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Mendip Hills AONB Partnership Charterhouse Centre, BS40 7XR

t: 01761 462338

e:[email protected] w: www.mendiphillsaonb.org.uk

Planning Policy Council Canards Grave Road BA4 5BT

12 February 2018

Dear Sir/Madam,

Pre-submission draft of the Mendip District Local Plan 2006-2029 Part II: Sites & Policies Draft Supplementary Planning Document for Self and Custom build single-plot exception sites

Thank you for giving the AONB Unit an opportunity to comment on the pre- submission draft of the Mendip District Local Plan Part II and the draft Supplementary Planning Document for Self and Custom build single-plot exception sites.

The pre-submission draft of the Mendip District Local Plan Part II includes proposed allocations for additional sites for housing, employment and community facilities across Mendip. There are additional policies identifying Local Green Spaces, existing Employment Sites and a draft policy to promote self and custom build housing. Mendip District Council is further consulting on a separate Supplementary Planning Document which gives more details on proposed Policy DP24: Single-plot Exception Sites for Self & Custom-Build.

Mendip District Council policy as relates to the Mendip Hills AONB (DP4: Mendip’s Landscapes) sits within the Mendip District Local Plan 2006-2029 Part I: Strategy and Policies which was adopted 15th December 2014.

The Countryside and Rights of Way (CRoW) Act 2000 confirmed the significance of AONBs and Section 85 places a statutory duty on all relevant authorities to have regard to the purpose of conserving and enhancing natural beauty when discharging any function in relation to, or affecting land within and Area of Outstanding Natural Beauty. The National Planning Policy Framework (NPPF) under paragraph 115 sets out that ‘great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.’ Both legislation and national policy inform Plan- making.

The Mendip Hills AONB Management Plan 2014-19 as adopted by the joint local authorities, highlights the special qualities of the Mendip Hills AONB that create the Mendip Hills sense of place and identity and these include views to and from the Mendip Hills AONB, retaining dark skies and a sense of tranquillity. As set out in Natural ’s National Character Area (NCA) profile for the Mendip Hills (141), the area is ‘renowned for its tranquillity and inspirational qualities …’ The NCA further recognises that ‘Light pollution from development threatens the extent of the recognised dark skies and out-of-character development is a continuing risk to the essential nature of the area.’ Within the NCA Statement of Environmental Opportunity under SEO1 it sets out ‘Safeguard inward and outward views and to the distinctive hill line and conserve and enhance the special qualities, tranquillity, sense of remoteness and naturalness of the area’.

Proposed Policy DP24: Single-plot Exception Sites for Self & Custom-Build (page 33) sets out that as an exception to normal policies for the provision of housing in Core Polices 1 and 2, permission may be granted for single affordable self-build and custom build dwellings in locations adjoining rural settlements where they meet criteria including as relates to location, design and scale, future occupation and subject to other considerations. Within the draft policy (DP24) it is unclear as to how Policy DP4: Mendip’s Landscapes within the adopted Mendip District Local Plan 2006-2029 Part I will be considered. Further, proposed Policy DP24 sets out ‘The dwelling size will not normally be permitted to exceed 100 square metre gross internal floor space or occupy a plot of more than 0.1ha’. It is unclear as to how ‘normally’ would be considered within the context of the policy, if exceptions would be permissible and the potential impact on the countryside.

Section11. Primary and Secondary Villages Housing and Employment Allocations of the draft pre-submission draft of the Mendip District Local Plan Part II sets out housing allocation proposals within primary and secondary villages and includes land at Draycott (page 40-42) and Westbury sub-Mendip (page 80-83), both villages which would be considered to be within the ‘setting’ of the Mendip Hills AONB. Under DR1: Land at Westfield Lane, Draycott, we would request that the following text be included ‘Views from and towards the Mendip Hills AONB should be protected particularly when considering the appropriate scale of the development, layout, design (including lighting) and landscaping. The impact of development on the protected landscape and the special qualities of the Mendip Hills AONB would need to be carefully considered and supported by appropriate and acceptable mitigation measures’. Under WM1: Land at Court House Farm, Westbury sub-Mendip we would request that the following text be included ‘There will be the requirement to ensure that the development form and layout respect the sensitivities of the location close to the Mendip Hills AONB’.

We hope that the above comments are helpful.

Yours sincerely,

Cindy Carter AONB Unit Landscape Planning Officer cc Cllr Dawn Hill, AONB Partnership Committee Chair; Natural England, Mendip Hills AONB Parish Representative, The Mendip Society

The Mendip Hills AONB Partnership promotes and coordinates the conservation and enhancement of the Mendip Hills AONB