all the reasons given in these appeal decisions. work or any subsequent site allocation document Site C would be far too large, a smaller development would be more acceptable.Site C identified as Minerals safeguarded areas in the Somerset Minerals Plan.

Strong objection to build up to 200 new dwellings despite the housing shortage as the infrastructure could not cope with an additional number of vehicles through already congested roads.

Sites D and E are both in an excellent location and ‘historic environment’ considerations don’t apply.

Concern that Wedmore has very many springs in the area which cause problems with flooding.

Other already consented sites should be included when looking at the total number required as 50+ dwellings have been approved for Cross Farm. 60 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Tier 2 Employment

Summary of issues raised How it has been addressed

General agreement of the approach. Noted. Appropriate scale employment is supported by Policy D16.

Disagree that there is employment development Noted although the plan does support potential in Wedmore, however it is in easy commuter appropriate scale employment development. distance of Highbridge and Cheddar assuming the transport infrastructure is improved.

Tier 3 Housing

Summary of issues raised How it has been addressed

Strong support of the approach. Policy T5 sets out detailed criteria for the release of sites primarily Some small scale development outside of the development boundary to meet local housing or may be necessary to support local needs. infrastructure needs. Guidance on starter Greater clarity is required on what is meant by a “range of criteria” upon homes is still awaited. which development outside settlement boundaries will be considered. With a change or approach detailed in the Policy should also make provision for the development of starter homes. Housing White Paper. Criteria policies for Tier 3 and 4 should consider "grouping" settlements and targeting development on sites that will improve the self containment of the whole group.

Tier 4 Housing

Summary of issues raised How it has been addressed

Agreement to support affordable housing in Tier 4 settlements. Policy T10 provides opportunities for both Agree with the approach as the provision of additional housing to smaller local needs affordable villages is needed to maintain existing services. housing and some small scale market housing. Strong disagreement of the approach as it limits any open-market Additionally the plan has dwellings which are essential to sustain the important services and support for self build and facilities, unless approach allows small scale proposals for infill market self commissioned housing on suitable sites within the development boundary. housing within or adjacent to settlement boundaries. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 61

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Concern that the approach only cover large developments, and should also cover the complete housing implications including self-build.

Tier 5 Housing

Summary of issues raised How it has been addressed

Disagreement with the suggestion that developments “will be considered Policy T11 provides through detailed policy wording” as this is ambiguous and open to Policy exceptional opportunities interpretation. for small scale development but high Concern that criteria based policies can be used to resist almost any levels of local community development, rather than encourage economic and housing development. support are required. It is considered that if the Tier Strong agreement that development boundaries are needed for Tier 5 5 settlements had settlements to define the places where “limited” infill is appropriate and settlement boundaries it to prevent ribbon development. would imply acceptance Concerns that relaxing the approach to some settlements by identifying of development within them as Tier 5 will lead to inappropriate development being permitted. them. Any development Clear criteria/definitions should set out explicitly what very small is considered development can be allowed, so its is not open to wrong interpretation. exceptional.

Countryside

Summary of issues raised How it has been addressed

Consider limiting small caravan and camping sites popping up to support The Local Plan Policy T12 countryside protection. provides support for appropriate rural Flexibility in the policy is important, for example to support the enterprise including tourist Bridgwater and Taunton Canal with a hire boat base or marina. related development. Rural businesses are diverse but face a range of challenges. The Local Plan needs to prioritise jobs and growth in rural areas. There is a need to encourage small business formation and growth. 62 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Major Infrastructure Projects

Summary of issues raised How it has been addressed

Support of the approach. Noted. Reference to the potential for a tidal lagoon has been added Agreement that the Tidal Lagoon is important. to supporting text (paragraph 6.3). Request good evidence based documents are produced to support or reject any infrastructure improvements that may be made.

Hinkley Point C

Summary of issues raised How it has been addressed

Consider investigating the option of a new road from This issue was discussed at the DCO and Dunball to Cannington. rejected.

Need to look at the wider geographical areas that are Agreed, this was part of the wider impacted by the construction of HPC, especially the transport assessments that supported the road systems. DCO.

Concern that the text makes no reference to the pylon These are mentioned under MIP1 and lines going straight across the levels, and the alternative have also now been granted consent. of a cable along the Bristol Channel.

It should be made clear that a DCO has been granted The text in the Local Plan refers to the in connection with the HPC project and any impact DCO being granted and construction arising from the construction/operation have been having commenced. properly assessed and any mitigation appropriately secured.

Managing Flood Risk

Summary of issues raised How it has been addressed

Concern that sufficient attention has not Policy D1 (Flood Risk and Surface Water Management) been paid to the issue of surface water has been strengthened compared to the previous Core and drainage flooding. The two should Strategy with a specific section on addressing surface be addressed separately before water and drainage. This includes outlining where development is permitted. Concern that sustainable drainage systems will be expected and that the large increase in paved area from it must be demonstrated how development will manage the extensive greenfield allocations will surface water to not increase flood risk on site or off site. result in flooding problems.

Particular concerns raised regarding the A sequential risk based approach has been taken in risk from all sources of flooding at considering the proportion of overall growth that should be directed towards the Burnham-on-Sea and Highbridge Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 63

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Burnham-on-Sea and Highbridge and area. Using the Strategic Flood Risk Assessment Level the need to find long term solutions. 2 a sequential approach has also been taken to allocations, ensuring the sites taken forward are at least flood hazard and can be made safe over their lifetime. Proposals in the town will need to comply with Policy D1 (Flood Risk and Surface Water Management) ensuring the development is made safe and doesn't increase flood risk elsewhere.

A concern regarding the extent of flood Large areas of land in Sedgemoor fall within Flood Zone risk in Sedgemoor and the need to 3. The Council has sought to where possible direct a ensure it is taken into account proportion of the District's growth to areas of Flood Zone appropriately in the planning system, 1 (low risk). This is reflected in the spatial strategy with including steering development away an appropriate proportion of growth requirements being from flood risk areas. directed to the District's most sustainable rural settlements, where Flood Zone 1 development opportunities exist. It is not possible to direct all development to areas of low flood risk without compromising wider sustainability objectives. Where development has been located in Food Zone 3 it has been ensured that it can be made safe over its lifetime with reasonable certainty of delivery of required flood defence infrastructure.

Policy should focus on trees and Policy D1 (Flood Risk and Surface Water Management) woodlands in and around our towns with cross-references to the Local Plan's green infrastructure a ‘Managed Flood Risk’ policy, policy section which highlights the important role referencing the role that woods and trees woodland and other green infrastructure can have in can play to resolve a range of water improving the water environment (see paragraphs management and climate change issues 7.248-7.264).

Policy should allow for new tourism The Local Plan is overall supportive of improving the development or the extension of existing quality and diversity of tourism in Sedgemoor. In coastal development at the coast for tourism to locations are careful balance needs to be had between be located adjacent to water, which will supporting investment and improvement in the tourism provide wider sustainable benefits. industry whilst being mindful that these areas are at high flood risk. Policy D18 (Tourism) and the Policies Map establishes a Tourism Boundary for the Brean and Berrow tourism area and is supportive of remodelling where it does not increase vulnerability to flooding.

There is an extensive network of artificial Policy D1 (Flood Risk and Surface Water Management) ryhnes that perform an important has been improved with text specifically saying that drainage function. They must be taken development should be designed to enable suitable into account when considering access and maintenance of watercourses. development proposals and ensure the system is sustainable and maintainable into the future. The policy should be strengthened with regard to this. 64 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

In relation to specific allocations It is not considered to necessary to include more details consideration should be given to on specific instances where Flood Risk Assessments including text detailing where Flood Risk are required as this is already clearly set out in the Assessment's are required. National Planning Policy Framework and Practice Guidance.

Promoting High Quality and Inclusive Design

Summary of issues raised How it has been addressed

Disagreement over wording of national Policy D2 (Promoting High Quality and Inclusive space standards being the ‘minimum’ Design) and Paragraph 7.27 describes how the Council standard for new development ‘unless’ intend to retain a flexible approach to consideration of there is specific justification to reduce space to ensure viability consideration are taken into these. What is the specific justification? account on a site by site basis. The Somerset Strategic Minimum space standards must be met or Housing Market Assessment did not find any strong exceeded to build communities, not evidence for adopting the national space standard. In estates that feel overcrowded. relation to affordable housing (which by there nature are usually fully occupied) registered providers in any case build to housing quality standards.

Evidence needed to support standards; Policy D2 (Promoting High Quality and Inclusive otherwise they are not justified and could Design) and supporting text maintain a flexible add a burden that could harm the delivery approach to achieving appropriate levels of space within of new homes. dwellings, which will include taking into account viability considerations.

Policy should reflect the needs of people Policy D2 (Promoting High Quality and Inclusive in the district and the existing character of Design) required development to demonstrate that it each settlement. There is a need for new responds positively to and reflects local characteristics development to reflect local and the identify of the surrounding area. distinctiveness.

The PPG states justification should be We have undertaken a review of applying national provided for new space standards by; space standards as part of the Somerset Strategic showing an evidence of need, viability and Housing Market Assessment. This did not find any timing. strong evidence for adopting the national space standard.

Building for Life now includes only 12 Supporting text has been changed to refer to Building criteria, not 20. for Life 12 and that the Council will use these guidelines when assessing development proposals against design requirements. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 65

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Sustainable Construction and Reducing Carbon Emissions in New Development

Summary of issues raised How it has been addressed

The policy should adopt Passivhaus In the context of the outcome of the housing standards Building Standards for a future of energy review it is not considered appropriate or consistent with efficient, comfortable homes. Government policy or guidance for Local Plan policies to require Passivhaus Building standards to be met. Policy Policy D3 (Sustainability and Energy in Development) does however provide support for new development to exceed building regulation requirements, including on issues such as energy consumption and performance.

There is concern that the increased cost Policy Policy D3 (Sustainability and Energy in of schemes to make development Development) does not set any specific standards or sustainable will jeopardise the viability of levels that are contrary to or exceed the National sites. Planning Practice Guidance or Building Regulations.

Care needs to be taken with affordable Policy Policy D3 (Sustainability and Energy in housing schemes, to prevent sites not Development) does not set any specific standards or coming forward due to sustainable levels that are contrary to or exceed the National construction costs Planning Practice Guidance or Building Regulations.

Despite changes to national policy the The Local Plan policy on sustainable construction needs Council should still seek high standards to be consistent with the National Planning Policy of sustainable construction, given the Framework and National Planning Practice Guidance. climate change threat. Development Policy D3 has been prepared in this context. It does should incorporate renewable and energy however require applicants to demonstrate how efficient technology to build to the highest proposals have maximised their contribution to sustainability standards. sustainable construction objectives, encouraging the use of higher standards on energy efficiency and energy generation where appropriate and viable.

The requirements for site waste Paragraph 7.47 cross references to the Somerset Waste management plans increases in Core Strategy when referring to Site Waste Management proportion with the scale of the proposed Plans. development so policy should cross-refer to the Somerset Waste Core Strategy.

Renewable or Low Carbon Energy Generation

Summary of issues raised How it has been addressed

In terms of types of renewable and low Policy D4 (Renewable or Low Carbon Energy and Heat carbon projects tidal lagoons most Generation projects) provides support for projects that preferred, onshore wind turbine farms maximise regeneration of energy from renewable and least preferred. low carbon sources. If an appropriate scheme comes forward this would include tidal lagoon projects. The Council has not allocated sites for onshore wind energy 66 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

generation, although the policy provides support for community led projects which may be promoted through Neighbourhood Plans.

All new commercial and residential Policy D5 specifies that this would be expected from developments should incorporate new development unless it is demonstrated that it is renewable technology, eg. Solar panels. not feasible of viable.

Policy should be supported by evidence This comment relates to co-locating heat customers for local energy demand, particularly in and suppliers. DECC have produced heat mapping, as the Bridgwater area. shown in the Renewables topic paper which forms part of the Local Plan evidence base.

Some concern that it is not appropriate to The Council has not allocated sites for onshore wind identify specific sites for wind farms given energy generation, although the policy provides support that new nuclear power station will be for community led projects which may be promoted addressing power shortages anyway. through Neighbourhood Plans.

The policy should also include reference Reference to AONB has been added to policy D4 and to how renewable development may that proposals would only be considered acceptable if impact on the surrounding hills and AONB. there are no alternative sites or where it is in the public or national interest. The Local Plan should be read as a whole therefore the proposals would also be considered against the requirements to Policy D20: Landscape with regard to proposals conserving and enhancing these areas.

The Local Plan should provide protection Reference to impacts on the ‘local economy’ (including for the sensitive tourist economy and tourism and agriculture) has been added to Policy D4 accommodation from the impacts of as a factor to be taken in to account when considering renewable and low carbon energy renewable energy proposals. development.

Local Plan should include a policy Reference to impacts on the ‘local economy’ (including statement that requires planning tourism and agriculture) has been added to Policy D4 applications for renewable energy are as a factor to be taken in to account when considering assessed according to their potential renewable energy proposals. impact on tourist accommodation.

In terms of appropriate areas for The Council has produced a Renewables topic paper renewable or local carbon energy which includes a sieve analysis of the environmental, generation (in some cases including physical, infrastructural and residential constraints of onshore wind turbines) suggestions the District to identify areas that could be considered include along the M5 corridor, between for allocation within Neighbourhood Plans as ‘suitable Express Park and Dunball and Land east areas’ by Neighbourhood Planning Groups. of Brookhayes Farm, Cossington. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 67

Regulation 18 - Main Issues Raised 3

Housing

Summary of issues raised How it has been addressed

Agreement that housing needs will The Council has prepared an updated Strategic Housing need to be fully updated and Market Assessment to inform the new Local Plan. This can reviewed to provide evidence for be viewed in the evidence base section of the Councils housing mix. website. Its recommendations in relation to housing mix have been incorporated into Policy D6: Housing Mix.

In the Burnham area there is a It is acknowledged that bungalows can be popular with older demand for affordable 2 bedroom persons seeking to downsize, often freeing up family sized bungalows to allow older persons housing for younger families. Policy D6 refers to both type to downsize. and size of accommodation and therefore provides the policy framework to seek certain types of housing (such as bungalows) where there is local evidence of need. The policy also seeks an appropriate proportion of new homes to meet accessible and adaptable dwelling standards to allow people to stay in their homes for longer.

Disagreement that starter homes Policy D6 specifies that starter homes should be provided in should be provided separately on accordance with Regulations and Guidance. While changes only brownfield sites. They should are yet to be formally introduced, based on Government always be incorporated within consultations it was expected that a proportion of starter developments. homes will be required on all sites of 10 or more units, not just brownfield sites. This approach has now changed following following the Governments Housing White Paper where the focus is now on affordable home ownership products more generally.

General agreement for the plan to The Local Plan includes a policy specifically on promoting support self-build opportunities. self-build (Policy D10) and enabling sufficient plots to be delivered to meet the need identified on the Council self build and custom build register.

Concern over self-build projects that For small scale self-build schemes in rural areas Policy D10 are adjoining development sets out criteria for when self build schemes will be supported. boundaries- should be exception This includes ensuring that sites are only considered where only. it is to meet the need identified on the self build and custom build register and future occupants demonstrate an appropriate local connection.

A proportion of plots should be Policy D10 (self-build) requires allocated housing sites to have reserved for self-build if there is a regard to the self-build and custom build register and where registered demand, given that plots there is demand include an appropriate amount of dwellings can be integrated within plots for sale to self or custom builders. developments.

Policy must meet the needs of the Policy D6 (Housing Mix) requirements and its supporting text ageing population; providing has been based on the the findings of the Strategic Housing smaller, adaptable homes to allow Market Assessment and what sizes of properties are expected elderly to downsize and free up to be needed based for on demographic changes in the District 68 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

homes in the district. A proportion up to 2032. It also includes provision for a proportion of of housing on new developments accessible and adaptable homes to be delivered to meet the should be built to the Lifetime needs to an ageing population. It would not be appropriate Homes standard. for the Local Plan to specify lifetime homes standards, national planning practice guidance is clear that only enhanced building regulations should be applied where justified by local evidence.

Strong agreement for the plan to A new policy focused specifically on residential annexes has include detail on residential annexes been included in the Local Plan (policy D13). due to the reduction of funding and care homes.

Support for residential annexes if Policy D13 (residential annexes) expects that annex attached to existing premises. accommodation is delivered either through adaptation or extension of the main house. However this will not be appropriate or desirable in all instances therefore the policy allows for free standing annexes where it can be clearly justified.

Concern that not enough jobs are The work undertaken in the Strategic Housing Market being predicted to employ the Assessment that has informed the Local Plan included additional home owners. analysis to establish if there was an imbalance between where population growth is projected to occur and where the jobs might be provided. This concluded that across the District there can be expected to be a good balance between jobs and the population to take up employment opportunities.

Affordable Housing

Summary of issues raised How it has been addressed

Affordable housing should be In relation to meeting local rural affordable housing need both safeguarded for people that have Policy T5 (Tier 3 settlements) and Policy T10 (Tier 4 lived locally for most of their lives. settlements) refer to a local lettings policy to ensure homes are allocated to those with a local connection.

A review of what is affordable Affordable Housing is defined in the National Planning Policy housing. Framework and it would not be appropriate for the Local Plan to present alternative definitions or criteria. Policies in the plan are however flexible enough to respond to any changes that may be introduced in the future.

Flexibility needed to allow In delivering affordable housing Polices T5 and T10 allow for clustering of a mix of homes, e.g. an element of market housing to also be delivered on sites affordable and open market realised to meet local affordable housing need. Policy D7 housing. (affordable housing) specifies that affordable housing should be well integrated with any market housing. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 69

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Policy needs to be flexible in terms Policy D6 (Housing Mix) and D7 (Affordable Housing) do refer of house sizes and tenures sought to the sizes and tenures that will be sought based on the to take into account local findings of the Strategic Housing Market Assessment. However considerations and site the Local Plan is clear that these are a starting point of characteristics. discussions and the mix of sizes and tenures will be considered on a sites by site basis taking into account local needs.

The percentage of affordable The thresholds and percentages of affordable housing sought housing should vary on a site by are specified in the Local Plan however Policy D7 is clear that site basis to reflect local needs. these will be negotiated on a site by site basis taking into account viability considerations. For Tier 3 and 4 settlements the policy approach is to only release sites for development where they are meeting an identified local need for affordable housing (Polices T5 and T10).

Needs to be integrated within Policy D7 (Affordable Housing) includes policy wording development so that affordable regarding the affordable housing element being well integrated plots are not undesirable or with any market housing. isolated.

Concern over flexibility of approach Policy D7 (Affordable Housing) includes wording to take to affordable housing in villages to account of viability considerations when negotiating the reflect viability and priority proportion of affordable housing. In relation to Tier 3 and 4 considerations. settlements policies T5 and T10 allow for elements of market housing to help address viability considerations and ensure sites needed to meet local affordable housing need can be delivered.

General support for maximising the Agree. The affordable housing need identified in the Strategic delivery of affordable homes, Housing Market Assessment means that the Council is justified particularly in the Districts urban in seeking to maximise affordable housing provision in new areas. development. The Local Plan also ensures a flexible approach with specific affordable housing requirements considered on a site by site basis to take into account viability considerations.

Rural Local Needs

Summary of issues raised How it has been addressed

Disagreement in removing the A general Rural Exception Sites policy has not been included in policy as Rural Exception Sites the Local Plan under the district wide policy section. This is (RES) are key providers of because it is considered this would duplicate Place-making policies. affordable housing Polices T5 and T10 now provide for the release of sites outside of settlements boundaries to meet identified local needs affordable housing needs across the 17 Tier 3 and 10 Tier 4 rural settlements identified in the settlement hierarchy. 70 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Summary of issues raised How it has been addressed

Should be amended to This has been done by addressing rural local need as part of the reference settlement hierarchy. the Place-making policy (Polices T5 and T10) which apply different approach towards the exceptional release of affordable housing sites for different levels of the hierarchy for rural Sedgemoor.

Retain policy and amend to Agree. Policy policies T5 and T10 allow for a proportion of market reflect guidance of NPPF which housing on sites to enable cross subsidy and improve the likelihood considers the necessity to of viable schemes being able to be delivered. This is considered include market housing on to be an appropriate approach given the current climate where Rural Exception Sites in order grant funding has an uncertain future. to make schemes viable.

Retain policy and incorporate It is considered Policy D7 (Affordable Housing) and policies T5 latest Government policy and and T10 which address rural affordable housing need are guidance on affordable consistent with national policy and guidance. This includes the housing. thresholds at which affordable housing will be sought and allowing for including for a degree of cross-subsidy in rural areas to make schemes viable.

Affordable housing should be The policies in the Local Plan seek to deliver affordable housing available in all settlements. across a wide range of settlements, either through site allocations or through criteria based policies to allow for sites to be release of sites where there is identified local need. The exception to this is the very small Tier 5 settlements which have few or no services and are not considered to be sustainable locations for development. While the policy approach to Tier 5 settlements (T11) does allow for very limited infill development in exceptional circumstances in general it would be expected that any local housing identified is accommodated at more sustainable settlements in their vicinity. This plan led approach is considered to be consistent with the NPPF core principles of taking into account the role and character of settlements and actively managing patterns of development.

Gypsies, Travellers and Travelling Show People

Summary of issues raised How it has been addressed

Pitches promoted within Flood Zone 3a are Policy D9 is consistent with national policy in ensuring unsuitable and should be a last resort. that pitches are not located in inappropriate locations Many areas located in Flood Zone 3a so at flood risk, instead being steered to low risk areas. single story permanent accommodation is inappropriate.

New sites should be distributed to avoid a It is considered that sites should generally be located disproportionate load on nearby local within a reasonable distance on local services, services, e.g. Education. including education. However Policy S3 (Infrastructure Delivery) may be relevant to larger sites to ensure services, facilities and infrastructure are improved to Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 71

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

meet needs and requirements arising from development.

Many fields on Northmoor suitable for one Northmoor is located in Flood Zone 3 and would caravan or mobile trailer in each. therefore not be suitable for pitches based on Policy D9 and national planning policy.

Concern that the number of pitches in the The Gypsy and Traveller Accommodation Assessment Gypsy and Traveller Accommodation was undertaken jointly with other Somerset authorities Assessment currently approved or in use and is considered to provide the best local evidence is significantly underestimated. of need for pitches.

Concern that sites will be remote from Policy D9 includes criteria that sites be within a communities. reasonable distance to local facilities and services.

The suggested approach of relaxing the This was previously put forward as a potential policy to allow some sites in flood risk areas approach during the Stage 1 consultation, given the is contrary to national government policy extensive areas of the District that fall within flood zone and consequently there would be an in 3. It is however acknowledged that this is not principle objection to pitches in FZ3a. consistent with current national planning policy and has not been taken forward in the policy wording in the Local Plan.

Sustainable Transport and Movement

Summary of issues raised How it has been addressed

Agreement with approach and support to General approach to transport has been retained in the strengthen policy. new Local Plan under policies D14 and D15 along with strengthening on issues parking standards and safeguarded routes.

Support for additional cross reference to Reference to the adopted travel planning SPD has been adopted travel plan SPD. included in the delivery section of policy D15 (paragraph 7.131).

The needs of pedestrians, cyclists and Both transport policies in the Local Plan (D14 and D15) public transport should be designed first, seek development to enhance facilities for pedestrians to ensure sustainable modes are not and cyclist and provide accessible public transport considered as an afterthought. options. In addition to this policy D2 (Promoting High Quality and Inclusive Design) includes a requirement for development to demonstrate such objectives are being met through the masterplanning of sites.

Concerns about the cumulative impacts Policy D15 (managing the transport impacts of of housing developments at Cheddar, development) includes requirements for development Wedmore and Axbridge as well as the to be supported by appropriate evidence regarding expansion of Bristol Airport increasing impacts of the surrounding road network and that traffic 72 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

the volume of traffic on the A38 and local generated does to compromise the function of the local roads. and strategic road network.

Transport Assessment Report needs to It would be expected that where transport assessments be kept up-to-date and monitored. are required through Policy D15 to support planning applications that they use up-to-date best practice in undertaking the assessment. At the planning application stage the Council would seek advice from relevant consultee's on the adequacy of transport assessment work undertaken.

Concern that the changing issue of traffic Transport is a key priority of the Council and understands congestion in the District should be a its importance in making Sedgemoor an attractive place priority for SDC to prevent visitors and to live, visit and do business. Policy D14 refers to the tourism to be deterred from the area. Sedgemoor Transport Strategy which the Council are undertaking to refresh and update key transport priorities and improvements going forward.

Local Plan should include a commitment Policy BH8 (Transport) sets out the transport priorities to address the issue of traffic congestion, of Burnham-on-Sea and Highbridge, including particularly in relation to Burnham-on-Sea addressing congestion and cycling improvements. as there is a high number of cyclists and people using wheelchairs.

Consideration should be given to Policy D15 includes requirements for an appropriate transparent pricing of parking within new travel plan in new development, including measures to developments to influence choice and encourage more sustainable modes of travel. incentivise more sustainable choices.

Economic Prosperity

Summary of issues raised How it has been addressed

General support for this approach. The new Local Plan retains the positive approach to planning for new employment development in the District.

Local labour agreements, both in Policy D16 (Economic Prosperity) includes requirements construction and in end-use employment, with regarding to local labour agreements. should be part of the planning conditions on large scale developments.

How will areas with no suitable transport Policy D16 supports small scale employment infrastructure be encouraged? E.g. development well located to sustainable settlements in Cheddar. the District, provided they are appropriate to the scale and character of the community. In relation to Cheddar employment land has been promoted to the Council and an allocation is included in the Local Plan (Policy C4). Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 73

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

Employment and business opportunities Overall it is considered the Local Plan takes a consistent must be created alongside housing approach to both employment and housing across developments to create sustainable different settlements, steering larger scale housing and communities. employment allocations to the main urban area, while also allowing local housing need sites and small scale employment in the more rural areas.

Tourism must be included within this Tourism is addressed under its own dedicated policy policy. under Policy D18. Compared to the current Core Strategy this includes a more detailed policy framework for tourism development in the District.

Policy should provide flexibility for Policy D17 provides a mechanism by which for existing vacated employment sites to be released vacant employment sites to be considered for alternative to contribute towards other development uses where certain criteria are met and there is no needs, specifically housing. likelihood of a viable employment use continuing on the site.

Text should be amended to allow for Policy D16 support appropriate small scale employment greenfield sites in exceptional use within or well related to settlement boundaries. This circumstances and where demand will therefore in some cases allow greenfield sites to dictates to ensure a robust and flexible come forward for employment. supply of employment floor space can be achieved.

Policy should be amended to address Policy D19 provides a flexible approach to town centre occupancy rates in retail areas. uses and seeks to maintain and enhance their viability and vitality.

Educational training and development The Skills/Labour section of Policy D16 indicates that needs to be included starting with local labour should include a training and recruitment schools and colleges, as well as plan. In addition Policy D30 (education) takes a positive university level. approach in meeting addressing the education needs of the district through the provision of new education facilities.

Tourism

Summary of issues raised How it has been addressed

Strong support towards suggested The suggested approach has been taken and Policy approach. D18 includes additional locational criteria for tourism development.

Encouragement of ‘green’ tourism. Policy D18 sets out a specific objective to promote sustainable tourism taking into account the impacts and effects of climate change. 74 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Summary of issues raised How it has been addressed

Investment in Cheddar is needed. There Policy C7 (Cheddar Gorge) includes support for needs to be more support for tourism in proposals that enhance the existing area, including Cheddar given the number of local improvements in pedestrian facilities, traffic businesses they rely on it. management and public realm. Policy D18 also provides general support for new tourism facilities where they are appropriate to the size and role of the settlement.

Encouragement is needed for owners of Policy D18 and C7 are generally supportive of buildings within the Cheddar Gorge area to appropriate tourism development and therefore bring derelict properties back into use. provide an appropriate framework that would allow underused or derelict tourism facilities to be through back into use.

A review is needed on caravan park Caravan licensing is addressed through separate licensing and the occupancy of holiday legislation to planning and it is therefore not homes to define a clear licensing policy. considered necessary or appropriate to include reference to it in the Local Plan. While D18 does includes policies to guide tourism accommodation (including caravan and camping).

Improvements to and greater promotion of The Bridgwater and Taunton Canal is identified as the Bridgwater and Taunton Canal to attract an tourist attraction in the District under paragraph visitors to the area. 7.142 of the supporting text to the tourism policy (D18).

Policy should explore opportunities to These aspirations are included as objectives in Policy increase sustainable modes of travel to the D18 (Tourism). District’s tourist assets including cycling and walking.

Disagreement to introduce policy restraint It is considered appropriate to use conditions on the occupation of tourism restricting occupation to ensure that tourist accommodation that could reduce inward accommodation is being used for its lawful use. To investment and harm growth. provide flexibility to different circumstances policy D18 does however set out criteria for when the removal of conditions that restrict occupation will be considered.

Development should avoid countryside and The spatial strategy seeks to maximise development greenfield and stay within town boundaries. within settlements. However to plan positively it has As tourists visit Somerset for the wildlife and been necessary to identify greenfield opportunities to coast. meet the District development needs. District wide policies in the natural environment section of the plan seek to protect and enhance key assets that attract tourists to the area.

Policy should be amended to ensure it does It is considered that Policy D18 (tourism) provides not preclude tourist accommodation enough flexibility in this regard. Policy wording acknowledges that some tourism accommodation in Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 75

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

development that is reliant on initial access the countryside may be appropriate where it is in by car. conjunction with a particular countryside attraction.

Tourism policies must be flexible to allow D18 (Tourism) is considered to be appropriately businesses to adapt to changing economic flexible to enable businesses to adapt to changing trends and changes in the demands of demands, including the need to remodel sites. tourists, and the diversification of sites. Flexibility is key to ensure sites remain economically viable and can continue to support the local economy, e.g. The Caravan Club.

Do not allow people to build sheds / log A specific section on the retention of holiday cabins for holiday accommodation which accommodation has been included in Policy D18 are then converted in to full time residential (tourism) to seek to address this issue. developments.

Support for reintroducing a tourism boundary A tourism boundary has been included in the Local to Brean, to support and provide clarity on Plan to support the remodelling of sites and provide appropriate tourism development in the area clearer guidance regarding undertaking sequential and support local businesses. This has tests with regard to the flood risk constraints in this previously been included in Local Plan and area. it is argued its re-introduction is considered justified.

Retail Hierarchy

Summary of issues raised How it has been addressed

Policy needs to be proactive with The retail policy (D19) seeks to strike the right consideration needed towards town centres balance between allowing flexibility regarding uses and how they will adapt to changing shopping in certain areas/frontages, whist still having an habits; rise of internet shopping. Policy is too approach that preserves and enhancing the vitality restrictive and can lead to dead retail of town centres. frontages, not reflecting the changing retail culture.

Highbridge has no cultural benefits, no Policy BH10 and the Policies Map identifies restaurants and no evening entertainment for Highbridge as a District Centre where proposals to residents in its town centre. improve the public realm and provide enhanced facilities are encouraged.

Greater control is needed in the Countryside Policy D20 seeks to protects and enhance the to ensure design and location is not districts landscape, particularly AONB. Policy T14 detrimental to the landscape, particularly provides more policy guidance on the sorts of retail views from the AONB. proposals that will be supported in countryside locations. 76 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Summary of issues raised How it has been addressed

Policy is considered to have a gap relating to Policy D38 (Local Services) which includes retail provision in villages, particularly Tier 2 commercial facilities such as shops applies to these villages. settlement tiers and is considered to provide the appropriate policy framework to encourage and retain facilities as appropriate.

Natural Environment

Summary of issues raised How it has been addressed

Majority support the suggested approach. Noted. Policies relating to the protection and enhancement of the natural environment remain an important part of the Local Plan.

There are a number of internationally, A HRA of the Local Plan has been undertaken and european and nationally protected sites in or has concluded that there are unlikely to be any in close proximity to the district (North significant adverse effects on designated habitats Somerset and Mendip bat SAC, Severn or species. estuary, Somerset level and moors SPA/Ramsar). European sites will be a key consideration in the HRA for the plan.

Two areas of AONB could be affected by AONB’s are important landscape designations, they proposals (Mendip Hills and Quantock Hills were one of the focus of discussions when AONB). These should be taken into account assessing options against the landscape objective in the preparation of the plan and district wide of the sustainability Appraisal. Local Plan policy policies. D20 states that development in AONB will only be supported where it enhances and conserves the exceptional beauty and character of these areas.

Evolving policy does not provide the absolute Additional policy (D23) has been included within protection for ancient woodland, which is the Local Plan to specifically prevent damage to below UK average in Sedgemoor. ancient woodland and veteran trees.

NPPF does not currently provide sufficient Additional policy (D23) has been included within protection for ancient woodland, so Local the Local Plan to specifically prevent damage to Plans must provide this protection. ancient woodland and veteran trees.

No new developments on AONB. The Local Plan contains a policy (D20) which states that development in AONB will only be supported where it enhances and conserves the exceptional beauty and character of these areas.

In relation to AONB policy needs to be clear The Local Plan contains a policy (D20) which states on how protection, enhancement and that development in AONB will only be supported restoration will be implemented. where it enhances and conserves the exceptional beauty and character of these areas. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 77

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Summary of issues raised How it has been addressed

Bridgwater and Taunton canal should be The Ecological Network mapping has been included on any new map base as an prepared by SERC and SCC. The canal is identified important ecological corridor in its own right, as a component of Sedgemoor’s green as well as providing linkages between other infrastructure network. Context for policies D32 and sites of ecological importance. D33 recognises that maintaining a GI network contributes to ecological and recreational needs.

Document should contain details of Somerset Reference has been included within policy (D21) County Council’s biodiversity offsetting text as advised by SCC Ecologist methodology or specific proposals of how it would be applied in Sedgemoor.

Habitat that is red listed or where critically Policy D21 requires an Ecological Impact endangered species reside should not be Assessment to be carried out for proposals that developed to protect biodiversity. might impact on species or habitats of nature conservation significance.

Proposals with the potential to cause damage Wording to that effect has been included within the to mapped components of Somerset’s Ecological Networks policy (D22). Ecological Network should be resisted and must demonstrate how this impact will be minimised.

Integrity of the AONB need to be protected by The Local Plan contains a policy (D20) which states the NPPF. In this context development in the that development in AONB will only be supported Cheddar and Axbridge areas outside of where it enhances and conserves the exceptional existing boundaries must not be encouraged beauty and character of these areas. Impacts on or permitted. the integrity of the AONB must be assessed on a case by case basis.

Bat Consultation Zones

Summary of issues raised How it has been addressed

Strong agreement with this Bat Consultation Zones have been retained in the new Local approach. Plan under policy D24.

Support to use the most up-to-date Supporting text refers to the fact that the extent of zones may survey data. vary as new data and information comes to light.

The conditions attached to Policy D24 acts as a trigger to ensure that the appropriate development need to be site specific. information is provided by the applicant and the relevant consultee bodies consulted. What conditions are applied will depend on the outcome of this process and will vary on a site by site basis.

Objection that ‘tests of significance’ A policy that prevented any development within bat are not good enough; no consultation zone areas would be overly restrictive and would development should be allowed not be considered to comply with national policy. It is 78 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

where bats live and forage as all considered the approach set out in D24 ensures that development will disturb them. appropriate safeguards are in place to protect bats and their habitat. This includes where necessary undertaking Habitats Regulations Assessment which by its nature is a precautionary process.

Pollution Impacts of Development and Protecting Residential Amenity

Summary of issues raised How it has been addressed

The cumulative impact on air quality Cumulative impacts with regard to air quality are identified needs to be considered. as a consideration in the Sustainability Appraisal of the plan and this has been taken into account in the sustainability appraisal of different options.

Schools in close proximity to sources Policy D25 (Pollution) includes a section of development of pollution need careful scrutiny. in the vicinity of sources of pollution to ensure risk and impacts are appropriately addressed.

Monitoring and attention needs to be In terms of what is in the remit of the Local Plan the overall paid to vehicle exhaust pollution levels, spatial strategy has been is to locate the majority of particularly where children and development in the sustainable locations where facilities walking/playing. and services can be accessed using sustainable modes of transport (e.g. walking and cycling), therefore seeking to reduce car use and the associated pollution issues that arise.

Consideration of any potential impacts Policy D25 ensures that where pollution concerns arise of groundwater outside of source (which could include water pollution arising from protection zones will be required, in the non-mains drainage) them planning applications are event applicants are unable to connect supported by the necessary assessments to ensure any to the main foul sewerage network. impacts are adequately addressed.

Historic Environment

Summary of issues raised How it has been addressed

Concerns of lack of evidence to inform The Historic Environment Assessment was undertaken the plan and ensure that it protects and by SW Heritage Trust on our behalf and is included within enhances the historic environment. A the Evidence Base for the Local Plan. This has informed thorough assessment needs to be allocations and policy wording for the proposed undertaken of the strategy. submission Local Plan.

Responses in general agreement of the Saved Policies on archaeology from previous Local Plan approach of including saved local plan / Core Strategy have been included within Policies D27, polices on archaeology to strengthen the D28 and D29. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 79

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

policy framework for the historic environment.

Where is the conservation area A rolling programme of updating Conservation Area management plan for Axbridge. Appraisals and Management Plans for settlements throughout the District is underway.

Policy wording should be strengthened This should not be addressed by the Local Plan as the to differentiate between different types grade of listed building (for example) is a material of sites and provides the level of consideration. Locally listed buildings are not designated protection appropriate to each. heritage assets and are therefore assessed differently, however, if these are to be designated within the Neighbourhood Plans then additional policies for locally listed buildings would not be required. This would be seen as doubling up and not required. Policies and supporting text are in accordance with the requirements of NPPF and all regulatory designations are referred to.

Education Provision

Summary of issues raised How it has been addressed

A range of schools are already at full The Council has worked closely with County education to capacity and it is uncertain whether understand the capacity issues around education. Where they can be physically extended until necessary a positive approach has been taken including feasibility studies are undertaken. allocating new sites for educational purposes. In addition These are principally schools that are policy D30 (education) provides a positive approach to in the districts larger settlements. ensuring additional, extended or enhanced educational Across rural settlements some schools facilities are supported. do have additional capacity.

Policy should consider setting an Separate to the Local Plan authorities already have a duties indicative limit on car travel to school with regarding transport arrangements for eligible children on a site by site basis, incorporated in and promoting sustainable travel and transport. It is not the school travel plan. considered appropriate to include criteria as part of the Local Plan. Policy D30 does however support proposals for education facilities that are accessible by a range of sustainable transport modes.

Schools should be as small as The scale of facilities required will vary depending on educationally and financially viable to educational needs identified. Policy D30 supports proposals enable access by walking and cycling. for education facilities that are accessible by a range of sustainable transport modes.

Concern that schools in Cheddar are Education provision with particular reference to Cheddar already virtually full. is discussed in Policy C10 and supporting text. Given the proposed new homes in the village it is anticipated that the 80 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

First School will require some remodelling and extension within its current site over the plan period.

Policy should plan for the development Supporting text for policy D30 acknowledges the proposals of a university in Somerset. regarding a university in Somerset. It is considered that the policy provides a suitable framework to allow these aspirations to be realised.

Education facilities should be planned The plan has taken a positive approach to understand the alongside developments and not as education capacity issues in the District and includes an afterthought. allocations for education alongside proposed housing allocations. Policy S3 (Infrastructure Delivery) is considered to provide the appropriate mechanisms to ensure new school (and other infrastructure) are delivered in a timely manner to meet the increased demand arising from new development.

Concerns that only large strategic While larger sites will be expected to meet any identified housing sites will be expected to meet shortfall smaller sites and individual sites will provide for identified shortfall needs. this by payment of CIL.

Health and Social Care

Summary of issues raised How it has been addressed

Concern there appears to be no policy Policy D31 includes a section on health care covering the provision of health facilities such facilities and that new development that creates a as doctors and dentists. need for additional health facilities will be expected to meet any shortfall.

Open space provision is especially important, Comprehensive policies have been included on as is access to the countryside. these topics (policies D32 to D37).

Concern there is no provision of sports Land at BASC is protected as recreational open facilities within the new plans for Burnham space with potential for further expansion and and Highbridge. investment. New development will also be required to make appropriate provision or contributions. Detailed neighbourhood planning work may also identify new opportunities.

Wording of ‘promotion’ of walking and cycling Wording has been amended as advised. should be changed to ‘enabling’.

Policy should include the role of green The important role of green infrastructure in infrastructure, particularly trees and woods contributing to improved health and wellbeing is and the impact they have by contributing to addressed through specific Green Infrastructure improved health and wellbeing. Buffer zones policies (D32, D33) and their supporting text. and green space are necessary to promote physical and mental health. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 81

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

The Local Plan should contain a separate A separate policy on this topic has been included ‘Trees and Woodland’ policy. (Policy D23).

The promotion of walking and cycling needs The promotion of sustainable modes of transport is to be considerably strengthened, including a key issues that has informed the spatial strategy encouragement for projects that help deal with and is referred to across many of the district wide adult obesity. policies. Policy D31 specifically support proposals that enable walking and cycling.

The Canal and River Trust promote the canal The canal has been identified as informal and towpath as a freely available local open recreational outdoor space on the policies map, air gym. linked to Policy D36 (Protection of Existing Public Recreational Outdoor Space).

Agreement that health impact assessment Policy D31 specifies that Health Impact Assessment requirements need to be more specific as may be required to support major planning currently has been widely ignored. applications.

Green Infrastructure, Open Space, Sports and Recreation

Summary of issues raised How it has been addressed

Proposals for children’s play areas should Noted and agreed. Policy D37 sets out the be part of development proposals, e.g. that requirements. of South Lakeland.

ANGSt standards must be applied to new Noted and agreed. Policy D33 sets out the developments. requirements.

Consideration could be given to creating Noted although the priority is on improving routes inter-town cycleways if the opportunity within settlements that offer the greatest benefits. arises; Bridgwater-Taunton and However longer routes will be considered where Bridgwater-Burnham/Highbridge. opportunities arise, for example as part of the HPC mitigation package.

Support of approach assuming it continues Local Plan policy D32 retains wording to this effect. to give priority to “the protection and planting of trees for public amenity and climate change mitigation”.

Concern that horse riders and bridleways Whilst the Local Plan cannot specifically address this are not mentioned, and although it is a there is a reference to horse riding within the County Council responsibility, Sedgemoor introductory text of Local Plan Policies D32 and D33. should plan for use by all on new or existing paths.

Fields and hills around Cheddar must be The Mendip Hills are protected through AONB status. protected. There is no justification for the blanket protection of fields around Cheddar through the Local Plan. 82 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Ensure Brue Farm deals with outdoor Noted. There is an existing planning consent for the space, recreational area and opportunities first phase and policies in the local plan will address for all ages to exercise. these issues for the proposed phase 2 allocation.

Lack of open green space in Burnham. The Local Plan cannot address existing deficiency but can (and does) resist the loss of recreational spaces. The Plan is supported by an evidence report which has identified areas of the District that do not meet Natural England’s Accessible Natural Greenspace Standard. This information can be used by Parish Councils and Neighbourhood Planning Groups if they choose to address existing deficiencies.

Adequate green space and recreational Noted. This is matter addressed through the Council's facilities should be provided using the R.123 list that sets out the priorities for spending CIL. money set aside through CIL developments. It is informed by the current IDS.

Support of the Brean sluice project to create Noted. Various policies in the plan that promote a cycle way to Weston-Super-Mare and cycling help to support this project. greater emphasis is needed on other projects.

Consideration towards both Cokerhurst and The Western Extension includes substantial areas of Queenswood Farm is needed to designate open space/green space, appendix 1 illustrates these local green space. principles. Local Green Space designations need to meet specific requirements. Evidence has not been provided to demonstrate that the Cokerhurst site meets these requirements. Local Green Space designation should not be used in a way that undermines this aim of plan making.

Manor Gardens, Burnham should be Manor Gardens is identified as Informal Outdoor designated as local green space. Space on the Local Plan policies map and is therefore afforded protection by Local plan policy D36.

Suggestion for the Wembdon playing fields This area is identified as Informal and Formal Outdoor between Church Road and Homberg Way Space on the Local Plan policies map and is therefore and the adjoining public open space afforded protection by Local plan policy D36. between Oak Apple Drive and Homberg Way as local green space.

Suggestion for the land either side of the This area was assessed within the Local Green Space A370 in East Brent, previously designated desktop assessment (part of the Local Plan evidence as green wedge should be considered as base). Whilst there was insufficient evidence provided local green space. to confirm that the site was of particular importance to the local community the area will continue to be afforded protection by Local Plan policy D34.

Option E for Burnham; land between the This area was assessed within the Local Green Space existing settlement boundary and the new desktop assessment (part of the Local Plan evidence base). There was insufficient evidence provided to Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 83

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

development should be kept as green confirm that the site was of particular importance to space. the local community.

Wembdon parkland should be added to This area is identified as Informal and Formal Outdoor Local Green Space. Space on the Local Plan policies map and is therefore afforded protection by Local plan policy D36.

Plan should be based on objectively The Local Plan is supported by a Sports and assessed need which informs a strategy for Recreation Facilities Strategy and Delivery Plan sports and recreation. Positive policies that undertaken in 2013. Local Plan policy D36 seeks to protect, enhance and provide necessary protect recreational outdoor space. Local Plan policy sports facilities should reflect this evidence D38 seeks to protect indoor sports facilities. base.

Previous Local Plan Policy BE7 "Open These areas have been carried forward as policy D35 Areas Protected from Development" is of the new Local Plan. important and offer vital protection to areas of interest. It should not be omitted.

Community and Cultural Facilities

Summary of issues raised How it has been addressed

Support of the approach to provide a single Policy D38 (Local Services) seeks to plan positively policy as this reflects the guidance in for the provision of facilities, consistent with the paragraphs 70 and 156 of the NPPF. NPPF. This includes policies to guard against the unnecessary loss of valued facilities and services.

Recommendation for policy to resist the loss Policy D38 addresses this concern and resists the or change of use of existing community and loss the existing services unless certain criteria cultural facilities unless replacement facilities are met. are provided on site.

A description of the term ‘community and The policy has been renamed to local services cultural facilities’ should be provided in the which is considered a clearer. What local services glossary and accompanying text on examples. are considered to be is explained in the supporting text to Policy D38. 84 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Local Plan Review - Additional Consultation

East Bridgwater - Revised Option

Summary of issues raised How it has been addressed

Follett’s Farm is considered to be an Noted and agreed, the Local Plan includes this area appropriate and sustainable location for future as a strategic housing allocation. residential growth in Bridgwater, due to the proximity to amenities and services including a primary school, bus services and employment.

Where’s the evidence 1500 new homes are The SHMA sets out the overall housing needs and required in this area? the spatial strategy sets out the requirements for Bridgwater growth. The site is well related to existing facilities, has least direct traffic impacts and is deliverable.

Concern that the consultation is focused The Local Plan includes additional employment singularly on residential development, whilst allocations and the eastern extension is well located little thought has been given to encouraging in terms of NE Bridgwater and Bristol Road business and commercial development. employment areas.

Proposed development will have a huge Development will impact upon this area although it impact on the rural environment on the should be noted that it is close to the M5 motorway outskirts of town by; increased light and noise and associated noise and disturbance. Development pollution, increased traffic congestion and will provide acoustic screening as well as detriment to road safety. improvements to the local road network, specifically Bower Lane.

Parking provision needs consideration as Noted and agreed. The adopted County car parking most households have 2+ cars and rely on standards will form the basis of provision. parking their cars on the roads.

The alternative access to Dunwear Lane via Agreed, this is not proposed as an access to River Lane is not suitable as it is a narrow development. Detailed access arrangements will single track lane that opens via a slope onto need to be assessed through a transport impact a national speed limit carriageway on an assessment. S-bend.

No new development until Bower Lane and The phased delivery of housing and necessary Dunwear Lane are fully upgraded to dual infrastructure, including the improvements to Bower traffic highways with lighting and pavements Lane will be based upon a detailed Trasnport both sides. Impacts Assessment and set out within the design and development principles document required under Policy B4.

A new road from beyond the Hospital site Development of the eastern extension will deliver which runs alongside the M5 would allow improvements, both on-line and off-line to Bower access to new housing and it could be built Lane. There is no requirement or advantage in an to take width and weight along with the additional access road. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 85

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed increased traffic experiences along Bower Lane.

Services including a secondary school, Necessary infrastructure will be delivered as part of doctor’s surgeries and dentists must be comprehensive development. However, the site is provided. well related to existing facilities. There is no requirement for a new secondary school but a new primary school is needed.

Concern that the proposed allocations are The Bridgwater barrier will provided long term flood within Flood Zone 3 and an increase of up to protection for Bridgwater, including this area, and 1500 dwellings will increase the risk of is due to be delivered by 2024. Appropriate surface drainage issues to existing dwellings. water drainage strategy including provision of SUDs will form part of the detailed design of the scheme.

Building homes closer to the M5 will present An appropriate noise mitigation strategy that could unacceptable noise and air pollution to include bunds and/or acoustic fencing will be families. required. Experience at NE Bridgwater demonstrates that proximity to the motorway is not a constraint to successful development.

Concern that the habitats of many types of Detailed ecological surveys and appropriate birds, animals and protected species of bats mitigation will be required. The site is not within a will be destroyed. bat consultation zone.

It is unclear on whether a link to Colley Lane This has been considered in further detail and it is is considered necessary to facilitate the not necessary. Bridgwater East option.

Must consider facilities for children and Agreed and development will provide appropriate teenagers as there is currently not enough to open space and recreation opportunities. occupy existing residents.

Like the current developments being built in Details of the appropriate street lighting strategy will Durleigh and Chilton Trinity, there should be be developed through the design process. However, no street lighting. this area is already dominated by existing development and the M5 as well as new development such as the hospital. It is not necessarily an obvious candidate for reduced street lighting.

Residents currently experience significant Noted. The Local Plan sets out a range of transport difficulty gaining access to the motorway. improvements and J.23 is due to be signalised, improving access and reducing congestion.

Concern regarding insurance and mortgage Whilst not directly a planning matter, the success prices/options for existing and new of NE Bridgwater and other areas of Bridgwater developments as many companies refuse demonstrate that this issue does not appear to be properties in Flood Zone 3. a significant barrier to successful house sales. 86 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Summary of issues raised How it has been addressed

Disagreement to such large development The area is not good quality agricultural land and proposals as prime agricultural land will be generally used for grazing. lost.

Wildlife and green areas are important; a park Noted and agreed. The illustrative plan in Appendix or playground needs to be developed with 1 indicates a central green area close to the Bower safe cycle routes to provide easy access for Inn. There is also a requirement to provide walking families. and cycling links.

Tier 1 Settlements

Summary of issues raised How it has been addressed

Some support for creating place-making policies Noted. The Local Plan includes detailed policies for each individual Tier 1 settlement. for Cheddar.

Concern that categorising Cheddar as Tier 1 Policies seek to promote enhancement of Cheddar settlement will negatively impact on Gorge and deliver infrastructure improvements environmental status of the area and damage including junction improvements. tourism trade.

Concern that a lack of brownfield sites available There are limited brownfield opportunities. for development will lead to the loss of valuable However, allocated greenfield sites include agricultural land and extensive environmental extensive open space and appropriate ecological damage. mitigation.

Objection to development on greenfield land as It is not possible to deliver the housing needs of it will remove habitat and hedgerows for the district without identifying greenfield sites. The struggling wildlife. sites identified have been fully assessed and represent the most sustainable options. Significant impacts upon ecology and landscape will require mitigation.

Concern that the tier rating method is too The role and function evidence does consider local simplistic, as scoring settlements on local employment opportunities and transport whilst the facilities without consideration for local sustainability assessment considers a range of employment opportunities, transport and social, economic and environmental impacts. environmental impact is not a true representation.

Object to Cheddar as a Tier 1 settlement as it Cheddar is identified as a rural village in the Local remains a village, not suitable for housing plan. However, it is the largest such rural delivery on such a large scale. There is also a settlement with an extensive and varied range of lack of transport infrastructure within the village. shops and local services. The proposed housing growth set out in the Local Plan is a similar rate to historic levels of growth and that suggested in the draft Cheddar Neighbourhood Plan. The plan Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 87

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

identifies a range of transport infrastructure improvements.

Strong support for North Petherton as a Tier 1 Noted and agreed. settlement as it has a good range of services and is strategically well located to its neighbouring towns.

Concern that the classification of North Noted. Developments will need to be supported Petherton as a Tier 1 settlement will put by a transport impact assessment. pressure on junctions along the A38 that have existing capacity problems.

Cheddar stands within and immediately Policies in the Local Plan address these concerns. adjacent to the Mendip Hills AONB and current Landscape impacts and ecological impacts have plans for Cheddar would compromise the been assessed and the scale and layout of environmental status. development will need to minimise adverse impacts.

Burnham-on-Sea and Highbridge - Refined Options

Summary of issues raised How it has been addressed

Highway improvements need to be considered The Local Plan does not identify further growth in along Stoddens Rd, Love Lane and Frank Foley this area. However, there may be opportunities to Way to manage the speed of vehicles. promote local safety schemes through Somerset County Council as highway authority.

Plot A should be well integrated with the This site is not allocated in the Local Plan. existing development allowing for pedestrian and cycle movement between the sites by creating connected and walkable communities.

Site A should only be developed if there were conditions on development and it is shown to be viable because of the rhynes.

Support for the land at Stoddens Lane which Noted. However at the current time there is neither would bring forward a relief road to help the strategic need for development of this scale, address congestion within the area. or a deliverable option. Significant work is needed to identify the strategic transport requirements and Sites D and E represent an opportunity to flood risk mitigation strategy. The Local Plan does deliver a strategic allocation that would include detailed text referring to the future potential contribute to the delivery of a new road to for development in this area and the on-going duty access the Brean and Berrow tourism area. to cooperate discussions with North Somerset. 88 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

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Summary of issues raised How it has been addressed

The allocation of Stoddens Lane could deliver This site is not allocated in the local plan but flood a flood defence solution as the whole site is defence and other infrastructure requirements can located within Flood Zone 3. be considered in a future plan should this area be identified for strategic growth.

Concern that development D will greatly Any potential development in this area would need increase the traffic flow, particularly if there will to be supported by a strategic transport only be one entrance and one exit which will assessment. Until this and other technical work also make the site isolated. has been undertaken and the finding understood, it is not considered appropriate to allocate this site. The site should only be considered as part of the larger strategic option to the north.

Site C is suitable and available for residential Agreed, this site is allocated for residential development that is preferable to commercial development. It is at low flood risk compared to use in this area. other sites in the area and well located to employment opportunities.

Some support for discounting sites B and C in Site B forms an extension to the allocated Brue as they would result in the most significant Farm whilst site C is adjacent to the M5 and impact on landscape and the setting of the existing employment development. It is not town. considered that they have unacceptable landscape impacts.

Development in any of the areas promoted Agreed. The Local Plan protects the existing BASC must not result in the boundaries of the BASC facility. ground being weakened, and once development is granted the site should be enhanced to meet a greater demand for services offered at the ground.

Land to the east of Frank Foley Parkway should These sites have significant flood risk and surface be included as part of the urban extension, as water drainage constraints. Until the long term sites A and B are the most logical options due flood defence strategy has been identified and to their proximity to public transport, the town surface water constraints addressed it is not centre, schools, the road network and business appropriate for development to be considered in opportunities at Isleport. these locations. The area is also protected as countryside around settlements under Policy D34. Additionally the Local Plan identifies deliverable opportunities that are at lower flood risk.

Development should be designed to minimise Noted, no housing allocations are proposed that visual impacts from the perspective of Brent would directly impact upon Brent Knoll at this time. Knoll. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 89

Regulation 18 - Main Issues Raised 3

Cheddar - Refined Options

Summary of issues raised How it has been addressed

The land to the south of Labourham Way is The site is not considered to be as well related within a low flood risk area, outside of the AONB to the village, is close to the AONB, and within and is near to/adjacent to surrounding land uses an area used by bats for foraging. The site in the Winchester Farm area and would be therefore has not been allocated for residential appropriate for employment use. use although a smaller part is identified for commercial development.

Site I for employment use is appropriate as it Agreed, this site is identified for employment use. would provide development opportunities that meet the needs of the community.

Concern that little or no action will be taken The Local Plan identifies traffic improvements but towards the narrow roads, lack of pavements or there is no realistic prospect of a bypass in the a bypass. short term.

Strong support for self-build in Cheddar to Noted. Policy D10 provides policy support for self enable people to obtain their dream affordable build and self commissioned housing within or home; Site D would be an ideal location as it is adjacent to the settlement boundary. a site suitable for low density housing that is well linked to the village and its facilities.

Object to development without infrastructure The local plan identifies a range of infrastructure being planned as Cheddar’s existing facilities that new development will deliver. are stretched to breaking point, for example there is concern that children have to travel from Cheddar to Axbridge to the junior school.

Area A would be a good site if further light Noted. This site is not allocated but any proposals industrial premises are required in Cheddar as would be considered under the rural brownfield they are well screened by hedging. site policy.

Options B and C would destroy the landscape This has been considered through the and village feel that tourists come to see and a sustainability appraisal of the different site options significant increase in housing in Cheddar would for Cheddar. There are no grounds for this detract from this area as a nationally important concern. Policies seek to promote enhancement tourist area. of Cheddar Gorge and deliver infrastructure improvements including junction improvements.

Options F and H should not be included as they Noted. Site F is not allocated. Site H is primarily are in Flood Zone 3. outside the flood zone and is likely to come forward for residential development.

Options A and G are within the AONB so should Neither site is allocated for development in the not be considered. Local Plan.

Development must be kept as far as possible Noted. This would be taken into account when from ancient woodland, with a buffer area considering any proposals that impacted upon maintained between the ancient woodland and ancient woodland. any development boundary. 90 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Cheddar has an above average ageing Noted, the size, tenure and type of housing will population, so surely there is a need to facilitate be considered at the application stage and is suitable accommodation for the elderly and expected to reflect local needs and thereby freeing up suitable family demographics. accommodation.

Concern that there is still no evidence of such Development at Cheddar identified in the Local ‘local’ need for the proposed housing in Plan is to meet the district housing needs set out Cheddar. in the SHMA.

Support for the proposal for north of Hellier’s This site is allocated in the Local Plan. Lane as the best location.

Concern that the reliance on the single proposed Unclear what the ground for this are. As a site for access point will risk the effective delivery of site about 150 units, a single access point is B. acceptable.

It is not clear what benefits would be secured The Local Plan sets out the benefits that include by linking the proposed sites B and C. traffic improvements on Upper New Road, improvements to the magic roundabout, enhancement of Sharpham Road playing fields and enhancement to the Strawberry Line.

Support for Site H but as a residential Noted, the plan has assumed this site will come development site to contribute to the Council’s forward for residential development. 5 year land supply of housing as it connects most easily with the existing village centre and other facilities and is within the development boundary.

Cheddar should not take more than 300 homes The level of growth suggested for Cheddar is up to 2032. similar to the historic rate and can be delivered without significant negative impacts. The Local Plan broadly reflects the emerging neighbourhood planning work rolled forward to 2032.

Cheddar should have adequate pedestrian Whilst this is something to aspire to the reality is facilities including wider pavements to take a that in Cheddar, as with most rural villages, this pushchair/wheelchair and zebra crossings. is not possible. The focus is on improvements, particularly in the village centre.

Sharpham Road Bridge needs to be widened, Noted. This issue relates primarily to obligations incorporating pavements on both sides. attached to recent development. Potentially development at Helliers Lane might contribute to improvements in this area.

Only limited infill within the boundary should be The Local Plan supports appropriate infill considered, ensuring the provision of sufficient development and requires development to accord off-road parking with these new builds. with the County parking standards. However, there are limited opportunities and therefore a need to allocate greenfield sites as well. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 91

Regulation 18 - Main Issues Raised 3

Summary of issues raised How it has been addressed

If site I is developed for further employment it is The allocation requires a traffic impact on the wrong side of the village to access the assessment and the uses are restricted to B1 A38 and M5 causing an increase of traffic and B2. However, it offers the opportunity for through the centre. appropriate expansion of existing businesses or new investment.

Site D would encourage vehicle movements due This area is not allocated although potentially self to distance from the amenities. build opportunities might be considered on their own merits. Concern that Site D is highly visible due to its elevated position.

North Petherton - Refined Options

Summary of issues raised How it has been addressed

Concern that a lack of brownfield sites available Policies in the local plan seek to protect for development will lead to the loss of valuable landscape quality and ecological interests. agricultural land and extensive environmental damage.

Objections to development on Greenfield land as it will remove habitat and hedgerows for wildlife such as the House Sparrow and Starling.

Disagreement to include the land south of Park This site is not allocated and the area is Lane (Site F) as it is encroaching the green edge. identified as countryside around settlements under Policy D34 recognising the importance of protecting the separation between Bridgwater and North Petherton.

Site F adjoins the A38 and a new access is Noted, however retaining the separation achievable. between the town and Bridgwater is an important objective and the area is identified as Support for Site F which is identified within Flood "countryside around settlements" under D34. Zone 1 and is at the lowest risk of flooding.

It is unclear if a bypass is required to support The Local Plan does not include a bypass additional development in North Petherton to although this option can be assessed further address the congestion in the town centre, as either through neighbourhood planning or a well as how it could be funded. future transport strategy. Instead the focus is on local traffic management to ease congestion and more modest levels of growth. 92 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

3 Regulation 18 - Main Issues Raised

Summary of issues raised How it has been addressed

Support for a bypass to relieve traffic but concern Noted. The Local Plan does not promote a the two proposed routings are far from ideal; it by-pass and instead the focus is on traffic would be logical to run the road as far as possible management through the town centre. The alongside the M5. existing Parkersfield facility provides for a wide range of sport and recreation and is protected One of the proposed routes for the bypass passes under Policy D36. through Parkersfield, which is an invaluable open community space providing sports facilities, a nursery, a community hall, 2 playgrounds, a BMX track and Greenfield space; this area would become even more essential following the proposed developments.

Concern there is no provision for additional school Whilst it is not possible to expand North places or doctor’s surgeries planned in the Petherton Primary School an allocation for a document. new primary school at Willstock Village is included in the plan. This will provide additional places in the area. Policy D31 provides support for additional healthcare facilities where needed. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 93

Regulation 19 - Consultation 4

Overview

4.1 Following the preparation of the Local Plan under the regulation 18 consultation stages the Council prepared the publication version of the Local Plan for formal consultation. This document is known as the Proposed Submission Local Plan, with formal consultation being undertaken following Council approval to submit this version to the Planning Inspectorate for public examination. Public consultation on the proposed submission documents took place between 30th January 2017 and 17th March 2017, meeting the minimum statutory six week consultation period.

Consultation Undertaken

4.2 Copies of the Local Plan and other proposed submission documents were made available in a number of forms, including as online web pages, as electronic documents and as hard copy versions. Hard copies of the documents were made available for inspection at the Council offices and libraries across the District.

4.3 Those who had been invited to comment or had previously commented during the regulation 18 consultation stages were sent notifications of the consultation by either letter or email. Notifications were also sent to anyone else who had since had been added to our consultation database and wished to be kept up-to-date regarding planning policy consultations. Notifications included a statement of the representations procedure and where the proposed submission documents could be inspected. Representation forms for commenting on the plan were made available in a number of formats, including web page, fillable pdf, MS word, and as hard copies. To try and aid understanding of how to most effectively comment on the Local Plan the Council also prepared a guidance note on legal compliance and the tests of soundness. Copies of supporting material used during the regulation 19 consultation are included in Appendix 6.

4.4 As with the previous consultation stages the Council used a range of methods to consult and raise awareness with stakeholders and interested parties. This included newsletters, leaflets, press releases, public notices, posters, public exhibition events and meetings as described in more detail in section 2. For the regulation 19 consultation the following public consultation events were organised:

Regulation 19 Consultation - 30th January 2017 to 17th March 2017

Saturday 4th February (10am - 2pm) - Angel Pace Shopping Centre, Bridgwater

Monday 6th February (2pm - 7pm) - Community Hall, Highbridge

Tuesday 7th February (3pm - 7pm) - Village Hall, Woolavington

Wednesday 8th February (3pm - 7pm) - Princess Theatre, Burnham-on-Sea

Thursday 9th February (3:15pm - 7pm) - St John and St Francis School, Bridgwater

Monday 13th February (2:30pm - 7pm) - St Georges School, Wembdon

Wednesday 15th February (3pm - 7pm) - Village Hall, Wedmore

Thursday 16th February (2pm - 7pm) - Community Centre, North Petherton

Monday 20th February (3:30pm - 6pm) - Town Hall, Axbridge

Tuesday 21st February (2:30pm - 7pm) - Village Hall, Cheddar 94 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

4 Regulation 19 - Consultation

Regulation 19 Consultation - 30th January 2017 to 17th March 2017

Thursday 23rd February (2pm - 6pm) - Village Hall, Cannington

Monday 27th February (3pm - 7pm) - Church Room, Puriton

Thursday 2nd March (3pm - 7pm) - Village Hall, Nether Stowey

4.5 Although not a formal requirement of the regulations at this stage Appendices 2 - 5 includes some examples of the methods of communication used and media coverage during the regulation 19 consultation stage.

Representations Received

4.6 The table below sets out the total number of separate comments received during the regulation 19 consultation stage and how many people/organisations commented. Out of the 293 respondents, 64 have indicated that they consider it necessary to participate in the oral part of the examination.

Consultation Stage Total Comments Total Respondents

Proposed Submission Local Plan 921 293 (2011-2032)

4.7 Representations were received in the form of both paper hard copies and electronic submissions. Some respondents had used the representation forms provided by the Council whilst others provided comments as letters or emails. Where respondents to the Local Plan commented online or used one of the available representation forms it included asking whether they considered the Local Plan to be legally compliant or sound. For context the following tables provide a breakdown of the answers for all comments received:

Do you consider the Local Plan is % Total % Answer Count Legally Compliant?

Yes 39% 72 356

No 15% 28 139

Blank (no response) 46% - 426

Total 100% 100% 921

4.8 This indicates that whilst a significant proportion (46%) of respondents did not comment on whether or not they considered the Local Plan legally compliant, of those that did comment around 70% considered the plan to be legally compliant. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 95

Regulation 19 - Consultation 4

Do you consider the Local Plan % Total % Answer Count is Sound?

Yes 6.5% 10% 60

No 61.5% 90% 567

Blank (no response) 32% - 294

Total 100% 100% 921

4.9 Compared to legal compliance a larger proportion of comments indicated whether or not they considered the plan sound. Of those which answered 90% of comments indicated that plan was not sound for one reasons or another. The following table provides a breakdown on which grounds respondents considered the Local Plan was unsound. Given that for each comment more than one reason could be indicated for why the plan is considered unsound, for the table below the total count exceeds the number of comments received (921):

If you consider the Plan is unsound, on % Total % Answer Count which grounds do you consider the document in unsound?

Positively Prepared 18% 23% 325

Justified 23% 28% 406

Effective 23% 29% 411

Consistent with National Policy 16% 20% 294

Blank (no response) 20% - 366

Total 100% 100% 1,802

4.10 This indicates a generally even split in terms of which tests of soundness respondents felt the plan fails to satisfy, with failure of the plan to be justified and effective indicated the most frequently in comments. 96 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

Regulation 19 - Main Issues Raised

5.1 Copies of each representation received during the regulation 19 consultation (i.e. pursuant to regulation 20) are submitted alongside the Local Plan to the Planning Inspectorate in both hard copy and electronic formats. All representations can also be viewed electronically via the Council's consultation portal. On the consultation portal representations can also be filtered by specific respondent.

5.2 A summary of the main issues raised in representations on on the Proposed Submission Local Plan are listed in the table below under different topic areas. Given the number of individual comments received this summary does not try to capture every detailed matter raised by respondents. All individual comments are publicly available to view in full.

General and Whole Plan Comments

That the Local Plan as a whole does not provide enough support for small and medium sized enterprises (SME's), in terms of supporting start-ups and future growth.

General support from a number of Parish Council's in terms of plan approach and identification of a wider range of rural settlements.

No plan wide viability assessment has been undertaken to support the policies and allocations in the Local Plan.

Support for the plan as a whole from a number of specific bodies, including the Environment Agency and Somerset County Council Transport Policy.

There an anomalies and gaps in the evidence base presented to support the plan and justify the approach.

A number of objections raised regarding the Sustainability Appraisal, including whether sites have been correctly or consistently assessed against certain Sustainability Objectives.

A number of specific bodies indicate assisting in plan preparation in relation to duty to cooperate requirements. But concerns raised that no evidence provided with the plan to reflect any cooperation having being undertaken in relation to the Council's duty to cooperate requirements.

No reference made in the Local Plan to the recently approved Garden Town within Somerset.

Terminology used in relation to the release of sites outside of the settlement boundary is inconsistent in policies across the plans.

Across a number of policies greater clarity is required regarding what consultation with the Parish Council and local community will be expected for development sites released outside of settlement boundaries.

A number of policies across the plan should refer to and to take into account neighbourhood plans where they are adopted or in the process of being prepared.

Policies and allocations in the plan need to be strengthened in terms protecting and enhancing the historic environment/designated heritage assets.

A number of omission sites put forward in various locations across the District, with respondents making a case for their inclusion in the plan. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 97

Regulation 19 - Main Issues Raised 5

General and Whole Plan Comments

There should be better cross-referencing between relevant policies in the plan.

Consultation Arrangements

Consultation has been inadequate and poorly executed for both the current regulation 19 and previous regulation 18 stages.

The consultation events were poorly undertaken, including advertisement of events and limited hours of access precluding attendance by some members of the public.

That using either the online system or electronic representation forms for commenting is time consuming, confusing and unreliable.

That the length of the document makes it difficult for members of the public to comment effectively.

That the Local Plan falls short of statements made in the Council's published regulation 18 consultation statement.

Views of Parish Council and local community, including those engaged in neighbourhood planning, are not being listened to in preparation of the plan.

Introduction and Spatial Portrait

Some support for revised wording to Spatial Portrait following regulation 18 consultation.

The Spatial Portrait wording needs to be strengthened in relation to protected landscapes.

Spatial Portrait needs to mention other major roads not just the M5, with more recognition is needed to problems of increased traffic on trunk roads and junctions outside of the main urban areas.

Queries over what is meant by affordable housing and how the need discussed in the Spatial Portrait has been calculated.

Text in Spatial Portrait needs to be more specific about infrastructure requirements.

That the importance of sustainable modes of transport (e.g. walking and cycling) needs to be strengthened in the text.

Vision and Priorities

Vision and Strategic priorities recognise the problems but no ideas/solutions to address them.

Some of the wording used in the vision and priorities section considered inconsistent with wording used later in the plan.

Vision and priorities will not be delivered and are not reflected by the policies/allocations in the plan. 98 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

Vision and Priorities

The vision and strategic priorities should be strengthened in relation to infrastructure provision, the role of trees and woodland, sustainable transport alternatives, addressing traffic congestion, attracting businesses, education and protecting landscape designations.

Policies in the plan do not respect the overarching priority to respect the function and character of settlements.

Strategic Policies

Policy S1 should be amended to recognise NPPF requirement for development to be restricted in certain areas.

There is a conflict in the spatial strategy between delivering new development and protection of the countryside and designated landscapes.

Support from some for settlement hierarchy and that it reflects the most sustainable pattern of development.

Objections to the settlement hierarchy in relation to the status of a number of the settlements, with different respondents putting forward reasons as to why they should be either higher or lower in the hierarchy. In particular a large number of objections in relation to Tier 1 and Tier 2 settlements, with many considering that they are not sustainable locations for the scale of development indicated and should therefore be moved lower down the hierarchy.

That in determining the hierarchy that settlements have not been assessed consistently in terms of services/facilities and other planning considerations.

Concern that in determining different settlements place in the hierarchy and their ability to accommodate new development the Council has not adequately taken into consideration a range of issues, including: settlement character/identity, the range of local services, infrastructure capacity, traffic congestion, connectively to strategic road network, availability of public transport, school capacity, employment opportunities, impact on tourism, flood risk and relevant nature conservation/landscape constraints.

The Council's role and function evidence base which informed the settlement hierarchy is not accurate, including not taking into account the role of tourism specific facilities.

That development should be more dispersed across the District, rather than focused in specific locations which will disrupt the character of settlements.

More development should be focused on the M5 corridor rather than in rural areas, given the better transport links.

Concern regarding development encroaching on green fields outside settlement boundaries, particularly in rural locations, given lack of sites within settlements.

Scale of development at Burnham-on-Sea considered insufficient to maintain its status. There is also a disparity in the scale of growth proposed for Cheddar and North Petherton, both Tier 1 settlements. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 99

Regulation 19 - Main Issues Raised 5

Strategic Policies

Spatial Strategy fails to provide adequately for cross-boundary objectively assessed housing need (OAHN). No statement of cooperation confirming that OAHN across the Housing Market Area will be met in full.

Queries on whether the Strategic Housing Market Assessment underestimates the OAHN for the District, including in relation to how historic migration, future population growth, household formation rates, market signals and affordable housing need have been considered.

Questionable whether increase in housing target in the plan is sufficient to boost housing supply in line with NPPF and ambitions of Housing White Paper.

OAHN needs to be increased as currently does not adequately take into account the additional needs arising from Hinkley Point C construction or the deficit of affordable housing in the District.

The methodology for calculating the OAHN will need to be revisited before adoption given the announcement in the Housing White Paper.

It is not clear whether the residual housing requirement takes into account a non-implementation lapse rate for existing commitments.

The plan fails to provide for a 5 year supply of housing land upon adoption and uses an inappropriate methodology. No flexibility in Housing Land Supply.

That the policy approach to managing housing delivery if a 5 year supply cannot be demonstrated is inconsistent with Tier 2 housing policies considered later in the plan.

That the strategy is heavily reliant on large scale urban extensions in meeting the Districts housing needs.

Policy wording in relation to allowing very exceptional limited development in Tier 5 settlements needs to be clearer and less ambiguous, including more detail to what level of local support is required.

Local Plan approach of prioritising brownfield land in the plan is inconsistent with the NPPF.

Sedgemoor District Council not ensuring that infrastructure is in place before development takes place.

Questionable whether infrastructure (e.g. transport, education, community facilities) will cope for the amount of growth. Vital roads and other infrastructure should be a requirement of any new development.

For transport infrastructure focus is mainly on walking and cycling, investment in other transport infrastructure (e.g. roads) is long overdue.

Infrastructure Delivery (Policy S3) should be strengthened to provide certainty that decision makers ensure required infrastructure is provided.

Concern that the Infrastructure Delivery Strategy (IDS) supporting the plan is not detailed enough regarding required infrastructure for specific areas or allocations, and does not take into account historic infrastructure problems. It needs to include infrastructure that enables delivery of development. 100 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

Strategic Policies

Policy wording on infrastructure requirements places unreasonable burden on small businesses and individuals.

Viability considerations need to be strengthened for infrastructure policy (Policy S3). There should also be recognition that commercially sensitive elements of viability appraisals should be kept confidential.

Plan needs to take into account that most areas of the District are not benefiting from Hinkley Point C infrastructure mitigation.

General support for Sustainable Development Principles (Policy S4), but policy wording should be amended in a number of areas (e.g. brownfield development, flood risk) and some considered that the overall spatial strategy did not accord with the policy principles.

Majority of comments supportive of policy addressing climate change mitigation and adaptation (Policy S5).

Place-Making Policies: Bridgwater

Land at West Bridgwater – the most objections to any policy, many in principle but also suggesting that detailed research needed to understand measures to address traffic issues. Traffic generated during construction and occupation of residential areas and school will create safety and congestion problems. Suggestions that any residential development in this area should be phased beyond Hinkley C construction.

Land at East Bridgwater- objections to use of greenfield sites, Bower Lane should remain undeveloped, concerns regarding traffic impacts, lack of infrastructure to cope with growth, environmental concerns including flood risk, and suggestion that overall development numbers should be reduced.

Some concerns regarding development to the south of Bridgwater and the loss of the green wedge. Suggestion that any further development in this area should be phased later in the plan and must be supported by infrastructure.

Objection to employment land at Huntworth and impact on existing residents. Scale of development should be reduced.

Opportunities to deliver a northern and western by-pass have not been considered.

Place-Making Policies: Burnham-on-Sea and Highbridge

Both objections and support for residential development to the north of Stoddens Road in this and future plans.

Objections to the non-allocation of land to the east of Frank Folley Parkway and love Lane.

Suggestion that Brue Farm allocation should be extended to include additional available land although other objectors question the deliverability of this site.

Some local objections to BH3 land off Isleport Lane Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 101

Regulation 19 - Main Issues Raised 5

Place-Making Policies: Burnham-on-Sea and Highbridge

Objection to the inclusion of supporting text that refers to the possibility of growth from North Somerset being accommodated within the north Burnham area as well as suggestions that these paragraphs be amended to reflect the current status of the West of England joint spatial plan.

Objections to the extent of the defined tourism boundary and supporting text.

Objections to the extent of the proposed town centre boundary.

Place-Making Policies: Tier 1 Settlements

For Cheddar the plan fails to take into account proposals and allocations made within the Neighbourhood Plan.

Loss of identify of both Cheddar and Axbridge would result from large scale expansion.

Should only retain housing within the settlement boundary to meet local needs.

All development should comply with the Parish Councils interim Neighbourhood Plan.

Overall concern that there is not sufficient infrastructure to meet the demands of increased development.

Particular concerns raised about the capacity of highways to accommodate further growth in this area and C1 should be deleted

Questions as to what improvements there can be to Sharpham Road playing fields, some objectors wish to see C2 deleted and retained as green wedge.

General objections to employment land at C4 due to traffic concerns and suggestion that alternative site next to Cheddar Business Park should be allocated.

Support for mixed-use development on Yeo Valley site although counter views that it should be retained for commercial uses.

Cheddar should not be viewed in isolation and development will have impacts on neighbouring parishes such as Shipham.

Further detailed comments regarding highway capacity, impact of HGV’s through the centre of the village and wider area.

North Petherton place-making policies should retain the option of a North Petherton by-pass.

A new secondary school is needed in the North Petherton Area.

A number of objectors suggest alternative/additional sites at North Petherton.

Place-Making Policies: Tier 2 Settlements

Objection to the interim criteria policy - detailed allocations should be made in the plan now. 102 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

Place-Making Policies: Tier 2 Settlements

Suggested housing figures for settlements should be the maximum number. Any increase should be limited to no more than 20% and demonstrate no adverse impacts.

Suggested housing figures for Wedmore should be increased.

Objections to policy approach for Puriton, Woolavington, Axbridge and that they should not be designated as Tier 2 settlements.

Higher levels of growth should go to Cannington, reflecting opportunities in the SHLAA and the proximity to Hinkley.

Policies should have greater emphasis and recognition of the historic environment.

Place-Making Policies: Tier 3 Settlements

Objection to the inclusion of place making objectives as policy.

Number of detailed site suggestions for villages in Tier 3.

No indication as to how the suggested 650 houses are to be allocated across the Tier 3 settlements.

Concern at need to provide a robust assessment of alternative SHLAA sites to demonstrate that application site is most appropriate.

Place-Making Policies: Tier 4 Settlements

Clarification on policy wording, including what is meant by meaningful and robust consultation referred to under Policy T10.

Policies should specifically refer to enhancement of the historic environment.

Some support for more flexible approach, including allowing an degree of market housing in tier 4 settlements to make schemes viable.

Place-Making Policies: Tier 5 Settlements and Countryside

Concerns as to the detailed interpretation of Policy T11 and that a number of areas of the policy wording need to be clarified.

Detailed comments on the status of Compton Bishop, including the extent of the area the policy applies to and how AONB will be considered.

Policies for the countryside are too restrictive and do not support small businesses.

Polices should allow development of sustainable greenfield sites on the edge of existing settlements.

Major Infrastructure Projects

Early engagement on major infrastructure projects impact necessary to understand and mitigate impacts, including construction traffic on the Strategic Road Network. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 103

Regulation 19 - Main Issues Raised 5

Major Infrastructure Projects

Phasing of any major infrastructure projects alongside build out of any strategic housing allocations will be an important consideration.

More positive approach needed in relation to temporary and permanent Hinkley Point C workers.

Approach to addressing Hinkley Point C workers accommodation needs to be consistent with NPPF, including with regard to flood risk. Local Plan does not address the impacts on Cheddar with regard to Hinkley development, despite the implications in terms of HGV traffic. Hinkley Community Impact Mitigation Fund should be used to deliver required infrastructure improvements.

District Wide Policies - Living Sustainably

Flood Risk policy (D1) should be strengthened in relation to making reference to caravan and camping, the important role of tree planting in flood risk management, and ensuring any residual flood risk in new development should be addressed.

Concerns that all new build development will not need to meet minimum space standards and that this will lead to inferior housing.

Given that adopting minimum space standards needs to be clearly evidenced any reference to space standards should be removed.

Objections that the plan on the basis that it introduces sustainability standards that exceed those prescribed in Building Regulations and that this in contrary to national policy.

No evidence provided for adopting higher water efficiency standards as set out in Policy D3.

Requirements of policies in this section are onerous and need to be proportionate to the scale of individual proposals. Only appropriate for certain major developments.

Policy D4 regarding renewable or low carbon energy and heat generation is not consistent with NPPF in terms in relation to consideration of AONB.

That Policy D5 introduces additional technical standards that are contrary to the NPPF and does not reflect the energy hierarchy

Housing Policy (D6) should respond to local demand in terms of housing mix and address the needs of older persons better, including the need for bungalows.

Approach requiring adaptability/accessibility in contrary to national policy. Evidence needs to be provided for adopting standards.

Policy wording in relation to housings needs to reflect new position in relation to starter homes following Housing White Paper.

Policy D7 should be more explicit in setting affordable housing targets. The differing thresholds for seeking contributions across different settlements is also confusing and not compliant with relevant Ministerial Statement. 104 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

District Wide Policies - Living Sustainably

Affordable housing tenures should reflect local need and be consistent with emerging national policy.

Need for integration of affordable and market housing should be explained further.

Policy and text in relation to Specialist Accommodation (D8) should be more flexible regarding different models of provision and provide stronger wording regarding any off-site affordable housing provision.

Objections to requirement for self build plots as part of allocated sites given practical complications and viability considerations.

Some general support for policy approach to allow rural self build schemes (D10), but objections to wording and terminology in terms of clarity and consistency with other policies in the plan.

Concerns raised that the self build policy may be too permissive in rural areas.

That rather than having a criteria based policy the plan should be positively allocating sites for self build.

Transport policies must consider wider area impacted by development and ensure that required improvements are in place prior to development happening.

Wording in transport policy (D15) should be strengthened in relation to travel planning, development affecting level crossings and encouraging early pre-application engagement.

District Wide Policies - Ensuring Economic Wellbeing

Approach to managing employment land (Policy D16) makes no reference to SME's and is not consistent with spatial strategy in terms of development in rural locations having to demonstrate a countryside need.

Objections to policy approach to safeguarding existing employment land (Policy D17), stating that it is overly onerous and not consistent with the NPPF.

Approach to tourism policy needs to be more supportive and permissive of development and include a consistent long-term approach to addressing flood risk in the Brean area (Policy D18).

Policy D18 needs to ensure tourism/holiday accommodation is used for that purpose.

Policy approach for retail (D19) should have greater flexibility, including removing the prescriptive approach of defining primary and secondary frontages.

The retail area of Wedmore should be included in policy D19 and be shown on the policies map.

District Wide Policies - Enjoying and Achieving

Supporting text and policy wording in relation to landscape quality and conserving and enhancing areas of AONB should include more detail and be strengthened, including being more explicit about protecting and enhancing its setting and views from areas of AONB. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 105

Regulation 19 - Main Issues Raised 5

District Wide Policies - Enjoying and Achieving

Some considered that the landscape policy should be less onerous and be clearer in terms of the instances where Landscape Visual Impact Assessments are required.

Policy D21 currently makes no reference to geodiversity and should be strengthened to ensure a clearer approach to protecting and enhancing nature conservation sites, including better reflecting the mitigation hierarchy.

Policy relating to biodiversity and geodiversity places an unreasonable burden on small developments.

Ecological networks mapping referred to is currently not shown on the Policies Map.

Some objections to the ecological networks policy (D22) wording that it is to restrictive compared to the NPPF, while other considered it should be strengthened further.

Support for new policy in relation to trees and woodland, but reference to TPO's unnecessary given they already have protection under legislation.

Pollution Policy (D25) does not provide sufficient protection of all controlled waters and should include more specific detail on sensitive receptors.

Historic Environment policy needs some rewording to ensure clarity and conformity with the NPPF.

Overall support for archaeological policies (D28 and D29) although some changes should be considered to ensure a proportionate approach in terms of assessments required.

District Wide Policies - Being Healthy

Concern regarding potential for double counting (i.e. CIL and Section 106) in relation to contributions to meet health needs.

General support for Green Infrastructure policies, though concerns from some that the section overall is inconsistent in its approach and would not be proportionate for certain development proposals. Policy wording should also be strengthened in terms of the multi-functional benefits of Green Infrastructure.

A number of objections to 'Countryside around Settlements' policy (D34) on the basis that it seeks to designate large areas of land and is not consistent with the NPPF. While others support the policy but consider the protection it offers should be strengthened and more areas should be identified.

Additional areas put forward for identification under the 'Open Areas Protected from Development' policy (D35).

Concern that the relationship of Policy D35 to Local Green Space is unclear, and that the policy is overly restrictive.

Overall support for policy protection for existing recreational outdoor space (D36), but concerns that some areas identified on the Policies Map are not accessible to the public. 106 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

5 Regulation 19 - Main Issues Raised

District Wide Policies - Being Healthy

Recommended that the council undertake an up-to-date playing pitch strategy and assess the needs and opportunities for sporting provision.

Objections of the requirements set out for outdoor public recreation space for new development (D37). Considered the requirements are not justified and are disproportionate to the impacts of development.

Appendices

Indicative plans are inconsistent in some areas with the allocations as identified in the policies in the Local Plan and as shown on the Policies Maps.

Some of the access arrangements shown on the indicative plans are incorrect or are one of a number of access options.

Further indicators should be added to the monitoring framework to better monitor policy implementation.

Policies Map

A number of representations seeking changes to the settlement boundaries at different locations across the District.

A range of additional sites promoted where respondents have indicated they should be identified for development on the Policies Map to meet the Districts needs.

Tourism boundary should be extended to support investment and take into account potential additional land requirements for remodelling of tourism uses.

Recreational areas shown should be updated and amended, including removing sites where they are not accessible to the public.

Suggested Modifications Document

5.3 Following review of representations made on the Local Plan the Council has drafted a schedule of suggested modifications for instances where the Council agree that a change should be incorporated into the plan. This schedule is submitted alongside the Local Plan for consideration through the examination process. The intention is that if some of these changes are taken forward it should assist in securing the overall soundness of the Local Plan and as far as possible resolve some of the objections made, allowing the examination to focus on particular key areas. Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 107

Appendix 1 - Specific and General Consultation Bodies 108 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 1 - Specific and General Consultation Bodies

Specific Consultation Bodies

Below is the list of specific consultation bodies invited to make representations during the Regulation 18 consultation. This is taken from the Council consultation database.

Aller Parish Council Ashcott Parish Council Avon and Somerset Constabulary Axbridge Town Council Badgworth Parish Council Bawdrip Parish Council Berrow Parish Council Bishops Lydeard and Cothelstone Parish Council Blagdon Parish Council Bleadon Parish Council Brean Parish Council Brent Knoll Parish Council Bridgwater Town Council Bridgwater Without Parish Council Bristol Water British Telecom PLC Broomfield Parish Council Burnham Without Parish Council Burnham-on-Sea & Highbridge Town Council Burrington Parish Council Burtle Parish Council Cannington Parish Council and Neighbourhood Plan Steering Group Catcott Parish Council Chapel Allerton Parish Council Cheddar Parish Council Cheddon Fitzpaine Parish Council Chedzoy Parish Council Chilton Polden Parish Council Chilton Trinity Parish Council Churchill & Langford Parish Council Civil Aviation Authority Coal Authority Compton Bishop Parish Council Cossington Parish Council Creech St Michael Parish Council Crowcombe Parish Council Durleigh Parish Council East Brent Parish Council East Huntspill Parish Council Edington Parish Council EE Enmore Parish Council Environment Agency Fiddington Parish Council Goathurst Parish Council Godney Parish Council Greinton Parish Council Health and Safety Executive Heart of the South West Local Enterprise Partnership High Ham Parish Council Highways England Historic England Holford Parish Council Homes and Communities Agency Inland waterways Kingston St Mary Parish Council Loxton Parish Council Lympsham Parish Council Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 109

Appendix 1 - Specific and General Consultation Bodies

Lyng Parish Council Marine Management Organisation Mark Parish Council Meare Parish Council Mendip District Council Mendip Hills AONB Middlezoy Parish Council Mobile Operators Association Moorlynch Parish Council National Grid Natural England Nether Stowey Parish Council Network Rail NHS England (Commissioning Board) North Curry Parish Council North Petherton Town Council North Somerset Council Office of Rail Regulation / Office of Rail and Road Openreach Othery Parish Council Otterhampton Parish Council Over Stowey Parish Council Pawlett Parish Council Priddy Parish Council Puriton Parish Council Quantock Hills AONB Rodney Stoke Parish Council Shapwick Parish Council Sharpham Parish Council Shipham Parish Council Somerset clinical commissioning Group Somerset County Council Somerset County Council (Education Authority) Somerset County Council (Highway Authority) Somerset County Council (Lead Local Flood Authority) Somerset County Council (Planning Policy) Somerset Drainage Boards Consortium Somerset Local Nature Partnership South Somerset District Council Spaxton Parish Council Stawell Parish Council Stockland Bristol Parish Meeting Stogursey Parish Council Stoke St Gregory Parish Council Taunton Deane Borough Council Three Thurloxton Parish Council Vodafone and O2 Wales & West Utilities Ltd Walton Parish Council Weare Parish Council Wedmore Parish Council Wellington Town Council Wembdon Parish Council Wessex Water West Bagborough Parish Council West Huntspill Parish Council West Monkton Parish Council West Somerset District Council Westbury-sub-Mendip Parish Council Western Power Distribution Westonzoyland Parish Council Winscombe and Sandford Parish Council Wookey Parish Council 110 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 1 - Specific and General Consultation Bodies

Woolavington Parish Council Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 111

Appendix 1 - Specific and General Consultation Bodies

General Consultation Bodies

Below is the list of the general consultation bodies invited to make representations during the Regulation 18 consultation. In addition to the organisations listed below individuals who were registered on our online consultation portal and had specified that they wished to be notified of consultation events were also sent emails or letters. At present there are 1,800 individuals or organisations registered on the Council's online consultation portal, of which approximately 1,300 had specified that they wished to be notified of consultation events. The Council seeks to ensure the database is kept as up-to-date as possible as organisations change and new organisations are identified.

Acorn Developments (SW) Ltd Acorus Rural Property Services Advantage South West Age Concern Somerset AJB (south west) Ltd Alder King Alletsons Solicitors Alliance Planning Allotment Society Ancient Monument Society Angel Place Anglo Irish Investments Ltd Animal Farm Adventure Park apwplanning Architecture by Design Arcus Consultancy Services Ltd Arup Asda Stores Ltd Association of Bridgwater Industrialists Atkins Ltd Axbridge Chamber of Commerce Axbridge Town Design Plan BAE Systems Barton Willmore Barton Willmore Planning Partnership Bell Cornwell Berry Associates Bilfinger GVA Bloor Homes Blue Cedar Homes Ltd. Bourne Leisure Ltd Bovis Homes Braveheart Consultancy Bridgwater & District Archaeological Society Bridgwater & District Civic Society Bridgwater Chamber of Commerce Bridgwater Churches Together/Church Leaders Forum Bridgwater Eastover Ward Bridgwater Forward Bridgwater Gateway Ltd Bridgwater Heritage Regeneration Partnership Bridgwater Industrialists Bridgwater Resource Recovery Ltd Bridgwater Senior Citizens Forum Bridgwater TUC Bridgwater YMCA Brimble Lea & Partners Bristol & Severnside Rail Partnership Burnham Chamber of Commerce Burnham Development (Somerset) Ltd Burnham Development Somerset Ltd Burnham Traders Association 112 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 1 - Specific and General Consultation Bodies

CABE (South West) Caldecotte Consultants Campaign for Real Ale Caravan Club Carleton Lord Carpets Ltd Carter Jonas LLP Central Romani Travellers' Council Cheddar LVA LLP Chris Groves Associates Christopher Lyons Clark Landscape Design Clive Miller & Associates Clive Miller Associates Clobbers Cluttons LLP Colliers CRE Colliers International Community Council for Somerset Compass Disability Services Concise Construction Ltd Court Design CPRE Somerset CSJ Planning Consultants Ltd Cushman & Wakefield D2 Planning Limited David Ames Associates David Lock Associates Defence Estates Operations South Dentons Department of Works and Pensions Devon & Somerset Fire and Rescue Service DLP Planning Douglas Smith Partnership DPDS (South West) Durston Parish Meeting Earlsfield Town Planning Ltd Earthstone EDF Energy Edwin Fisher Will Trust English Rural Action Ltd Entec Uk Ltd Equality South West Exmoor National Park Authority Farming & Wildlife Advisory Group Federation of Small Businesses Fernleigh Properties First Great Western First Somerset and Avon Flinders Design Forestry Commission Friends, Families and Travellers Support Group Fulford Land & Planning Fusion Online Ltd G L Hearn Garden History Society Genesis Town Planning Georgian Group Gladman Developments Ltd Graham Moir Associates Green Wedmore Greenhill & Brownfield Greenslade Taylor Hunt Gregory Gray Associates GVA Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 113

Appendix 1 - Specific and General Consultation Bodies

GVA Grimley Halcrow Group Limited Hammonds Yate Partnership Hannick Homes Harmony Land Ltd Harrow Estates Haygrove School Heriz Payne Ltd Highbridge Residents Association Highbridge Traders Association Hoddell Associates Hoddell Associates Ltd Holiday Resort Unity Holt Farms Ltd Home Builders Federation Homes In Sedgemoor Hooks Hornington Investments Limited Humberts Hunter Page Planning Ian Jewson Planning Ltd Insight Marketing Isle of Wedmore Society J24 Action Group Jane Clarke Architectural Services Jillings Hutton Planning JLL Job Centre Plus Jonathon Rhind Architects JS Bloor & Barratt Strategic Junction 24 Action Group Katmar Properties Limited Kenmore (Bridgwater) LLP King Alfred School Kirkwells Knight Frank Landhold Capital Leith Planning Ltd Level 7 Computers Luken Beck Ltd Lyndon Brett Partnership Magna Mark Cullen Martin Grant Homes Mead Realisations Ltd Menadorm Miles & Hurman Charity Trusts Miller Turner Investment Management Ltd Mitchell Architects MWA Nathaniel Lichfield & Partners Ltd National Farmers' Union South West Region National Federation of Gypsy Liaison Groups National Gypsy Council National Trust NEW Masterplanning Limited NLP Planning Open Spaces Society Pardoes Solicitors Parsons Brinckerhoff Paul Lillycrop Building Design Paul Martin Associates Paul Rowe Architectural Services PCAH 114 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 1 - Specific and General Consultation Bodies

PCL Planning Ltd Peacock and Smith Pegasus Group Persimmon Homes Severn Valley Peter Brett Associates LLP PJ Planning Planning Aid Planning Potential Ltd Planning Prospects planning2build Planware Ltd Port of Bridgwater PPDL PPS Group PR Bridgwater Ltd PRDesign Pro Planning PRO Vision Planning and Design Property Link (South) Ltd Puriton Primary School Quod Rackham Planning Ltd railfuture Redrow Rentplus Road Haulage Association Robinson & Brice Romani Gypsy Council Royal Mail Royal Mail Property Holdings Royal Society for the Protection of Birds RPS Planning RSPB Taunton SAGE Sainsbury's Supermarkets Ltd Salmon Planning Company Savills Sedgemoor Bridleways Association Sedgemoor Citizens Advice Bureau Sedgemoor Saunterers Sedgemoor Volunteer Bureau Sellwood Planning Severn Estuary Partnership SF Planning Limited SHAL Housing Ltd Shattock Associates Showmans Guild of Great Britain Small Industries Group Smith Gamblin Haworth Smith Jenkins SNR Denton UK LLP Society for the Protection of Ancient Buildings Somerset Archaeological Society (South) Somerset Association of Local Councils Somerset Building Preservation Trust Somerset Chamber of Commerce Somerset Economic Partnership Somerset Environmental Records Centre Somerset Gardens Trust Somerset Gateway Somerset Gay Health Somerset Industrial Archaeological Society Somerset Levels & Moors LEADER+ Somerset Racial Equality Council Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 115

Appendix 1 - Specific and General Consultation Bodies

Somerset Rural Youth Somerset Tourism Association Somerset Wildlife Trust South West Ambulance Service South West HARP Planning Consortium South West Law South West Reg. Committee of Jehovah's Witnesses Sport England St. John's Church, Eastover Stewart Ross Associates/DevPlan Strategic Land Partnership Stratus Environmental Summerfield SW Ltd Sustainable Axbridge Network Sustainable Somerset Group Sustrans Tamlyn & Son Taunton Access Group Taunton and Somerset NHS Foundation Trust Taunton Vale Gospel Hall Trust Taylor Wimpey Team Green Growers Ltd Telereal Services Telereal Trillium Terence O Rourke Terence O'Rourke Ltd Tetlow King Planning The Canal and River Trust The Isle of Wedmore Society The Jewellery Shop The Mendip Society The People's PLot The Planning Bureau Ltd The Silverwood Partnership The Strawberry Line Society The Town and Country Planning Practice Ltd. The Trustees of Lord Vesteys 1942 Settlement Theatres Trust Trevor J Spurway (Architects) Ltd. Trimwise Gym, Eastover Turley Unison South West Victorian Society Waddeton Park Ltd West Country Ambulance Service NHS Trust Westfield and Cannington Churches White Young Green Williams Planning & Design Consultancy Willis & Co. Women's Institute Woodland Trust Yarlington Housing Group Young Somerset Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 116

Appendix 2 - Newletter and Leaflet Examples Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 117

Appendix 2 - Newletter and Leaflet Examples

Example of Newsletter (page 1) 118 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 2 - Newletter and Leaflet Examples

Example of newsletter (page 2)

Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 123

Appendix 2 - Newletter and Leaflet Examples 124 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 2 - Newletter and Leaflet Examples Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 125

Appendix 3 - Press Release and Public Notice Examples 126 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 3 - Press Release and Public Notice Examples

Press Release Example

News Release

Have your say about shaping Sedgemoor’s future Local residents are being encouraged to seize the opportunity to have their say on how the district of Sedgemoor should grow and change over the next twenty years. Sedgemoor District Council has organised nineteen consultation events, as well as having the documentation on-line.

Sedgemoor District Council has a Local Plan, known as its Core Strategy, which is up for its five-year review and the Council would like to know what things people think needs changing or updating within the document. This review will forward the plan by another five years, planning new development in the District up to 2032.

To help gather this valuable feedback from the public, the Council has produced a consultation document and is inviting comments. Planning Officers have arranged a series of events, exhibitions and presentations where they can talk through the policies and listen to people’s views. The consultation is the first stage in a long prescribed process, which will end in June 2017.

This consultation period starts from Monday, October 26 until December 18 after which the Local Plan will be re-drafted incorporating the changes and put out for further consultation next summer. It will then be subject to examination by planning inspectors.

Among the topics covered by the Local Plan are Housing, Employment, Retail and Infrastructure. When adopted, the Local Plan will identify the Council’s vision for how these and other topics should be managed, which policies should apply and where new development should be allocated.

Other key issues for discussion include safeguarding the natural and historic environment, adapting to climate change and design principles. This is an important opportunity for people living and working in the district to have a say in how it would look for the next generation of citizens.

Now is the time to speak up about what sort of place residents want Sedgemoor to be in the future. Planning affects so many aspects of our daily lives from where we live, how we travel, what careers we can choose and how we spend our leisure time, that is why taking an active part in its processes is so worthwhile.

The consultation document, initial Sustainability Appraisal Report and other relevant supporting documents can be found online on the Council’s website: www.sedgemoor.gov.uk/ldf or at the Sedgemoor District Council Offices, Bridgwater House, Kings Square, Bridgwater, TA6 3AR Monday to Friday - 9:00am to 5.00pm

For further information, please contact the Planning Policy team as follows:

• Tel: 01278 435544

• Email: [email protected]

Background information

The consultation events will be held as follows:- Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 127

Appendix 3 - Press Release and Public Notice Examples

Burnham-on-Sea

Public consultation – Saturday 31st October 9am-3pm at Food and Drink Festival, Princess Street

Burnham and Highbridge

Town Council consultation – Monday 2nd November 6:30pm at Old Court House

Berrow

Public consultation – Tuesday 3rd November 1-6:15pm at Village Hall

Parish Council consultation – Tuesday 3rd November 6:15pm at Village Hall

Chilton Trinity

Public consultation – Wednesday 4th November 3-7pm at Village Hall

Parish Council consultation - Wednesday 4th November 7:30pm at Village Hall

Bridgwater

Public consultation – Friday 6th November at Angel place (9:30am-2pm)

Nether Stowey

Public consultation – Monday 9th November 1-7pm at Village Hall

Parish Council consultation – Monday 9th November 7pm at Village Hall

Highbridge

Public consultation – Tuesday 10th November 1-8pm at Highbridge Community Hall

Bridgwater

Public consultation – Saturday 14th November at Angel Place (9:30am – 2pm)

Wembdon

Public consultation – Monday 16th November 5-7pm at School hall

Parish Council consultation – Monday 16th November 7pm at School hall

North Petherton

Public consultation – Tuesday 17th November 1-6pm at Community Centre

Town Council consultation – Tuesday 17th November 7pm at Bowling Club

Wedmore

Public consultation – Wednesday 18th November 1-7pm at Council Rooms 128 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 3 - Press Release and Public Notice Examples

Parish Council consultation – Wednesday 18th November 7:30pm Council Rooms

Bridgwater

Town Council consultation – Thursday 19th November 10am at Town Hall

Cannington

Public consultation – Friday 20th November 2-7pm at Village Hall

Parish Council consultation – Friday 20th November 7pm at Village Hall

Cheddar

Public consultation – Tuesday 24th November 1-6pm at St Andrews Church rooms

Parish Council consultation – Tuesday 24th November 6:30pm at Parish Rooms

East Brent and Rooksbridge

Public consultation – Thursday 26th November 2-8pm at Village Hall

Edington

Public consultation – Tuesday 1st December at Village Hall 2:00 p.m. until 8:00 pm.

Westonzoyland

Public consultation – Wednesday 2nd December 2-8pm at Village Hall

Woolavington

Public consultation – Tuesday 8th December 1-7pm at Village Hall

Parish Council consultation – Tuesday 8th December 7pm at Village Hall

Puriton

Public consultation – Thursday 10th December 1-7pm at Church Hall Rooms

Parish Council consultation – Thursday 10th December 7pm at Village Hall

Timetable - Plan Preparation Stage Dates

Participation in plan preparation (this stage) Oct - Dec 2015

Publication and consultation on proposed submission July/August 2016

Document Submission to Secretary of State October 2016

Examination hearings period January 2017

Adoption and publication June 2017 Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 129

Appendix 3 - Press Release and Public Notice Examples

NOTICE OF PUBLIC CONSULTATION SEDGEMOOR LOCAL PLAN - 5 YEAR REVIEW 26TH OCTOBER - 18TH DECEMBER

Sedgemoor District Council is consulting the public on a review of its Local Plan (Core Strategy) which will plan for and manage new development in the District until 2032. The Council wants to hear the views of residents and businesses on what the Local Plan should contain. The documents can be seen at Sedgemoor District Council Offices, Bridgwater House, King Square, Bridgwater, TA6 3AR (Monday to Friday 9:00am to 5.00pm) or online at: www.sedgemoor.gov.uk/ldf

The Council is holding a series of events to present the Local Plan Review and listen to the views of residents. For a list of these events please contact the Planning Policy Team on 01278 435544, [email protected] or check the web address above. Consultation responses can be made using forms from our website or our offices or using the online response system at: http://sedgemoor- consult.limehouse.co.uk/portal/

Public Notice Example - Reg 18 130 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 3 - Press Release and Public Notice Examples

SEDGEMOOR DISTRICT COUNCIL THE TOWN AND COUNTRY PLANNING (LOCAL PLANNING) (ENGLAND) REGULATIONS 2012: NOTICE OF PUBLICATION OF A LOCAL PLAN (REGULATION 19) Sedgemoor District Council is consulting on its Proposed Submission Local Plan for a period of 6 weeks from Monday 31st January 2017 to Friday 17th March 2017. The Local Plan allocates sites for development and detailed development management policies. The document, Sustainability Appraisal Report and other relevant supporting documents are available for inspection at Sedgemoor District Council Offices, Bridgwater House, King Square, Bridgwater, TA6 3AR (Monday to Friday 9am to 5pm) or online at: www.sedgemoor.gov.uk/LocalPlan The Proposed Submission Local Plan can also be inspected at the following public libraries during normal opening hours; Bridgwater, Burnham-on- Sea, Highbridge, North Petherton and Nether Stowey. Comments on the Proposed Submission Local Plan should be made using: Our online response system, available through the following website: http://sedgemoor-consult.limehouse.co.uk/portal/ Using a printed or emailed comments form, available with the documents on our website. Hard copy comments forms are available on request. Completed paper forms should be returned to District Council Offices, at the above address. All responses must be received no later than 5pm on 17th March 2017. Please be aware that all comments we receive will be publicly available and will be included on our website. For further information, please contact the Planning Policy team on 01278 4355544, [email protected] or check the web address above. Date of Notice: 31st January 2017.

Public Notice Example - Reg 19 Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 131

Appendix 4 - Display Board Examples 132 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 4 - Display Board Examples

Local Plan Consultation

Introduction and context

Local Plan options consultation

Consultation on proposed Why is it important? submission document

The Government places Local Plans at the heart of the planning system, addressing future requirements relating to housing, employment, retail and other facilities and infrastructure. Submission of plan to Secretary of State When adopted the Local Plan will: • Set out the vision and objectives for the future of the District. • Contain strategic policies, growth targets and site allocations that will guide planning Examination in public of the applications. Together with adopted Neighbourhood Plans it will be the starting submitted plan point for determining planning applications in the District. • Be a spatial document, deciding what development should take place, where and when it should happen, and how it will be delivered. • Be the basis for addressing key issues, including safeguarding the natural and historic Adoption environment, adapting to climate change and securing good design as part of new development.

Why should you get involved?

This marks the first stage of consultation on the content of the new Local Plan. This is your opportunity to have a say on how we plan new development over the next 20 years, and what sort of place you want the district to be in the future.

Planning affects many aspects of our lives – from where we live and work to how we spend our leisure time. Local communities are well placed to consider the impacts and opportunities around the various development options available.

Some overarching questions include: • Where are the appropriate locations of new development? • What range of infrastructure and facilities are required to support growth? • What unique aspects of the District need to be protected?

Why are we reviewing the plan?

The current plan covers the period from 2006 – 2027. This committed to a five yearly review of the plan to ensure its policies remain up-to- date and we identify sufficient sites to meet our growth requirements. The review will therefore role forward the plan period by another five years, up to 2032.

The review is an opportunity to ensure changes to national policy (called the National Planning Policy Framework) are taken fully into account.

To ensure the plan complies with Government policy, its approach needs to be justified based on evidence. We are therefore updating a wide range of social, environmental and economic evidence to inform the proposed strategy. With the ‘presumption in favour of sustainable development’ the need to maintain an up-to-date plan has never been more important. Lack of an up-to-date plan can lead to the costly process of ‘planning by appeal’ and provide less scope of achieve high quality developments that benefit the District’s local communities.

Tell us what you think...

www.sedgemoor.gov.uk/ldf 01278 435544 [email protected] Planning Policy Team, Sedgemoor District Council, Bridgwater House, King Square, Bridgwater, TA6 3AR Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 133

Appendix 4 - Display Board Examples

Local Plan Consultation

Providing new homes and jobs

How do we identify housing Scenario 1 - Scenario 2 - Scenario 3 - requirements? Based on Based on Low Based on high demographic economic economic projections growth forecast growth forecast Government planning policy requires the Council to identify housing and employment Total new N/A 8,342 9,791 requirements over the period covered by the jobs plan. These requirements must be based on rigorous and objective assessment of Total 10,300 11,690 12,300 population projections and economic housing need forecasts. Total To inform this consultation the Council has housing need 490 557 586 undertaken evidence base work which has per annum modelled a number of scenarios for the 2011- 2032 plan period

How many homes are we building at the moment?

Recent completions have been consistently above minimum target in the existing Core Strategy of 505 dwellings per year. On average since 2006 586 new homes have been completed each year, the same as what would be needed going forward under the high economic growth scenario above.

What number of homes should we plan for?

The Council intend to undertake further more detailed work to before finalising housing targets. From work undertaken so far the Council considers we should look to plan for the high economic growth scenario of around 12,300 new homes from 2011- 2032. Based on what we have delivered in the past this target is considered realistic whilst still being in line with aspirations to boost the supply of both market and affordable housing.

How much employment land do we need to plan for?

It is important to ensure the delivery of housing is aligned with employment to ensure there are opportunities available locally for workers living in the district. The emerging high economic growth forecast identifies that around 9,790 jobs will be created up to 2032. This equates to a need to identify approximately 150 hectares of employment land. While there are a number of key large employment sites expected to come forward (e.g. Huntspill Energy Park), it will be important to identify further sites to meet these forecasts and the needs of a range of employment sectors.

What level of housing and jobs growth do you think we should plan for?

www.sedgemoor.gov.uk/ldf 01278 435544 [email protected] Planning Policy Team, Sedgemoor District Council, Bridgwater House, King Square, Bridgwater, TA6 3AR 134 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 4 - Display Board Examples

Towards a Spatial Strategy

Housing

Jobs Heritage

Retail Design

Infrastructure Landscape

Climate change Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 135

Appendix 5 - Sample of Media Coverage 136 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 5 - Sample of Media Coverage

Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 137

Appendix 5 - Sample of Media Coverage 138 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 5 - Sample of Media Coverage Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 139

Appendix 5 - Sample of Media Coverage 140 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 5 - Sample of Media Coverage Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 141

Appendix 6 - Reg 19 Consultation Supporting Material 142 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 6 - Reg 19 Consultation Supporting Material Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 143

Appendix 6 - Reg 19 Consultation Supporting Material 144 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 6 - Reg 19 Consultation Supporting Material Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 145

Appendix 6 - Reg 19 Consultation Supporting Material 146 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 6 - Reg 19 Consultation Supporting Material Local Plan: Consultation Statement (Reg 22) Sedgemoor District Council 2017 147

Appendix 6 - Reg 19 Consultation Supporting Material 148 Sedgemoor District Council 2017 Local Plan: Consultation Statement (Reg 22)

Appendix 6 - Reg 19 Consultation Supporting Material