TAUNTON DEANE CORE STRATEGY – SUBMISSION REPORT

SUMMARY OF RESPONSES TO PUBLICATION (Reg 27) Page 1. Whole Plan 2 2. Proposals Maps 6 3. Vision for Borough 7 4. Strategic Objective 1: Climate Change 11 5. SO2: Economy 13 6. SO3: Town and other Centres 15 7. SO4: Housing 17 8. SO5: Inclusive Communities 18 9. SO6: Accessibility 19 10. SO7: Infrastructure 23 11. SO8: Environment 25 12. Policy CP1 Climate Change 28 13. Policy CP2 Economy 33 14. Policy CP3Town and other Centres 37 15. Policy CP4 Housing 44 16. Policy CP5 Inclusive Communities 51 17. Policy CP6 Transport and Accessibility 60 18. Policy CP7 Infrastructure 64 19. Policy CP8 Environment 68 20. Policy SP1 Sustainable Development Locations 84 21. Policy SP2 Realising the vision for 91 22. Policy SP3 Realising the vision for Wellington 98 23. Policy SP4 Realising the vision for the Rural Areas 102 24. Policy SS1 Monkton Heathfield 107 25. Policy SS2 Priorswood/Nerrols 118 26. Policy SS3 Wellington – Longforth 124 27. Policy SS4 Wellington – Cades/Jurston 126 28. Policy SS5 Wellington – Strategic Employment Site 127 29. Policy SS6 Staplegrove – Broad Location for Growth 128 30. Policy SS7 / – Broad Location for Growth 130 31. Policy SS8 Taunton – Broad Location for Strategic Employment 134 32. Policy DM1 General requirements 137 33. Policy DM2 Development in the Countryside 141 34. Policy DM3 Gypsy and Traveller Site Selection Criteria 146 35. Policy DM4 Design 148 36. Policy DM5 Use of Resources and Sustainable Design 150 37. Representations on Omission Sites 154 38. Infrastructure Delivery Plan 157 39. Sustainability Appraisal 167

CORE STRATEGY SCHEDULE OF CHANGES 173

CORE STRATEGY KEY ISSUES 185

1 Whole Plan

ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED brackets) CHANGE Support Natural (562) Support for the production of a forward looking document None Support noted None which recognises the role of the natural environment in creating successful sustainable communities. There are a number of elements within the Core Strategy which are particularly supported including the extent to which the document embraces the concept of green infrastructure; the inclusion of Accessible Natural Greenspace Standards (ANGSt) and the identification, on the proposals Map, of bat consultation zones. Sustainability County Council As strategic Planning Authority and Transport Planning None Support noted – comment on SA dealt None Appraisal (516) Authority, based on the evidence provided, we do not have with under Sustainability Appraisal; any comments to make on ‘issues of soundness’. There is references to Future Transport Plan made; some concern, however, that the scoring system used to IDP comment dealt with under IDP; Travel assess the development options in the Sustainability Appraisal Planning comment dealt with under CP6. is not explained; while the final scores are not included in the document. References to Somerset Local transport Plan should be Somerset’s Future Transport Plan. There are some inconsistencies between the Core Strategy and the IDP. Too little emphasis on Travel Planning. Support Highways Agency The Council has positively and effectively engaged with the None Support noted None (covering letter) Highways Agency in the process of the preparation of the plan, in relation to both its content and development of the transport evidence base. This has enabled the Highways Agency initial concerns to be largely addressed and I am able broadly to support the plan’s strategy and proposals. Water Environment Agency (295) 1. The Core Strategy does not include any consultation with the None 1. Wessex Water and South West Water 1. None provision water providers to ensure that the proposals are supported were consulted on water supply as well by adequate provisions within the relevant company’s Water as sewage treatment. They did not Resource Plan. identify any strategic problems in terms 2. Include a specific policy for windfall development, particularly of water supply for future development. since the identified housing provision for the plan period has 2. Policy CP8 covers all development on 2. None been demonstrated to be delivered entirely within Flood unallocated Greenfield sites outside of Zone 1. The policy should not support housing within areas settlement boundaries. An additional known to be at a high risk of flooding (i.e. Flood Zone 3). policy for windfall development is not Although Policy CP8 goes some way to clarify TDBCs considered necessary. The Core position on unallocated Greenfield sites, but this may be Strategy only contains high level or better placed in a separate policy for windfall sites. strategic policies. More detailed

2 ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED brackets) CHANGE policies for the management of development will be included in the Site Allocations DPD. Consultation Some of the public exhibitions held regarding Core Strategy None None of the public exhibitions were by None 1. DW Alder Town were invitation only and were considered overly restrictive. The invitation only and were widely publicised Planning Consultants consultation events relating to the various stages of the Core through public notices on notice boards, on Behalf of Strategy have not been suitably advertised. The info has been parish councils, the Council’s newsletter landowner: South of only advertised on Borough Council web-site, and website and the local press. Notices Harris’ Farm, not on the front page but buried in the planning related were not only in the Star, but also in the Hillcommon (117) sections where only those looking for the info would venture. Somerset County Gazette and Wellington 2. DW Alder Town Also, concerns were raised as to the accessibility of the Weekly News, which cover an area wider Planning Consultants information as not everyone has internet access and although than Taunton Deane. After the Reg 25 on Behalf of notices have been put in the Star newspaper, it is only Public Consultation the Council published landowner: distributed to certain areas and is not accessible for everyone. the Summary of Consultation Response in Broadlands (132) Concerns over the fact that the public were not given a chance December 2010. This document included 3. DW Alder Town to comment on the changes made to the Core Strategy since the Council response to the Planning Consultants the last consultation, for example, the exclusion of Killams site. representations. Although there is no on Behalf of The public have not been given opportunity to comment on the requirement to do so, the Council landowner: Cornhill, principles of this or alternative provision that was put in place. published a first draft of the Core Strategy Wellington (210) There is no list of what the evidence base contains and it on its website in February 2011 to enable 4. DW Alder Town cannot therefore be assumed that the content of the DPD is everyone to examine the substance of Planning Consultants justified by evidence, and there is no clear reference to the what was to be formally published for on Behalf of aims of the Sustainable Community Strategy or how these public consultation under Reg 27 in July landowner: have been incorporated into the plan. and August 2011. There is no requirement Highlands, Cotford for an additional stage of public St. Luke (258) consultation between the Reg25 and the 5. DW Alder Town Reg 27 public consultations. Planning Consultants There is a list of the evidence base at on Behalf of Appendix 2 on page 127 of the Core landowner: Foxes Strategy. These documents were Meadow, Wellington published on the Council’s website at the (225) start of the Reg 27 public consultation. The Sustainable Community Strategy is part of the evidence base. Delivery 1. DW Alder Town 1. The plan fails to explain how its key policies will be achieved The draft Core Strategy refers to 1. The IDP only sets out the major None Planning Consultants as the plan states that many of the objectives will be funded allocated sites but it would be more infrastructure requirements for on Behalf of by the CIL. However, this is not due to be brought in for appropriate for these to be in the Site development that will be funded landowner: South of some time and even then it will not cover everything. This is Allocations DPD rather than the Core through CIL. Development will still Harris’ Farm, no suggestion that of how it is intended to cover the shortfall. Strategy. provide the usual on site requirements Hillcommon (130) such as access roads and utility 2. DW Alder Town connections.

3 ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED brackets) CHANGE Planning Consultants 2. The delivery sections of the Core and Spatial Policies do not There are separate policies relating 2. The delivery sections are not intended None on Behalf of provide enough detail on how, when and by whom the to spatial and land use planning to provide detail, but to signpost the landowner: policies will be delivered. More detail would be able to be which should be integrated. delivery and funding mechanisms, Broadlands (145) provided if the policies themselves were more focused. delivery bodies and key delivery dates. 3. DW Alder Town The detail is provided in other Planning Consultants documents such as the IDP, CIL and on Behalf of Urban Extensions SPD. landowner: Cornhill, 3. Although it is considered that the plan goes beyond 3. Not agreed. It is a spatial plan. None Wellington (223) traditional land use planning it maintains distinct separation 4. DW Alder Town between land use and spatial planning by having separate Planning Consultants policies relating to these. on Behalf of 4. The plan is considered to be rigid and inflexible and does 4. Not agreed. The plan is flexible and will None landowner: not take account of circumstances and no information is be subject to regular monitoring and Highlands, Cotford provided about how the Council will act if their policies are review to adapt to change. St. Luke (257) failing. 5. DW Alder Town 5. There is very little reference to the Sustainability Appraisal 5. The SA process has provided a key None Planning Consultants in the Core Strategy. input to the plan making process, but it on Behalf of is not necessary for policies to refer to landowner: Foxes it. Meadow, Wellington 6. Delivery mechanism and timescales for implementation are 6. See response to 2 above. None (238) not detailed enough to be meaningful. Public Rights Open Spaces Society The Core Strategy fails to address poor public rights of way The Core Strategy should address This is not a strategic matter for the None of Way (385) connections into the public rights of way network between poor public rights of way connections Core Strategy. However the Green the south side of the Quantocks/Kingston St. Mary to the into the public rights of way network Infrastructure Strategy did look at northern urban area of Taunton, i.e east side of Staplegrove, between the south side of the green and blue links and identified an Wellspring and west side of Priorswood. People do not Quantocks/Kingston St. Mary to the existing green link from Staplegrove via necessarily want to walk miles along lanes to reach the northern urban area of Taunton, i.e Nailsbourne to and public rights of way network and people also want quick east side of Staplegrove, Wellsprings the Quantocks. access into the countryside, not along narrow lanes. and west side of Priorswood.

Monitoring Barton Willmore on Behalf The Council need to justify specific figures included within the None Noted. None Measures of Comeytrowe Consortium measuring success section to demonstrate they are not only (321,322,323,324,325,326, reasonable with reference to the Regional Strategy and 327) national policy but they are also consistent with other elements of the Plan. Requirement Environment Agency Strategic site allocations contain minor watercourses which are Strategic sites should include a There is already provision within the None for buffer zone (288,289,290,291,292) subject to localised flood risk. requirement for buffer zones so as to strategic site policies for buffer zones. around minor reduce risk of localised flooding. watercourse Lack of English Heritage (208) Lack of specific policy on historic environment. Recent change Suggested policy in Appendix 1 to The place for a detailed policy on the None specific policy to PPS5. letter. historic environment is the Site Allocations

4 ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED brackets) CHANGE on historic DPD, not the Core Strategy. Policy CP8 environment Environment covers both the natural and historic environment. Support Sport England (167,168) Sport England has worked closely with the Borough Council in None Support noted None recent years to ensure a strategic approach is taken to future provision for sport and recreation. Support in the production of Playing Pitch Strategy and Sports Facilities Strategy and welcome their inclusion in the evidence base. Support Bishops Hull Parish Support for the deletion of Bishops Hull from the list of None Support noted None Council (536,537) strategic sites, from both an environmental and visual point of view and also the impact of additional traffic on the local road network, in particular the Wellington New Road/Silk Mills Road roundabout, which requires attention. The Council wishes to be consulted and involved in the masterplanning for the Comeytrowe development, because it will impact on the parish. Support Pegasus Planning Group The Core Strategy is effective and deliverable and clearly sets None Support noted None on behalf of Persimmon out the lead delivery body, delivery mechanisms and key Homes and Redrow delivery dates and is therefore capable of being monitored. Homes (296) The Core Strategy is consistent with national policy in so far as it takes forward national guidance and relevant strategies and policies of the development plan. Disadvantage Paul Partington (384) - The Core Strategy is biased to those who have and use The Core Strategy should address The Core Strategy is not biased towards None for cycle and private motor cars and disadvantages those who wish to be the aspirations of the community and the private car. Indeed the strategy to walking able to communicate by bicycle and walking. support a cycle route to connect focus development in sustainable urban - The Core Strategy fails to make any provision for the to Taunton and to extensions with improved public transport, aspirations for the community for a cycle route to connect Cotford St. Luke and address poor cycle and walking links will encourage Bishops Lydeard to Taunton and to Cotford St. Luke. public rights of way connections into modal shift away from the car. - The Core Strategy fails to address poor public rights of way the public rights of way network The detailed comments on cycle routes connections into the public rights of way network between between the south side of the have been covered under Policy CP6. the south side of the Quantocks/Kingston St. Mary to the Quantocks/Kingston St. Mary to the Walking routes from the urban area to the northern urban area of Taunton, i.e. east side of northern urban area of Taunton, i.e Quantocks are covered in the Green Staplegrove, Wellspring and west side of Prioswood. People east side of Staplegrove, Wellspring Infrastructure Strategy which has informed do not necessarily want to walk miles along lanes to reach and west side of Prioswood. the proposals for the urban extensions the public rights of way network and people also want quick and broad locations for growth. access into the countryside, not along narrow lanes. Support Parish The Parish Council felt that this is an excellent document and None Support noted. It is not viable for the None Council (35) that TDB should benefit from this. We were very pleased to Longforth development to fund a new read that the River Tone forms a Northern boundary for bridge over the mainline railway. Wellington and hope this will prevent any major development within the Parish, however we feel small development should

5 ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED brackets) CHANGE continue with low cost housing in rural areas. Although we would welcome the Longforth development we feel it is essential that it crosses the railway line, should Aerosols and/or Reylon wish to not relocate the consequences could be detrimental to our Parish and Wellington. Support Parish Council (195, The Parish Council agrees with the long term strategic vision None Support noted None 197) for the future of the Borough and how it will develop over the next 15 years or more. The Parish Council welcomes the reduction in housing numbers from that originally proposed in the Regional Spatial Strategy and the previous Core Strategy consultation document and is also in agreement with the Vision for the Rural Areas as outlined in Spatial Policy SP4 - The Parish Council agrees that sustainability issues such as transportation and local services must be a major factor in the planning decision making process. We would also like to point out that the only shop/post office in Oake is likely to close before long.

Proposals Maps ORGANISATION(S) ISSUE (insert comment id in SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE brackets) TEST Bat consultation Zones Natural England (563) Support for the bat consultation zones None Support noted None on the Proposals Map.

6 Spatial Portrait and Vision for the Borough

ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST Spatial Portrait, Vision 1. The Spatial Portrait is too short and does not 1 None 1. In the absence of any comment as 1. None and Objectives 1.DW Alder Town Planning consider the issues relevant to the Borough. to what part of the Spatial Portrait Consultants on Behalf of should be expanded upon or which landowner: South of Harris’ issues are irrelevant or which issues Farm (118,119) have been omitted it is difficult to 2.DW Alder Town Planning respond. Consultants on Behalf of 2. The Vision and Strategic Objectives are not 2. None 2. There are separate Spatial Portraits 2. None landowner: Broadlands (133, place specific and could be applicable to and Visions for the Borough as a 134) anywhere in the country. There is a lack of whole, Taunton, Wellington and the 3.DW Alder Town Planning focus on what and where Taunton Deane Rural Areas. They are place specific Consultants on Behalf of needs to focus growth and development. and do respond to local landowner: Cornhill, Objectives in general are too general to be distinctiveness and growth. The Wellington (211,212) clear. As the plan does not explore the issues objectives relate to issues raised in 4.DW Alder Town Planning presented by the spatial portrait, the objectives the Spatial Portraits and Visions. Consultants on Behalf of do not respond to anything in particular, landowner: Highlands, resulting in them being generalised and not Cotford St. Luke (245,246) specific to meeting the needs of Taunton 5.DW Alder Town Planning Deane. Consultants on Behalf of landowner: Foxes Meadow, Wellington (226,227) Vision third paragraph Natural England (567) Although the Core Strategy is considered sound, Amend third paragraph to read: Agree, amend third paragraph. “Employment led as currently worded the vision might be taken to “Employment led growth … It will growth … It will imply that consideration of climate change by the help enable the Borough to help enable the Borough is contingent upon employment led consider, mitigate and adapt to the Borough to growth. The evidence suggests this is not the possible effects of climate consider, mitigate case (see paragraph 3.6, page 20 change,” and adapt to the possible effects of climate change,” Spatial Portrait and Strategic land Partnerships Support for the Spatial Portrait for the Borough for None Support noted. None Vision (382, 383) recognising the potential benefits associated with growth and the plans proposal to allow a significant quantum of new jobs and housing and associated infrastructure and facilities. General agreement with Spatial Portrait for the Borough stating that proposals will create a major challenge in terms of amelioration of impact on

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST the environment and delivery and yet with a set of robust spatial policies and appropriate development control policies it is considered possible to deliver the Core Strategy vision and objectives. The clarity and relative brevity of the Vision for the Borough is welcomed. Vision recognises growth Pegasus Planning Group on Persimmon Homes and Redrow Homes support None Support noted. None benefits Behalf of Persimmon and the Vision for the Borough as set out in the Spatial Redrow Homes (336) Portrait of the Borough – Section 2.1. The vision is consistent with the Government’s Planning for Growth Agenda as set out by the Chancellor in the Budget in March 2011 which sets out further planning reforms “to ensure that planning supports the sustainable development that is needed as the country emerges from the recession”. (Letter from the Chief Planner dated 31st March 2011). In this context it is noted that the Core Strategy recognises the potential benefits associated with growth (paragraph 2.17). The Plan proposes a significant quantum of new jobs and housing and associated infrastructure and facilities. Spatial Portrait and Quantock Hills AONB (273, 1. Support for the inclusion of a reference to the 1. None 1. Support noted. None Vision 274) Borough’s two AONBs within the initial chapter; setting out clearly the high quality and great variety of Taunton Deane’s landscape. 2. The Vision fails to reflect the Spatial Portrait in 2. The quality and special 2. The Spatial Portrait is descriptive of a sense that it does not reflect the scene- character of the diverse the issues in the Borough, whereas the setting text to highlight the high standard of landscapes in the Borough does Vision is a succinct statement about the landscape and variety of landscape not come across within the future opportunities. It would not be character within the Borough Vision. This should be placed appropriate to repeat descriptive alongside the reference to ‘the material from the Spatial Portrait in the diverse and ecologically rich Vision. landscapes’. Vision Oake Parish Council (197) Strong support for the strategic Vision for the None Support noted. None Borough and how it will develop over the next 15 years or so. Vision - health Miss L Webster on Behalf of NHS Somerset is delighted to see that the Vision None The Vision is deliberately a succinct None NHS Somerset (88) recognises that sustainable development benefits statement. The suggestion that it be in-

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST of health and wellbeing and promotes equity depth with themes would result in a amongst its communities. It is pleasing that the long statement lacking focus. Vision particularly recognises the importance of suitable and affordable housing, access to a range of services/facilities and accessibility via well-connected sustainable modes of travel. All of these are integral to improving the public health and wellbeing of the Taunton Deane community. However, NHS Somerset would like to see a much more comprehensive, in-depth Vision, containing a structured range of themed headings. For example, themes could include ‘health and well being’, ‘living sustainably’, ‘economic prosperity’ etc. Although the Vision recognises health, it is not implicitly mentioned. Both the Vision and Core Strategy document must commit to improving the health of the people by 2028/end of the Plan period as a result of improved housing standards, good access to a range of health care facilities and services, more people enjoying healthier lifestyles through sport, recreation and exercise, maximising the benefits of living within or close to a rural environment. Vision – culture and Mr M Hebditch on Behalf of There is no reference to the major cultural and It will emphasise Taunton's role as The Vision for Taunton has an agreed None sport Taunton Cultural Consortium sport facilities provided in Taunton itself: Museum a sub-regional urban centre, in proposed change to include culture and (46) of Somerset; Somerset Heritage Centre; part defined by urban character. sport in the second bullet point. It is not Brewhouse Theatre and Arts Centre; County considered necessary to repeat this in Cricket Ground etc. These contribute to a high the Vision for the Borough as a whole. quality urban environment, important for development, balancing the general rural character of the Borough. Vision - culture Mr G Ward on Behalf of Para 2: a) This starts by saying that Taunton Explicitly reference cultural The Vision for Taunton has an agreed None Taunton & District Civic Society Deane (TD) looks to secure a better life for its provision in Para 2 and perhaps proposed change to include culture in (59) communities. Hopefully "communities" is official quote examples - 2 theatres, the second bullet point. It is not speak for PEOPLE, and not for organisations - but cinema screens, Museum of considered necessary to repeat this in what a pity it is that improving the quality of life, Somerset (& SHC), Visual Arts the Vision for the Borough as a whole and life chances, for the people of TD is NOT a facilities, concert activity which should be succinct and focused. strategic objective. (Orchestra West, Blackdown The plan should be read as a whole b) If TD is to develop economically it needs to be Music Project), Carnival, local and subsequent policies set out in an attractive place to live, but this strategy Festivals (10 Parishes, Two more detail what is proposed where

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST consistently ignores (or at the least fails to Moors) etc etc. Para 3. Be more and how it will be delivered. explicitly state) the major contribution good specific about what needs to be cultural provision makes to quality of life. For a done (e.g. clearly indicate the proper understanding of the strategy cultural reliance on economic performance provision should not be swept up in the terms improvement) and also the "services, recreational and leisure facilities". It is a mechanisms are that will allow powerful attractor when seeking inward these ambitious aims to be (employment) investment. Currently TD is realised. (Reflect these culturally deprived. Roger Tym's work [which also mechanisms more closely in conflates cultural provision with leisure] shows subsequent policies. How will you that c. 80% of expenditure on 2 aspects, positively seek to diversify Museums/Art and Theatre/Concerts is outside TD. employment, get good design (By the way, the final sentence of para 2 is very etc?) Can you find some way to badly constructed and the meaning is obscure.) get improvement (or al least Para 3: (a)The first sentence: (i) How? (ii) surely maintenance of the current) in the part of the vision will also be to raise the quality of life for ALL the proportion of full-time jobs relative to part-time inhabitants, not just those in jobs? (b) Since increased growth means deprived areas, into the strategic increased demand for services, there is no objectives? assurance that growth will improve the funding available to achieve the improvements in facilities, sustainable transport etc. You mean, we think, that IMPROVING the economic performance will produce the necessary finance. (c) Historically efforts to secure good design have been very ineffective - what mechanisms can you introduce to get better design without getting into a stand-up fight at planning application time? Para 3 currently reads like political hot air. Vision – affordable Tetlow King Planning on The Vision statement makes a reference to The Council should aim to The Plan seeks to meet the need for None housing Behalf of SW Harp (190) access to suitable and affordable housing. The maximise the provision of affordable housing as well as providing need for affordable housing, however, is unlikely affordable housing. the necessary infrastructure for to be met given the level of housing proposed. development whist ensuring that it is viable and deliverable.

10 STRATEGIC OBJECTIVE 1: Climate Change ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST brackets) Monitoring measure Graham Ward on behalf Targets should be a stated None Specific or SMART targets are hard to None of Taunton and District numeric increase or decrease set for this topic as changes to carbon Civic Society (60) that is relatively taxing to emissions will result from many factors achieve. beyond planning control such as the rate of new build (dependent on factors such as the global economy) and when these properties may be built in relation to changes to Building Regulations on carbon emissions. Monitoring measure Graham Ward on behalf The source of each baseline Time periods should be stated, eg Accepted. For consistency, dates Amend Table 2.1 to read: of Taunton and District should be referenced (date?) monthly? Since 2012? etc should be attached to ‘baseline’ targets. Row 2, Target “… from Civic Society (60) Monitoring will continue to seek to 2006 baseline”. report annually where practical although Row 3, Target “… from some indicators are monitored from 2010 baseline”. external sources (e.g. per capita Row 4, Target “ … planning emissions via DECC) and frequency permission from 2012 varies. baseline”. Monitoring measure Graham Ward on behalf Some of these tests are too eg. Is it both a number and The indicator clearly states ‘number’. None of Taunton and District vague percentage of builds that qualify Civic Society (60) out of the total for the year? Monitoring measure Justin Milward on behalf Support the objective but would Include an Indicator of The Plan should be read as a whole. It None of Woodland Trust (14) like to see ‘Native woodland achievement using a trees and is not necessary to repeat a monitoring creation’ included as an woodland target similar to that indicator used in another topic Indicator of Achievement proposed in Strategic Objective 8 (Environment) although clearly many and an increase from 7.62% indicators can be used informally baseline to 50% increase in across a number of topic areas. woodland cover by 2028 in line with the Trusts aspirations Monitoring measure Somerset County Table 2.1, modal share should This is a ‘measurable’ indicator, the None Council (534) be defined or SMART source being the 5 yearly town centre ‘Health Check’ where for consistency, the same question is asked Monitoring measure Somerset County Table 2.1 Modal share baseline Amend 15% non car travel to work Accepted. The 15% figure actually Amend Table 2.1, ‘Modal Council (534) of 15% non car travel to work is to 34.3% relates only to public transport. Share’ criterion b. to read inaccurate. 34.3% Measures to cool Sue Singleton Priory Existing stock measures to None Noted. None temperatures Community Association produce sustainable cooling (11) may be more important in the central area.

11 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST brackets) Directing Strategic Land The statement directing None Noted. None development to Partnerships (370) development to sustainable sustainable locations locations is welcomed as it accords with the presumption in favour of sustainable development set out in the NPPF Measures for listed Mrs D. Bradley (506) Table 2.1 should be amended to None This is beyond the scope of the Core None buildings include a revised protocol for Strategy and more appropriately listed buildings, eg making it covered under the Planning (Listed easier to install double glazing Building and Conservation Area) Act etc. 1990 and PPS5.

12 STRATEGIC OBJECTIVE 2: Economy ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE CHANGE brackets) Support recognition GVA Planning (165) Support the aspiration of None Noted None of Taunton fulfilling enabling Taunton and the its potential Borough to fulfil its true potential. Overreliance on Pegasus Planning (on Support Objective 2 but concern Amend paragraph 2.19. Housing is given significant emphasis and projected needs are None employment led behalf of that if there is too much reliance Delete first sentence met in the Core Strategy. However, it is important that growth strategy Persimmon/Redrow) on an employment led strategy and replace with “The in the Borough is sustainable; to maintain self containment. (337) then the housing development Core Strategy seeks to The level of housing growth is therefore predicated on will not come forward as meet both employment projections of how the economy will grow over the Plan period, needed. and housing needs over with built in ‘adjustments’ for the elderly, household size etc Irrespective of housing the Plan period in associated with employment accordance with the If housing need was based purely on population projections growth there is still a need for national objective of rather than economic growth for example, housing numbers housing for elderly/retired and securing economic would likely be lower. If based on demand, it could be reduction in household size. The growth as set out in oversupplied in the Borough and Taunton could become a Core Strategy should therefore ‘Planning for Growth’ commuter town for Bristol or Exeter. meet economic and housing produced by the needs. Government in March 2011. Failure to provide a Don Alder (Reyglow Some of the strategic sites, None There is no contradiction or conflict. A strategic employment None strategic and, Haunch, such as the urban extensions, site has been identified at Firepool in the Taunton Town employment site Hillcommon, South conflict with the Plan Objectives. Centre AAP. The main areas of growth will not be in traditional Western Property, For example, the Plan seeks to ‘industrial estate’ type activities and thus a need for a second Highlands, Charles provide jobs yet fail to identify a ‘strategic’ employment site has not yet been established. French) (215),(121), strategic employment site. However, a large site at the Monkton Heathfield urban (230),(249), (137) extension has been identified to assist in meeting the Class B employment needs of Taunton. Nuclear power Graham Ward (Taunton The Strategy ignores what is None Taunton Deane is working in liaison with EDF and None station at Hinkley and District Civic happening nearby, e.g. Hinkley neighbouring authorities regarding jobs and development Society) (61) Power Station. There should be legacies if the scheme is implemented. However, most of the some reference to cooperation local jobs likely to be created are projected to come from the with other local authorities and local Sedgemoor/ rather than Taunton area. the local LEP. The Plan has been prepared in liaison with other neighbouring authorities and the (local) LEP is recognised as an important delivery partner (paragraph 3.37) Too much reliance Graham Ward (Taunton There is too heavy a reliance on None The figures in the Plan are evidenced based and derived from None on retail economy for and District Civic retail and lack of a commissioned Retail Capacity Study (Roger Tym 2010). growth Society) (61) acknowledgement on the impact There is no evidence that these figures are incorrect. The retail of internet shopping figure is not purely shop floor workers but include associated

13 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE CHANGE brackets) distribution etc and the internet shopping figure of 14% is comparable with the national picture. Retail capacity figures are reviewed every 5 years and thus if requiring change at the next study date (2015) will feed into the proposed Plan review in 2016. Welcome objective Strategic Land Welcome the clarity of this None Noted. None of sustainable Partnership (371) objective. Inclusion of land pattern of within urban extensions and development Wellington should in time lead to a more sustainable pattern of development Definition of self Graham Ward (Taunton It is overplaying self None An overall aim of the Plan is to increase self containment; None containment and District Civic containment to regard providing local opportunities for housing and employment. Society) (61) Wellington and Taunton as Such an approach assists in mitigating the impact of climate separate areas. change by reducing the need to commute for work.

Taunton and Wellington are around 9 km apart (centre to centre). Treating them as a single entity could mask significant traffic movement and hence CO2 emissions between these two towns, underplaying one of the Plans Strategic Objectives of addressing the causes and impacts of climate change. Too much emphasis PCL Planning (150) Concern that the Objective for None To base a Core Strategy on peoples ‘desire’ to live in Taunton None on self containment the Economy will result in failure Deane would be hard to objectively assess and would certainly to look appropriately at inward not be sustainable. The aim of balancing economic and migration pressures. It is too housing growth to maintain or enhance self containment is inward looking, focussing on self sustainable; preventing Taunton becoming a dormitory town, containment. reducing commuting and CO2 emissions and protecting the surrounding environment from needless urban sprawl. Culture D. Bradley (513) There is no mention of tourism None SO2 is a ‘Strategic Objective’, referencing broad Plan aims None or the cultural offer which such as self containment, not sector specific topics. provides the unique sense of place. Monitoring measure Graham Ward (Taunton Table 2.2 a) should specify if None As specified in Table 2.2, the identified target seeks to None and District Civic jobs are full time or full time measure ‘new job creation’ as the relevant measure of Society) (61) equivalent. economic success. The Economy evidence base (Roger Tym 2010) projects 11,900 new jobs over the Plan period. It is not possible, nor in this instance relevant to say whether or not these are or will be full, part time (or FTE which would count as one job).

14 STRATEGIC OBJECTIVE 3: Town and Other Centres ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) Support measures Strategic Land The general proposal to make None Noted None to promote town Partnerships (372) Taunton town centre and other centres centres as attractive and successful as possible is welcomed. Hierarchy of Gwilym Wren The identification of a hierarchy of There needs to be The Plan identifies a settlement and town None centres (Milverton Parish centres, including , recognition that centre hierarchy for the appropriate scale Council) (53) may have implications for development in the of growth of housing and ‘town centre Milverton as may the development defined centres will uses’. Milverton is at the lower end of the of northwest Wellington from a inevitably increase traffic hierarchy (minor rural centre) with very transport perspective. and villages on main limited residential growth proposed. It is local routes such as also on a public transport route to Milverton will suffer. Taunton, Wellington and Wiveliscombe (higher order settlements and centres). It is therefore extremely unlikely that residential and retail growth focussed in these higher order centres (and thus assisting localised self containment) would significantly increase traffic in Milverton. Support Monkton Pegasus Planning (on Support Strategic Objective 3 as it None Noted None Heathfield being in behalf of Persimmon / relates to Monkton Heathfield the centre Redrow) (335) hierarchy Office proposals Strategic Land In the light of the draft NPPF the None The NPPF is currently only in draft and it None and town centres Partnerships (372) Council need to consider whether would be premature to revise aspects of offices should be located in town the Core Strategy to reflect areas of a centres or whether new business draft document which may or may not parks such as Blackbrook, should change in its final form. However, even if a be replicated elsewhere in the sequential requirement for offices is Borough. removed from the final NPPF it would not necessarily preclude ‘provision for an appropriate scale of office development’ within centres, as currently stated in Strategic Objective 3. Cultural and Max Hebditch (on The cultural and leisure Amend paragraph 2.20 Accepted. For some town centre activities Amend paragraph 2.20 to read: leisure behalf of Taunton opportunities serve a much wider to read: “Regeneration the influence of Taunton spreads further “Regeneration of Taunton town catchments Cultural Consortium) area than the sub-region through of Taunton town centre than the sub-region. centre (through the Area Action Plan) (47) tourism, eg Somerset cricket. (through the Area Action will retain and enhance its role and Plan) will retain and focus for employment growth, enhance its role and shopping, leisure, nationally

15 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) focus for employment significant cultural and sport activity growth, shopping, within the sub-region, which extends leisure, nationally over western Somerset and into significant cultural and eastern Devon, and in the south-west sport activity within the generally. Wellington town centre will sub-region, which …” extends over western Somerset and into eastern Devon, and in the south-west generally”. Omission of Graham Ward Omission of ‘cultural’ and ‘sporting’ Include reference to Accepted. PPS4 does refer to ‘culture’ as Amend Objective 3 to read: cultural and (Taunton and District activities within the town centre cultural and sporting a main town centre use. The draft NPPF “… appropriate scale for retail, sporting reference Civic Society) (62) wording. activities in the does not refer to ‘cultural’ activity in leisure, cultural, sporting, office and Objective. promoting town centres although the other town centre activities …” Council considers that generally, such activities are most appropriate within a town centre as they may be major travel generators. Taunton town centre is also ‘home’ to County cricket. Omission of D. Bradley (512) The objective fails to reference The Core Strategy Agreed. Inclusion of cultural references Amend Objective 3 to read: reference to culture. should recognise the are suggested elsewhere (see Graham “… appropriate scale for retail, culture importance of culture. Ward 62, Max Hebditch 47,) leisure, cultural, sporting, office and other town centre activities …”

Amend paragraph 2.20 to read: “Regeneration of Taunton town centre (through the Area Action Plan) will retain and enhance its role and focus for employment growth, shopping, leisure, nationally significant cultural and sport activity within the sub-region, which extends over western Somerset and into eastern Devon, and in the south-west generally.

16 STRATEGIC OBJECTIVE 4: Housing

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id in TEST CHANGE brackets) Validity of Borough- 1. Baker Asscs on • Support the overall principle of • Supporting text should make reference to See responses to Core Policy 4 a) and b). This high None wide housing Behalf of Barratt the strategic objective. housing numbers in-line with RSS level strategic objective need not refer explicitly to a targets / use of Homes (340) However, it is not considered Proposed Changes (or at least Fordhams five year deliverable supply of housing land since it phasing 2. Pegasus Planning that supporting text is justified or 18,500 figure). already refers to the provision of a sufficient supply. Group on Behalf of consistent with Govt policy Persimmon Homes including the NPPF and PPS3. • Supporting text and table should make no and Redrow Homes reference to the phasing of housing (338) requirements. 3. APP on Behalf of Gadd Properties Ltd • Include reference in objective to (80) maintaining a five year deliverable supply 4. APP on Behalf of of housing land. David Wilson Homes (73) 5. PCL Planning on Behalf of the Shapland Trust (334) Mix of housing Milverton Parish Council • Policy fails to recognise explicitly • SO4/Policy should assert that housing Policy CP4 as worded in the Published Plan states: None required (39) the types of housing required need in rural communities is different from “New housing should help to contribute towards the particularly in rural areas where the larger centres and should therefore creation of sustainable, mixed communities offering the need is primarily for smaller aim to deliver: high quality homes providing for a mix of new housing houses which cater for young types, sizes and tenures which meet the needs of the families. 1) affordable housing Borough.” It is not considered necessary to explicitly 2) 2-3 bed houses within the reach of low- refer to the types of housing likely to be required in middle income rural workers rural areas. This level of detail may be more 3) a smaller proportion of executive homes appropriately reserved for a Neighbourhood Plan or background to a strategic allocation. Appropriate target Taunton & District Civic • Generally support objective but • Specify higher thresholds in terms of Support noted, but there is no basis for higher None for Building for Life Society Planning Group suggest BfL target of 85% of ‘liveability’ of each individual dwelling, as thresholds standards (63) assessments very good. At well as requiring good general least 95% of developments performance under BfL criteria (in-line with should achieve a perfect score comments). for design and construction criteria. Too much recent housing is of good technical quality but nearly unfit for habitation.

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id in TEST CHANGE brackets) Lack of reference Tetlow King on Behalf • Given the scale of growth from • Include reference in strategic objective 4 This high level strategic objective need not refer None to ageing of South West HARP households over the age of 65, to: ‘Increasing the delivery of care and explicitly to the needs of older people since it already population in (192) the Core Strategy should accommodation for older people.’ refers to meeting the needs of all sections of the relation to housing community. objective Support for o Strategic Land • Support for objective including • None None Strategic Objective Partnerships (373) affordable housing target. o Greenslade Taylor Hunt on Behalf of Comeytrowe Landowners (418) o Greenslade Taylor Hunt on Behalf of Mr C Wilkins (423) o Greenslade Taylor Hunt on Behalf of Mr G Cossey (425) o Greenslade Taylor Hunt on Behalf of Mr J Read (434) o Greenslade Taylor Hunt on Behalf of Mrs J Penny (432) o Barton Willmore on • Insufficient evidence to support None specified. The affordable housing target has been arrived at None. Behalf of The assertion that 25% affordable following an Affordable Housing Viability Study, an Comeytrowe housing can be delivered without initial Viability Assessment as part of the Infrastructure Consortium (313) inhibiting delivery of essential Delivery Plan and work undertaken as part of the o Barton Willmore on infrastructure. Strategic Masterplanning Commission. All three Behalf of DeVirgo studies conclude that a 25% target is likely to be Ltd (415) broadly deliverable, taking into account likely infrastructure requirements.

STRATEGIC OBJECTIVE 5: Inclusive Communities

No response

18 STRATEGIC OBJECTIVE 6: Accessibility

ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in CHANGE brackets) SUMMARY OF REP SOUNDNESS TEST Public transport target Taunton & District Civic Regarding 2.26, it is unlikely that a target of None Given that development patterns are effectively None Society (64) 50% of all trips by public transport will be permanent once created, it is essential that these achieved as public transport is likely to enable a larger proportion of trips to be undertaken diminish. without using a car. The locations that have been identified for major development in the Core Strategy – along main radial routes – are not those at risk of reductions in public transport services. Indeed they can benefit from existing services without a need for public subsidy. There is no reason to think that a considerably higher proportion of journey could not be made by walking, cycling and public transport, particularly in Taunton and Wellington: public transport use in Taunton is low even by UK standards and there is potential to substantially increase cycle use given that both Taunton and Wellington are relatively flat. The argument is circular: urban forms that make it inconvenient to walk, cycle or use public transport depress the use of these modes. Historically little regard was given to the impact of development patterns on travel choices: this now has to change.

The strategy would be sounder if it accepted Reduce 15% car free It is not physically possible for 80% of people to None that a car is a necessity for 80% of residential development travel to work by car – this would in fact be higher economically active people and that, since to 5%. than the current level of car use for the journey to many households have 2 or more work, and contrary to policies which aim to achieve a economically active people, nearly every gradual modal shift. household will require at least one car. Parking standards will be informed by good practice guidance such as the HCA’s ‘What Works Where’. Given that household car ownership is well below 85%, and that nearly 15% of new housing will be in Taunton town centre where many journeys can be made without using a car, a target of 15% car free housing is not unrealistic.

In Table 2.5 the 30 minutes public transport Reduce public transport Public transport is not really relevant for travel to and None target for access to primary schools seems target time to 15 minutes from primary schools, certainly for pupils in urban much too long. for 85% of new areas who would be expected to walk or cycle to

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ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in CHANGE brackets) SUMMARY OF REP SOUNDNESS TEST residential development. school. There is still a need for access to schools by staff and for the location of schools should therefore take account of public transport availability. It needs to be borne in mind that the public transport travel times including walking and waiting times: thus a 30 minute time is likely to involve no more than 15 minutes on the vehicle. Insert additional cycle Agreed in principle, although further consideration is Add reference to walking and and pedestrian targets needed as to what the percentage figures should be. cycling target times to primary for journey times to schools in Table 2.5 primary schools: 80% of new residential development to be within 10 minutes for cyclists (chiefly via non-road cycle paths) and 70% of new residential development to be within 15 minutes for walkers on pedestrian footways. Travel times Milverton Parish The achievement of the targets is more None The Core Strategy needs to set criteria which new None Council (40) likely to be dependent on external factors development should meet; otherwise it will be (fuel costs, increasing congestion) rather impossible to assess whether development is likely than being delivered by policy itself. to help achieve or hinder the objectives.

Placing residential development within 30 None Agreed – walking and cycling times are more Add reference to walking and minutes by public transport of a surgery or relevant. cycling target times to primary school will not fulfil much travel demand. schools in Table 2.5

The Core Strategy should provide evidence None While this is a reasonable suggestion, the data is not None of how much development is currently within available for existing developments. Ultimately it is given travel times of facilities so that the more important that new development is required to degree of aspiration can be measured and meet appropriate standards. the potential to achieve them can be assessed.

The Core Strategy needs to recognise the None Although its significance is recognised, this is not an An additional sentence could be risk that certain groups of the community issue that can be addressed through the planning added to 2.29 acknowledging the are going to be progressively deprived of system. Planning has no control over whether issue: ‘It needs to be recognised, access to services as travel costs increase services are provided close to the consumer or in however, that the planning

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ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in CHANGE brackets) SUMMARY OF REP SOUNDNESS TEST and public transport provision shrinks. centralised locations. Its influence is limited to system can not address the Support therefore needs to be given to the locating development close to existing services or policies of service providers that provision of services as close to the point of transport provision, or on a scale that can support have led to centralisation of consumption as possible. This means new facilities commercially, and avoiding the facilities in larger centres and making the rural settlements better location of development where service provision is reduction in rural transport connected and serviced by hubs where absent. provision.’ providers can provide a local outreach service to those in need.

Strategic road network Highways Agency (328) Paragraph 2.27 requires clarification in that None As recognised by the former Commission for Rewrite paragraph 2.27 to read: the Strategic Road Network is provided to Integrated Transport, it is also important that the ‘Development in the Borough accommodate long distance journeys and location of development encourages a modal switch needs to be planned in a way that unnecessary use of the M5 relates to for longer journeys (particularly to rail services) since which minimises use of the M5 short distance/local journeys. longer journeys account for a large proportion of for short-distance commuting carbon emissions from transport. The Tyndall and other journeys, particularly Centre has estimated that over 80% arise from where this involves ‘junction journeys over 5 miles long. hopping’. At the same time, Location of trip-generating development near railway there is also a need to stations, such as at Firepool in Taunton, is likely to encourage modal shift for longer- simultaneously address the HA’s concerns about distance journeys, since these junction hopping and local journeys. account for the majority of carbon emissions from transport.’ Support Strategic Land The clarity and brevity of SO6 is welcomed, None Support noted None Partnerships (374) especially as it ties in well with the NPPF.

Support Somerset County It would be helpful to It has been demonstrated – for example, in the Amend final sentence of Council (533) clarify that the modelling Bridgwater, Taunton and Wellington Future paragraph 2.26 to read ‘…in of Monkton Heathfield did Transport Strategy - that managing demand for Taunton – which has looked at not suggest that 50% of travel is the most effective way of achieving the the impact of growth across the trips should be by non- objectives referred to in 2.26. In other words, the town as a whole - suggests that, car modes, but that the use of non-car modes needs to be maximised. The to reflect best practice ‘eco studies were conceived figure of 50% has been taken as an exemplar standards’, at least 50%...’ to try and meet this derived from the eco-towns PPS. In fact, the PPS objective following advice suggests that in eco-developments, in the longer in the eco-standards term the non-car share could be planned to rise to PPS. 60%.

In Table 2.5, 400m is a In urban design terms it is important that the location None short distance for rail – a of new development gives greatest weight to ’higher

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ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in CHANGE brackets) SUMMARY OF REP SOUNDNESS TEST more generally accepted order’, rather than local, public transport facilities, of maximum walking which the railway station is the key one in Taunton. distance is 800m. As a medium-sized county town, average journey times are relatively short, and a walking distance of 800m (10+ minutes) at the destination end of a rail journey therefore seems excessively long. In addition, the TTCAAP allocates sufficient land to meet the requirement for new offices at Firepool, all of which is within 400m of Taunton station. A larger radius than 400m could therefore result in an unnecessary dispersal of development away from sub-regional public transport facilities, and away from the main site already identified for office development. With regard to the modes ‘Best practice’ should apply everywhere, not just in Paragraph 2.26 does not refer to of travel to the urban one urban extension. Traffic modelling has been any specific urban extensions; extensions, it should be based on the collective impact of all the urban however the wording could be clarified whether this extensions and the effects across the road network amended to refer to the growth applies to all urban in Taunton as a whole. of Taunton as a whole. extensions or just that at Monkton Heathfield? The reference to cycle At present the Taunton cycle network does not None schemes detailed in the appear to be defined in any adopted policy TTCAAP is welcomed document, so policies in the Core Strategy cannot but for a plan extending really be derived from it. to 2028 ambitions for longer-term schemes should also be included – for example, the Taunton cycle network detailed in the Cycling Strategy Appendix to the Future Transport Plan.

22 STRATEGIC OBJECTIVE 7: Infrastructure

ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id CHANGE CHANGE in brackets) SUMMARY OF REP SOUNDNESS TEST

CIL will not fund all DW Alder Town Taunton Deane seek to provide the necessary None SO7 states that ‘development provides the on- and off-site None infrastructure Planning Consultants on- and off-site infrastructure but the levy infrastructure that is necessary…’ (123, 139, 217, 232, suggested is not sufficient to fund all the The Core Strategy does not suggest that CIL would need to fund 251) infrastructure required. all the infrastructure that is required. Also, the Council is not required by the CIL regulations to set the amount of levy on this basis, but only to have regard to viability.

Delivery of off site APP Planning Ltd on Delivery of infrastructure will be in two ways, The Objective would be It is agreed that in some cases, development will be contributing Amend SO7 to infrastructure Behalf of David either directly by development or by means of clearer if it was worded to the cost of infrastructure rather than providing it directly. In read ‘To ensure Wilson Homes (74) pooled contributions collected through CIL. As ‘To ensure that other cases, development will have to provide it directly. that development APP Planning Ltd on written, SO7 only refers to delivery by development contributes provides or Behalf of Gadd development, which in some cases will not to the provision of on- contributes to the Properties (81) deliver off-site infrastructure. and off-site on- and off-site infrastructure… infrastructure… Limit contributions to Barton Willmore LLP As drafted, the policy wording and its Contributions to The scale of development proposed in Taunton requires None on site infrastructure on behalf of the supporting text place potentially unreasonable infrastructure from the significant investment in off-site infrastructure that is not linked Comeytrowe and unviable expectations on developers with Comeytrowe directly to individual development sites. Contributions from Consortium (308) an approach that would be inconsistent with development should be development cannot therefore be limited to facilities within its own national policy. limited to a series of on- site. It is a prime purpose of CIL that the levy can be used to site measures listed fund off-site infrastructure in combination with other sites that under a new policy would not be permissible under a S106 agreement. SO7 is not SS7A: Comeytrowe. therefore in conflict with national policy. There is also precedent for local authorities requiring contributions from development to a broad range of physical, social and environmental infrastructure. Support Baker Associates on Support the objective of delivering on- and off- None Noted. The Council will consult with the development industry None behalf of Barratt plc site infrastructure partly through developments when preparing its CIL charging schedule. (339) themselves and partly through contributions to pooled resources. The Council is urged to communicate regularly with the development industry in regard to the viability of development so that CIL can be set at a level that is appropriate for Taunton. Support Strategic Land CIL may not be the most effective way of None The Council has taken the decision to adopt CIL partly so that all None Partnerships (375) delivering appropriate and cost-effective developments contribute towards infrastructure costs, and partly infrastructure. A non-CIL approach would allow to secure funding for infrastructure projects on a pooled basis individual viability to be considered for every which without use of CIL will not be possible from 2014. project. For the least viable developments, CIL Experience suggests that it is impractical to secure contributions will result in pressure to reduce the level of via S106 from very small developments. The Government is also

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ISSUE ORGANISATION(S) RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id CHANGE CHANGE in brackets) SUMMARY OF REP SOUNDNESS TEST affordable housing. consulting on the case for delivering affordable housing via CIL. Omitted requirements D Bradley (511) SO7 makes no reference to local cultural None SO7 is not intended to identify specific infrastructure None facilities or churches, or to the need to requirements. These are contained in the IDP. Land for food conserve local land for food production. The production is not ‘infrastructure’ and is therefore not within the Priorswood Country Park is not large and scope of SO7. extensive enough to serve its purpose. It is not accepted that the Priorswood Country Park is too small. Support Somerset County Paragraphs 2.32 and 2.33 refer to or imply the None These requirements have been in place for many years (for None Council (532) pooling of contributions from developers. example, re-stated in Circular 05/2005) but they have not There are conditions stipulated in the CIL prevented local authorities from pooling contributions. regulations that any planning obligations during the transitional period must comply with the ‘necessity test’, i.e. that they are: Necessary to make the development acceptable in planning term Directly related to the development Fairly and reasonably related in scale and kind to the development Support RPS on Behalf of the Support SO7 and CP7 – the Police as a social None Support noted. The Police will be invited to participate in the None Avon and Somerset infrastructure provider are pleased to be formation of the CIL. Constabulary (569) included in the IDP and have made separate representations on this document The Constabulary use the ACPO toolkit as a way of securing developer contributions and would welcome the opportunity to be involved in the production of CIL.

24 Strategic Objective 8: Environment

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id CHANGE in brackets) SUMMARY OF REP SOUNDNESS TEST SO8 lack of Quantock Hills 1. Concern that there is a lack of emphasis on 1. Add the following text: “To maintain 1. and 2. Policy CP8 and paragraph 3.98 defines the 1. and 2. In SO8 emphasis on AONB (272) landscape in SO8. and enhance biodiversity, the varied natural environment to include wildlife sites of and Para 2.34 landscape and character and high quality of the international, national and local importance; geological replace “natural strengthen 2. Concern that using the term ‘Natural and landscape, the natural and man- sites; protected wildlife species; protected trees, and man-made Indicators man-made heritage’ is confusing. made heritage, minimising the need woodlands, orchards and hedgerows; Areas of heritage” with to travel, waste, pollution and the Outstanding Natural Beauty; landscape character “environment” use of non-renewable resources areas and green wedges. The wording in SO8 and and to promote good design and para 2.34 should be consistent with it, replacing materials which respect and “heritage” with “environment”. enhance local distinctiveness.” 3. The indicators used to measure SO8 could 3. Add the following indicators to Table 3. It is important that indicators are precise and 3. None be strengthened. 2.7: measurable: • “Number of planning applications • The suggested amendment is less precise than that granted contrary to the advice of the proposed Environment Agency advice on • Planning reports include all consultation responses flood defence or water quality and the planning decision must balance a range of grounds, where issues cannot be economic, social and environmental considerations. It overcome would be inequitable only to monitor environmental • Number of planning applications advice and would be burdensome to also monitor granted contrary to the advice of the compliance with economic and social advice. landscape, heritage, and • No target is proposed – how would you measure biodiversity officers and specialist changes in the character and condition of all consultees and contrary to policies landscapes. in statutory documents e.g. AONB Management Plans. • Ongoing process of monitoring changes the character and condition of all Taunton Deane landscapes. Support SO8 Strategic land Policy SO8 is welcomed as it is consistent with None Support noted. None Partnerships (376) NPPF in having proper regard to the natural environment. Paragraph 2.34 Mr G Wren on The man-made heritage of Milverton has been The objective should include a The commitment to maintain and enhance covers None Behalf of Milverton classed as an “Outstanding Heritage reference to the irreplaceable nature of avoiding damage. It is not agreed that development rarely Parish Council (68) Settlement”. It is exceptional with 85 listed the built and natural environment and a provides opportunities to enhance and contribute to the buildings in the parish. It is vital that any commitment to avoid damage. The quality of the environment. Paragraph 3.98 defines the development within the Parish should not Lawton Report advocates widening historic environment to include Conservation Areas; diminish that sense of “special place.” The biodiversity across areas. Designated Listed Buildings; parks and gardens of special historic

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id CHANGE in brackets) SUMMARY OF REP SOUNDNESS TEST 2.34 statement that 'Development provides sites SACs, SSSIs and local nature interest; archaeological sites of national and county opportunities to enhance and contribute to the reserves provide much of the importance and areas of high archaeological potential. quality of the environment' is rarely true as biodiversity 'capital' which will fuel this The six SSSI sites in the Borough are monitored in the developments by their nature change the expansion, so the condition of all these fourth Indicator; and SAC and protected species in the status quo. This Objective refers to the sites is important. Therefore the third Indicator and the proposed targets refer to condition condition of European Conservation sites. condition of and extent SSSIs, local and population of protected species. By their nature it is However, national ones, SSSIs like Langford nature reserves and BAP habitats difficult to monitor local nature reserves by their condition. Heathfield are not mentioned and local Nature should be included under success BAP species are referred to in Policy CP8 Environment. Reserves are only referred to by provision not measures. condition. There is no reference to BAP species or habitats or how the Deane contributes to the delivery of national targets. Table 2.7 first Mr J Milward on Support the use of woodland coverage as an Woodland coverage in the Borough The Council supports this ambitious aspiration, but Increase in line Indicator Target Behalf of Indicator, but the Target should be more Target amended to a 50% increase monitoring targets should be SMART – specific, with Somerset QWoodland Trust ambitious. As the Somerset Woodland rate in native woodland to 2028. measurable, achievable, realistic and timely. A 50% Woodland Strategy (15) Strategy 2010 calls for the 7% county cover to increase rate is not considered achievable or realistic, but 2010 from current increase to 8% cover, reflecting a 14.2% rate it is agreed to amend the first Indicator target coverage coverage of 7.62% of increase, we consider the Core Strategy figure for the Borough be increased to 8.7% to 8.7% target should adhere to this % rate of increase, which would produce an overall coverage figure for the Borough of 8.7%. The UK is one of the least wooded areas of Europe, with just 11.8% cover compared to around 44% for Europe as a whole. The Woodland Trust has an ambitious target of doubling native woodland cover by 2050. We would like to see the Council commit to a more ambitious Target of achieving a 50% increase in native woodland cover by 2028 in the Borough (in order to achieve the Trust’s aspiration of a doubling of native woodland cover by 2050). Monitoring sixth Environment The target for monitoring SO8 is not consistent To reflect how the ecological quality is The EA provide monitoring information to us on the % of Indicator: % of Indicator and Agency (287) with the way in which ecological quality is now now measured and monitored under the waterbodies achieving good ecological status. Amend waterbodies river target measured under the Water Framework Water Framework Directive – “Number sixth indicator and target. length of achieving Directive, which came into UK law in 2003 of waterbodies at Good Ecological good ecological Status (or above) – target: increase status (or above) from 2009 baseline data.” biological quality Target: Increase from 2009 2008

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id CHANGE in brackets) SUMMARY OF REP SOUNDNESS TEST baseline data High grade Mrs D Bradley (510) SO8 fails to mention or recognise grade A land None High grade agricultural land is included since it is the key None agricultural land to north of Taunton or potential conflict with “non-renewable resource”. National policy protects and Hestercome SSSI and bats. grades 1, 2 and 3a land, otherwise referred to as “the Hestercombe best and most versatile land”. The Hestercombe House bats SAC for lesser horseshoe bats is included under “biodiversity and the natural heritage” and is referred to in the fourth Indicator. There is no known potential conflict between agricultural land and bats.

27 POLICY CP1: Climate Change ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment SOUNDNESS TEST ID in brackets) Support Sarah Hamilton- Support the strategy which None Noted None Foyn, Pegasus seeks to direct development to Planning on behalf the most sustainable locations of and thus improving accessibility Persimmon/Redrow and reducing the need to travel, (341) which will assist climate change Support Strategic Land The detail of policy CP1 is None Noted None Partnerships (377) eminently sensible and welcomed, although repeating national policy. Support GVA (162) Support policy CP1, in particular Noted. None locating development in highly accessible locations and reducing the need to travel. Extend the Miss Louise Policy welcomed but could be None The scope of Planning to improve the existing None scope of CP1 Webster NHS extended to address issues housing stock are limited, although policy DM5 Somerset (89) such as improvements to seeks to do this through home extensions and the existing housing stock, carbon management fund may also allow this. encouraging sustainable The Plan does promote sustainable transport transport modes, behavioural modes (eg cycling), c/f policy CP6 ‘Accessibility’, change and energy demand and where able, seeks to manage energy management demand, (eg development patterns to reduce the need to travel in policy CP1 and carbon reduction in mew developments in policy DM5). Further Miss Louise The Plan should state how None TDBC commitment to the Nottingham Declaration None explanatory Webster NHS TDBC are adhering to the includes preparation of Strategies and Plans such text required Somerset (89) Nottingham declaration, what as those referred to in paragraph 3.6. These have will the associated documents associated rolling Action Plans which can change cover and when will they be year-on-year. The Core Strategy seeks to be complete? concise, avoiding unnecessary detail and thus it is not considered appropriate to set out yearly specific ‘actions’ from these documents in the Core Strategy. These documents and their status are available to the public via TDBC website. Strengthen Mr Gwilym Wren, Criterion h. is too nebulous and There need to be clear PPS22 (page 7) notes that LDD’s should contain None policy Milverton Parish worthless. Any developer will criteria to assess policies designed to encourage, rather than wording Council (41) point to the contribution their development – how important restrict renewable energy sources subject to proposal makes to the national is the proposal to the national appropriate environmental safeguards. The interest and thus override any picture? Will it make local Council does not consider that the current local impact on people or communities carbon neutral? wording is too orientated towards the national

28 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment SOUNDNESS TEST ID in brackets) environment. They should be measured interest. A balanced approach is undertaken. The against quality of life, not policy should be seen as a whole, not as impact, should not ‘pollute’ independent criteria. There will be instances through noise, traffic and where local community and environmental whether they provide a reasons outweigh wider interests and these are defined local environmental set out in CP1 (eg noise, scale, traffic generation, improvement. cumulative impact) consistent with PPS22. These Impact should be measured are objective criteria (see PPS22, para 19). on local biodiversity and ‘Impact’ is also a recognised term and easier to populations, not national address rather than ‘quality of life’ which is more ones. subjective (eg quality for life for whom? Some local residents suffering fuel poverty may regard local renewable energy as improving their quality of life whilst other, more affluent residents may regard this as less important than having their view altered through a proposed ‘renewable energy’ wind turbine). Strengthen Mr Gwilym Wren, Criterion i. (removal of facilities) Include ‘viable’ at end of If a facility is no longer ‘viable’ due to lack of None policy Milverton Parish is too loose and offers little or criterion i. as installations subsidy for example and does not therefore wording Council (41) no control, Requirement for its could be unused through lack generate energy it would no longer be removal is essential of subsidy being offered but ‘operational’. The proposed wording seems remain operational and the unnecessary Council couldn’t require their removal. Strengthen Mr Justin Milward, Any policy on climate change Propose criterion j., to state The Council accepts that tree planting helps None policy Woodland Trust should recognise the key role of “planting more trees and mitigate and adapt to climate change. However, wording (16) trees and native woodland in woods benefit health, tree and woodland planting can occur without the mitigating and adapting to flooding, renewable energy need for planning permission and thus falls climate change. and carbon sequestration” beyond the scope of this policy. Paragraphs 3.12 and 3.14 already refer to the benefits of tree planting within development proposals, relating back to policy CP1 criterion. A separate policy criterion is not therefore required.

Amend Sue Singleton, Solar opportunities on older None It is not considered likely that the design of such None supporting Priory Community housing stock should not be tall buildings could be accommodated within older text Association (12) prevented by allowing tall new established residential areas without adversely buildings that overshadow them. affecting the character of the area. This is not therefore thought to be a critical issue for the Core Strategy

29 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment SOUNDNESS TEST ID in brackets) Supporting Mr Gordon Ansell, It is wrong to say that climate Less emphasis on CO2 The Plan seeks a balanced approach through None text Cotford St. Luke (8) change is not irreversible. It is emissions and more thought mitigation and adaptation. However, as the Plan clarification irreversible as a result of natural on planning ways to live deals with new development proposals mitigation processes, whether global through global temperature is more relevant, although where appropriate warming or a long overdue ice- changes of at least +/- 5 adaptation is sought, (eg orientation of buildings, age. Emphasis must mainly degrees C. heat island reduction landscaping and measures therefore be on adaptation to reduce flooding) rather than prevention. Amend Blackdown Hills Paragraph 3.16 The lack of Landscape and landscape Criterion g of policy CP1 already refers to Amend paragraph 3.16 to read: supporting AONB (180) reference to landscape and designations should be landscape appearance and impact. Landscape “All renewable energy proposals text landscape designations is a referred to alongside ecology designations would fall under this criterion. including wind farm developments serious omission and not and wildlife Reference to landscape and landscape should be sensitively located to consistent with national policy designations can be cross referenced to avoid any significant harm to the supporting text without materially affecting the landscape, including the qualities Plan. for which any national designated landscapes have been recognised, and equally to avoid harming the ecology of the Borough and to offset potential impact on wildlife. Any development …” Amend Quantock Hills Whilst landscape is referenced There should be a clear Agree. See proposed amendment under See above amendment supporting AONB (271) in policy there is no supporting reference to AONB Blackdown Hills 180 (above) text text justification in paragraph landscape (and their setting) 3.16, thus biasing towards being particularly sensitive to wildlife. large scale, commercial renewable energy schemes. Amend Blackdown Hills Paragraph 3.17. English Nature Amend ref to English Nature Agree. Amend paragraph 3.17: Replace supporting AONB (180) does not exist. ‘English Nature’ with Natural text England. Amend Quantock Hills Whilst landscape impact is The term ‘appearance’ should Agree. Amend policy CP1 g. to read: supporting AONB (271) considered in policy, the term be replaced with ‘character’ “Their scale, form, design, text ‘appearance’ is less understood materials and cumulative impacts than the term ‘landscape can be satisfactorily assimilated character’ which is used in into the landscape or built national policy. environment and would not harm the appearance character of these areas and has no overriding impact on the amenity of the area in respect of noise, dust, odour and traffic generation”

30 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment SOUNDNESS TEST ID in brackets) Change to GVA (162) Breeam standards should be a None BREEAM is a recognised national standard None policy target, not benchmark, allowing against which to assess commercial new build. wording each proposal to be considered Paragraph 150 of the draft NPPF requires local on its merits. planning authorities to adopt nationally described standards. Change to GVA (162) Criterion e. measures to Revise criterion e. to take Government policy recognises the importance of None policy minimise and mitigate climate account of and reflect viability addressing climate change, minimising wording change should be revised to as a result of economic vulnerability and providing resilience. Such take account of viability circumstances at the time of measures set out in criterion e. should be resulting from economic submission. regarded as ‘standard’, to ensure a commercial circumstances at the time. investment is ‘future-proofed against climate change (eg extreme weather events) and addresses the consequences arising from its development (eg appropriate landscaping to address the ‘heat island’ effect) to ensure that the development remains fit-for-purpose. Further Tetlow King Unclear what is meant by Reducing the need to travel Core Strategies aim to be concise and avoid None explanatory Planning (189) ‘reducing the need to travel through locational decisions repeating national policy. Planning policy text required through locational decisions’. needs to be reworded or statements (e.g. PPS1, PPS4, PPS13) all seek to This should be justified in the properly explained in the create sustainable patterns of growth (e.g. ‘town supporting text. supporting text. centre first’, mixed use developments, addressing the causes and impacts of climate change) to reduce the need to travel. It is not necessary to explain this ‘concept’ further in the Core Strategy. Change to Tetlow King Meeting the code for Meeting the government’s Policy DM5 does follow the current national None policy Planning (189) sustainable homes should timetable for various Code timetable for carbon reduction through Building wording follow the national timetable. levels should be included as Regs. However, within larger urban extensions it Building regs are the most an informative guide only. does seek earlier implementation of the relevant appropriate forum. The Council CfSH standard “where viable”. This is consistent should not duplicate with Government policy; for example paragraphs unnecessary information. 149 and 150 of the draft NPPF encourages local planning authorities to “adopt proactive strategies … (within) nationally described standards” Strengthen Environment TDBC should encourage Criterion b. reword to See above (response to Tetlow King, 189) None policy Agency (286) developers to meet the highest “Specifying the highest level comment. The Council has commissioned an wording attainable levels of CfSH and of CfSH or in the case of evidence base (ARUP study) which raises viability BREEAM rather than prescribed BREEAM that can be viably issues if requiring higher /earlier implementation national targets. attained within the of national standards. The policy does not development through site however prevent higher standards being met if specific assessment” sought by a developer or viable.

31 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment SOUNDNESS TEST ID in brackets) Amend D. Bradley (508) Paragraph 3.14 should include None Paragraph 3.14 does include reference to tree None supporting reference to tree planting. planting text Amend Somerset County Paragraph 3.17 should also Agree Amend paragraph 3.17 to read: supporting Council (531) refer to SCC as the Transport “Lead Delivery Body: Taunton text Authority, an essential partner in Deane Borough Council as Local combating climate change. Planning Authority and Somerset County Council as Transport Authority and Waste Planning Authority in cooperation with partners including …”

32 POLICY CP2: Economy ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment ID in TEST CHANGE brackets) Strategy should not Pegasus Planning (on As stated in Strategic Objective 2, Amend paragraph 3.21 with It is correct that the Plan seeks to meet both None be simply behalf of Redrow / concern that the overall strategy is an additional final sentence to employment and housing needs. This is already clear employment led. Persimmon) (342) employment led. It is important to the read: from Objective 2 (Economy) and Objective 4 (Housing). overall delivery of the Core Strategy “… those who do not. The However, it is not a ‘housing led’ strategy. Rather, the to support housing and employment Core Strategy seeks to meet Core Strategy is ‘employment led’. Housing and other growth. both employment and requirements are predicated on an evidence based housing needs of the assessment of economic growth. Borough over the Plan period in accordance with the If it was ‘housing led’ there would be a danger that national objective of securing growth would not be sustainable; there could be an economic growth as set out in oversupply of housing in relation to employment ‘Planning for Growth’ growth, potentially resulting in declining self produced by the Government containment with unsustainable travel patterns to larger in March 2011” urban centres such as Bristol and Exeter for work. Concern with Graham Ward It is hard to see how the aim of Suggest as an alternative that Whilst it is accurate to say that an aim of the Economic None identified growth (Taunton and District rebalancing the local economy away TDBC “will not be seeking Development Strategy is to rebalance the economy sectors Civic Society Planning from the public sector can be jobs from public sector away from a public sector emphasis, it would not Group) (90) achieved if the key growth areas are relocations” necessarily be accurate to state that education and education and health health will remain public sector orientated; private care homes for a nationally ageing population being a recent example. Likewise, table 3.1 also indicates significant growth in other areas including retail and office based activities. It would not however be appropriate to state that the Council would not be seeking any public sector relocations if appropriate opportunities arose during the life of the Plan. No sites identified for Graham Ward Lack of past vision has left many The Strategy should earmark The Council fully consulted on future requirements None expansion of (Taunton and District sites unable to expand on-site sites that may satisfy from sectors such as health and education. No Hospital and 6th form Civic Society Planning without a hideously jumbled and expansion or re-location additional need was identified. It would be colleges Group) (90) unprepossessing outcome (eg needs for these critical inappropriate and could make the Plan unsound if Musgrove Hospital, Somerset economic powerhouses. provision were made for uses that were not required College). and for which no means for or interest in delivery was advanced. Future design of new buildings will be covered in other policies to seek to provide a ‘cohesive’ site outcome. Support resistance to Louise Webster (NHS Support the recognition of the need None Support noted None non sustainable Somerset) (91) for sustainable growth, making travel patterns particular reference to the avoidance of unsustainable travel patterns.

33 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment ID in TEST CHANGE brackets) Support for GVA Planning (166) Support the provision of around None Support noted None floorspace 49,000 sq.m. of additional Class B1a requirements office space and around 93,150 sq.m. of additional retail floorspace in Taunton.

Loss of employment Tetlow King (188) The paragraph relating to the loss of None These matters remain ‘proposals’ at the current time None land and PD existing or identified employment and would only apply if no external works were changes land needs to be carefully considered required. An element of control is therefore still in the light of Government proposals appropriate and would remain so in the future if the to remove the need to apply for proposals become policy; for example providing a planning permission when changing degree of control over a residential proposal that may from employment to housing use. otherwise affect the ongoing operational requirements of adjoining business operations.

Lack of recognition Simon Prescott (on As part of the suggested allocation of Policy SS7A Comeytrowe Such a change would be premature. Comeytrowe is None for opportunities at behalf of Barton 2,000 dwellings at Comeytrowe, should read: unlikely to commence before 2016 and policy SS7 Comeytrowe Willmore) (314) there should be consequential “A new mixed use district indicates up to 2,000 dwellings by 2028. It would be changes to the employment and town centre comprising up to 3,000 extremely unlikely that this extent of commercial centre sections of the Plan to provide sq.m. (gross) food store, up provision would be viable ‘upfront’ of the development. at Comeytrowe: to 3,000 sq.m. (gross or other • Up to 3,000 sq.m. convenience and comparison It would be more appropriate to await the outcome of foodstore retail (A1), financial and the masterplanning of Comeytrowe by the development • Up to 3,000 sq.m. of other professional services (A2), consortium which would require a thorough evidence A class uses restaurants and café’s (A3), base, including employment and retail requirements. • 5 hectares off employment drinking establishments (A4) This would dovetail into and inform a proposed Core land and hot food takeaways (A5), Strategy review around 2016. up to 1,000 sq.m. offices (B1) which could be on upper floors of buildings and multi- functional community facilities including a community hall, health facilities and sheltered housing provision; 5 hectares of additional employment land for B1 use (office, research and development, light industry), B2 use (general industrial) and B8 (storage and distribution).

34 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment ID in TEST CHANGE brackets) Lack of recognition Simon Prescott (on See comment above Amend Table 3.1 to reflect See above comment None for opportunities at behalf of Barton provision at Comeytrowe Comeytrowe Willmore) (314) referred to above. Definition of Taunton Pegasus Planning (on Support for policy CP2 but would be None This is not necessary. As noted, policy SP1 makes None urban area behalf of Redrow / useful if the definition of the Taunton clear what constitutes the Taunton urban area. This Persimmon) (342) urban area as set out on page 51 includes Monkton Heathfield (ie the Core Strategy could be included in policy CP2. This allocation). would be consistent with spatial policy SP1 and strategic site policy SS1 (Monkton Heathfield) Support reference to Pegasus Planning (on Support the reference to Monkton None Support noted None potential strategic behalf of Redrow / Heathfield being included in the area employment site at Persimmon) (342) of search for the delivery of an Monkton Heathfield additional strategic, non office based employment site with good links to the trunk route network. Tourism D. Bradley (507) Paragraph 3.24 makes no mention of None Tourism does play an important role in the local None tourism. Taunton is an ideal base for economy and this is recognised in Paragraph 6.19 and short breaks. policy DM2 of the Core Strategy. However, it was not specifically seen as a major growth area in the Roger Tym employment study. Query demand and D. Bradley (507) Question the statement in paragraph None The representation does not specify any reasoning None supply reference 3.27 “Borough wide employment behind this statement. However, the evidence base (eg would appear to be sufficient to meet Roger Tym study, annual employment monitor etc) projected demand” suggests that across the Deane demand and supply is well balanced. Paragraphs 3.28 and 3.29 however recognise that on a more localised basis there are deficiences in the Taunton urban area in particular and the Plan seeks to address this through allocations and protection of existing employment areas in particular. The Plan will be reviewed in 2016 and appropriate changes made at that time if required.

Reference to future Somerset County The Core Strategy is considered Noted. None strategic Council (530) sound. The County Council employment site. welcomes paragraph 3.28 which notes that Walford Cross will only come forward as part of a future Core Strategy review, due to severe infrastructure problems.

35 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment ID in TEST CHANGE brackets) Requirement for Strategic Land Support the hectarage targets for The Council needs to Figures in policy CP2 are derived from the Core None regular monitoring Partnerships (378) individual uses but it is inevitable that continually monitor both the Strategy evidence base. Figures in Table 3.1 are over the Plan period job types and provision and take-up of land estimated targets for the employment uses identified in numbers will change. The Council for the various uses identified policy CP2. Appendix 2 (Evidence base) identifies a must monitor the provision and take- and CP2 amended to allow range of documents that do annually monitor provision up of land for the various uses and for such changes. and take-up of employment activity on an annual basis CP2 amended to allow for such to enable Development Plans to respond to change. changes. The Core Strategy will be reviewed in 2016 and appropriate changes made at that time if required.

36 POLICY CP3: Town and Other Centres ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) Impact on Gwilym Wren It does not seem that None Wiveliscombe will extend beyond the current None Milverton on behalf of Wiveliscombe is destined for settlement limits but growth will be limited and Milverton greater development than what is consequences of this on Milverton would be Parish Council feasible within the village’s negligible, if any. However, this matter is not (54) boundaries so the impact on particularly relevant for policy CP3 which covers Milverton may be mitigated. the settlement hierarchy for town and other centres, not residential growth. Impact on Gwilym Wren Through this policy it would be If there is no scope for increased This policy (CP3) defines the hierarchy of centres None Milverton on behalf of very difficult for Milverton to employment in a village then the and activities within such centres. It is not Milverton sustain any significant requirement to accept housing particularly relevant for general employment Parish Council ‘employment’ development and should be scaled back in the relevant purposes (other than office use; see policy CP2) (54) that there is little scope for policies. nor Milverton itself, other than it would fall under sustainable housing expansion. the ‘rural centre’ category. Milverton must not take up overflow populations derived from unsustainable growth within the hierarchical settlements More retail WYG on Policy CP3 is not in accordance The Core Strategy should make it There is no conflict. Objective 2 (Economy) seeks None flexibility Behalf of with Strategic Objective 2 which clear that any application for new to ensure sufficient land in appropriate locations required Sainsburys seeks to provide the right retail development should be (an objective of Government policy). Policy CP3 (198) conditions and sufficient land in considered on its own merits against identifies a hierarchy of centres and ‘town centre’ appropriate locations to retain the the normal policy tests of the type use floorspace requirements over the Plan Boroughs high levels of self sequential approach and impact. period (again, an objective of Government policy). containment by ensuring an Any application for new retail development would adequate quality of main food still be ‘considered on its merits’ but a Plan led shopping provision across the system predicated on a robust evidence base Borough. remains central to Government policy and thus proposals would be rightly assessed against policies in the LDF, which are in turn consistent with national policy. Retail impact WYG on PPS4 and the draft NPPF set a A threshold of 2,500 sq.m. gross PPS4 advises that local impact thresholds can be None threshold Behalf of threshold of 2,500 sq.m. gross should be adopted for an impact applied where considered expedient. The Sainsburys floorspace for retail impact assessment. reasoning behind the 500 sq.m. threshold is set (198) assessments. Why does the out in the Roger Tym (2010) study, paragraphs Council consider it necessary to 9.67-9.83. This was informed by a range of set a 500 sq.m. gross convenience factors including existing floorspace and unit sizes floorspace threshold? in town and out of centres, recent applications and future development and the general strategy approach in the adopted town centre AAP

37 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) Rural centres Blackdown The supporting text is focussed on Part a.iv referring to loss of services Part a.iv is considered clear. The wording clearly None Hills AONB the urban areas and fails to in rural areas should specify whether states that it applies to new, or proposals to lose (178) provide any explanation for rural this relates to all rural settlements or services “within the defined settlement limits” considerations. Part a.iv of the just those within defined settlement policy dealing with loss of services limits classified elsewhere in the in rural areas is not clear enough. Plan, with the former being the favoured approach. Support for Pegasus Support for policy CP3 and note None Support noted None centre Planning (on that the proposed district centre at activities in behalf of Monkton Heathfield will support new Monkton Persimmon / the sustainability of the urban Heathfield Redrow) (343) extension and increase self district centre containment. Support for Strategic Land Welcome the policy which seeks to None Support noted None promoting Partnerships improve the town centre and other centres (379) town and village centres which are important to their local communities. More retail GVA on The policy lacks flexibility in There should be a range of retail The policy is indeed directly linked to the TCAAP None flexibility Behalf of St Taunton town centre to respond to units which could be delivered within as the LDF is a suite of integrated development required for Modwen occupier requirements and the town centre and this should documents. The Core Strategy is a strategic, not Firepool. (163) changes in economic include Firepool. detailed document. The Town Centre AAP circumstances. The policy is Inspector considered it appropriate to impose directly linked to the TCAAP, restrictions to retail proposals outside of the High imposing restrictions on unit sizes, Street (including Firepool) until 2016. The Core restricting occupier interest to the Strategy would not be the appropriate mechanism detriment of Firepool. to change this policy requirement. (see also Montague Evans response) Retail GVA on Concern with part b) of the policy There should be a more balanced The quantum of retail floorspace requirements for None provision at Behalf of St over the scale of provision for delivery of convenience goods. With Taunton and Monkton Heathfield have been Monkton Modwen (163) Monkton Heathfield in contrast to Firepool close to the railway station established through the 2010 (Roger Tym) Retail Heathfield Taunton town centre which is and benefitting from a range of public Capacity Study. and Firepool recognised as the ‘first preference’ transport and walking links this Convenience floorspace requirements are for town centre uses. It should be presents a suitable location for considered ‘balanced’. Taunton town centre more balanced. convenience retail provision. already has a range of convenience retail stores of varying size, (over 16,000 sq.m. gross foodstores within AAP area). A further site is allocated at Firepool in the TCAAP (4,000 sq.m.). Monkton Heathfield is an urban extension of around 5,000 new homes (plus c1500 existing). It

38 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) would not be ‘sustainable’ for such a settlement to have no convenience floorspace in the locality. Town centre Montague There is ambiguity relating to what None The level, detail and quantity of changes None definition Evans on sites fall within the definition of the requested go far beyond that required for a Core Behalf of EPF town centre for the purposes of Strategy which sets the strategic framework for (202) PPS4 (eg our clients High Street the Borough. Moreover, these issues are largely site) and the wider definition of the and clearly addressed in the adopted Taunton town centre which will include sites town centre AAP which, together with the Core which under that guidance should Strategy, form part of an integrated LDF. be treated as edge or out of centre The PPS4 ‘Good Practice Guide’ recommends a (eg Firepool site) proactive approach to bringing forward new development, including the scope to “expand existing centres” to accommodate town centre needs, not just retail (paragraph 4.9,4.12, 6.13 and the Case Study on page 29). This is precisely the approach taken in the Core Strategy, identifying the quantum of floorspace required over the Plan period to 2028 and recognising that Taunton town centre will need to expand to accommodate this. Further, paragraph 4.13 of the GPG suggests that it may be appropriate to “phase new development and identify priorities”. Again, this is precisely what has been done through the adopted Taunton town centre AAP which ‘protects’ the High Street from competing retail development proposals by requiring a sequential approach on alternative proposals prior to 2016. Such an approach is therefore entirely consistent with Government guidance in order to allow the town centre to expand to meet future needs without requiring adhoc, less sustainable locations. PPS4 Annex B defines the town centre boundary as including the primary shopping area and areas of predominantly leisure, business and other main town centre uses. The Proposals Map does indeed extend the town centre into part of Firepool (which also adjoins the Primary Shopping Area) as it will provide a range of “main town centre uses” including a strategic employment

39 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) site, hotel, leisure and opportunities for town centre retail expansion. This site is allocated in the AAP and the first phase is underway but will take a number of years to bring forward. This does not undermine or remove protection of High Street under TCAAP policy Hs1 for retail priority. The primary shopping area is defined in the Plan and PPS4 defines ‘edge of centre’ without the need for repetition in the Core Strategy. High Street for example is defined within the primary shopping area, Firepool is not. The LDF should be read as a whole and the town centre boundary recognised as not simply a retail designation. Sequential protection of High Street remains until 2016. Over the course of the Plan period to 2028 sites such as Firepool and Coal Orchard will be required for accommodating projected town centre retail requirements. The defined town centre boundary is therefore appropriate. Priority given Montague Nothing stated Page 10 Strategic Objective 3, Not required. See comment above. The town None to town Evans on suggest the following amended centre boundary is not simply a retail designation. centre sites Behalf of wording to read: It covers other activities such as business and EPF(202) “To enhance the role and function of leisure for example. These are not focussed on Taunton town centre in the regional High Street. Priority is already being given to hierarchy through the priority that will office development at Firepool for example. be given to the promotion to town centre sites first, then other regeneration opportunities …” Priority given Montague Nothing stated Page 10 Paragraph 2.20, additional Not required. See comment above. None to town Evans on sentence after “… eastern Devon” to centre sites Behalf of read “Priority shall be given to EPF(202) regeneration of sites in the town centre first” Application of Montague There needs to be a clear None PPS4 defines what constitutes town and edge of None sequential Evans on statement of how the sequential centre. It is not necessary to repeat Government approach Behalf of approach is applied in Taunton. policy in the Plan. As stated above, and EPF(202) For example paragraph 3.50 refers consistent with Government policy, until 2016 the to town centre units within the TCAAP policy Hs1 specifies that primary and secondary frontages. ‘priority/sequentiality’ will be applied to High Street This is a more appropriate proposals. However, over the Plan period the

40 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) definition than the reference to town centre will need to expand to accommodate “town centre” in the context of requirements. Sites such as Firepool will therefore regeneration sites, many of which be classed as town rather than edge of centre are appropriately defined as edge sites in terms of retail sequentiality. or out of centre. Definition of Montague The ‘Town Centre Boundary’ on None See above comments. The Core Strategy covers None town centre Evans on the ‘Taunton Town Centre Map’ is the period to 2028 and thus includes sites that will boundary Behalf of EPF a much wider definition which is be required to accommodate certain town centre (202) not in the PPS4 definition and uses and requirements after 2016 (sequential should be clarified. This includes retail protection). The boundary is appropriate as sites falling outside of the town drawn and is not only for retail development. centre and are less sequentially Without such a defined boundary to cover future preferable. This was identified by requirements for town centre uses there would be the TCAAP inspector confusion and opportunistic proposals for town centre uses in less sustainable locations and which would undermine the Plans strategy. Definition of Montague Request clarification that only the Additional sentence proposed in See above comments. This is not the case. The None town centre Evans on High Street sites fall within the paragraph 3.48 to read: town centre boundary has been established to Behalf of EPF town centre for the purposes of “ …together with primary and enable the centre to expand to accommodate (202) PPS4 and that other sites should secondary frontages which should be projected requirements over the Plan period. This be identified as edge or out of treated as the town centre for the does not however undermine the sequential centre purposes of this guidance. The Inset preference for retail development on the High map for Taunton identifies other sites Street site up to 2016, as set out in policy Hs1 of which fall outside this area which are the AAP. less preferable locations for retail development according to the sequential approach. Until the adoption of the …” Sequential Montague Page 31 paragraph 3.49 There are Amend paragraph 3.49 to read: “ …. See above comments. However, inclusion of this Amend paragraph 3.49 to assessment Evans on more sequentially preferable sites. Adequate land has been made sentence would not be in conflict with the read: Behalf of EPF The TCAAP Inspector stated that available within town centres as well Councils position on the ‘town centre first’ (commencing line 6) (202) sites such as Firepool, Coal as edge of centre sites in Taunton principle “…compounded by the fact Orchard, Morrisons and Tangier town centre as identified on the Inset that adequate land has been are out or edge of centre sites. Map to more than meet projected made available within town demand” centres as well as edge of centre sites in Taunton town centre as identified on the Inset Map to more than meet projected demand”. The Plan has therefore …

41 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) Sequential Montague Page 55 Policy SP2 . The second Amend Policy SP2, second bullet to See above comments. However, inclusion of this Amend policy SP2 (second assessment Evans (on bullet is inconsistent with the read: sentence would not be in conflict with the bullet) to read: “Focus Behalf of sequential approach in PPS4. “Focus shopping, leisure and other Councils position on the ‘town centre first’ shopping, leisure and other EPF)(202) employment growth towards town principle as the town centre boundary does employment growth towards centre and then other identified exclude certain AAP allocations such as Tangier. town centre and then other regeneration opportunities outside of identified regeneration the town centre delivered through the opportunities outside of the adopted Town Centre Area Action town centre delivered through Plan”. the adopted Town Centre Area Action Plan”. No reference Mrs D. Paragraph 3.41 fails to mention Paragraph 3.41 should include Accepted. Amend paragraph 3.41 to to culture Bradley (505) culture. culture. read: “… Taunton town centre is the major driver for economic growth within the Borough, providing the retail, leisure, cultural, sporting and office focus for a catchment population of over 350,000” No reference Rose The document is not consistent. Objective 3: Insert the word ‘cultural’ Accepted. PPS4 does refer to ‘culture’ as a main Amend Objective 3 to read: to culture Freeman on Objective 3 and policy SP2 do not to read “retail, leisure, cultural, office town centre use. The draft NPPF does not refer to “… appropriate scale for behalf of the refer to cultural activities (eg and other town centre activities” ‘cultural’ activity in promoting town centres retail, leisure, cultural, Theatres Trust museums, libraries, theatres and although the Council considers that generally, sporting, office and other town (350) art galleries). However, Vision 2 Policy SP2: Insert the word ‘cultural’ such activities are most appropriate within a town centre activities …” (page 54) and justification for to read “focus shopping, leisure and centre as they may be major travel generators. Amend Policy SP2 bullet 2 to policy SP2 (para 4.25) does. cultural development and other read: “Focus shopping, employment growth …” leisure and cultural development and other employment growth towards …” No reference Rose Table 2.3 (page 11) should Whilst accepted in principle the Council does not Amend Table 2.3 row 2 to to culture Freeman on monitor cultural provision. have any evidence of future need and thus it is include “Completed cultural behalf of the difficult to set ‘targets’. However, monitoring of floorspace” Theatres Trust completed cultural floorspace would assist overall Amend Table 2.3 row 3 to (350) monitoring of town centre vitality. include “Completed cultural floorspace” No reference Rose There is no definition of cultural The Glossary does not provide a definition of None to culture Freeman on facilities in the glossary to leisure, recreational or cultural facilities. The behalf of the compare with leisure or definition in PPS4 is considered sufficient. Theatres Trust recreational activities. (350)

42 ISSUE RESPONDEE SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert SOUNDNESS TEST comment ID in brackets) Changes to Montague Page 10 Table 2.3 ‘Measuring Reference should be made to: See comment above. None monitoring Evans on Success’ 1. completed town centre definition Behalf of Reference to 93,150 sq.m. gross floorspace falling outside the EPF(202) retail floorspace should be clarified town centre but within sites as it refers to the “amount of within the wider urban area of completed town and district centre Taunton and; floorspace …”. Many of the sites 2. A sequential approach shall be Of the ‘allocated’ sites in the AAP only fall outside of the town centre applied to the delivery of this Tangier/Tesco and part of Firepool would not be boundary for the purposes of total floorspace need reflecting within the identified town centre boundary for the PPS4 some identified sites are not Plan period to 2028. However, they fall within this within the town centre for the category as they are ‘TCAAP allocations’, not purposes of PPS4 adhoc, out of centre proposals. Changes to Montague Page 27 Table 3.1 requires None See comments above. However, for clarification it Amend Table 3.1, Retail, monitoring Evans on clarification that not all of the would be appropriate in this instance to insert ‘and Broad location to read: definition Behalf of 93,150 sq.m. of retail floorspace other allocations in the TCAAP’ “* Taunton town centre and EPF(202) will be accommodated in Taunton other allocations in the town centre because some TCAAP identified sites fall outside of the * Wellington …” town centre boundary for retail purposes Monitoring Strategic Land The Council will need to monitor None Noted. The Council already monitors changes to None Partnerships take up and demand over the Plan retail, leisure, employment provision etc through a (379) period and adjust requirements range of annual monitoring reports (and also the accordingly. AMR)

43 POLICY CP4: Housing

ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Validity of 6. Baker Asscs on Behalf of • Housing figures are not • Consider that in-light-of Against RSS Proposed Changes reqm of 21,800, None Borough-wide Barratt Homes (112) justified on the basis that detailed technical comments only 2,280 completions have taken place in first five housing targets 7. DPDS on Behalf of Notaro RSS evidence base should on Fordhams methodology a years. This means that average annual delivery rate New Homes (111) be taken into account in figure of at least 18,500 would have to exceed 1,300 (1,301) per annum to 8. Hoddell Associates on arriving at housing figures. dwellings should be set out meet Proposed Changes. Behalf of Comeytrowe (146) (32) (75) (82) (112) (Baker Asscs.) (Gadd Landowners (32) (111) (414) Properties Ltd) (David Wilson Para 4.6.19 of Panel Report acknowledges that 9. APP on Behalf of Gadd Homes) whilst the Borough has achieved build rates of 800 Properties Ltd (82) • Question methodology used dwellings per annum in the past, it cannot be 10. APP on Behalf of David by Fordhams particularly in • Housing requirements should expected that rate can be significantly exceeded Wilson Homes (75) regards to use of locally reflect those set out in the consistently over a 20 year period at Taunton itself. 11. Tetlow King on Behalf of derived migration Proposed Changes RSS Therefore, there are legitimate concerns about the South West HARP (148) information and assumptions evidence base (Notaro New deliverability of higher growth targets for the 12. IJP Planning on Behalf of about in-commuting. (75) Homes) (Gadd Properties Borough. In his conclusions on the Bristol Core Redrow Homes at (82) (112) Ltd) (David Wilson Homes) Strategy, that Inspector was minded to accept that Wellington (146) (Redrow Homes at the Proposed Changes figures for the City were 13. DW Alder Town Planning • Jobs requirement should be Wellington) (DW Alder on undeliverable and consequently accepted a Consultants on Behalf of 12,200 not 11,900 therefore Behalf of several landowners) minimum housing target of 26,400 dwellings (nearly landowner: South of Harris’ Fordhams have effectively 10,000 lower than the figures outlined in the Farm (129) ignored half a year’s housing • The CS should look to Proposed Changes to the RSS). requirement. (112) provide a level of housing 14. DW Alder Town Planning around 20,500 dwellings There is no realistic prospect of the RSS Proposed Consultants on Behalf of • Reductions in neighbouring which would better reflect Changes being adopted into the formal development landowner: Broadlands authorities housing figures RSS evidence base and plan. The letter of the DCLG Chief Planner makes (136) exacerbate undersupply NPPF (Comeytrowe clear that the evidence base supporting RSS is still across sub-region. (148) Landowners). valid. However, in the case of the RSS Proposed 15. DW Alder Town Planning Changes, some 35,000 representations were made Consultants on Behalf of • Policy is not consistent with • In order to be consistent with to its consultation and the validity upon which the landowner: Cornhill, NPPF requirement for 20% ‘The Plan for Growth’ Council uplift in housing numbers was based as never been Wellington (214) overage in five year should adopt highest formally rebutted by DCLG (nor is it likely to be). deliverable supply. (75) (82) employment led target for 16. DW Alder Town Planning (32) housing: 15,500 jobs. This The Fordhams LBHP is based upon a locally derived Consultants on Behalf of should include planning for approach drawing upon over 2,000 household landowner: Highlands, • Assumptions made higher levels of affordable surveys undertaken as part of the Council’s SHMA. Cotford St. Luke (248) regarding housing numbers housing (South West HARP) It is contended that by running the latest ONS 17. DW Alder Town Planning do not build on a robust projections and replacing local employment Consultants on Behalf of migration elements with primary data derived from

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST landowner: Foxes Meadow, assessment of housing the SHMA before applying the Councils jobs-led Wellington (229) need. Current economic scenario, the Council can rely upon a realistic but 18. PCL Planning on Behalf of context does not look still challenging housing target which will meet Shapland Trust (149) encouraging for the sort of housing need over the plan period and demand 19. Milverton Action Group forecasts upon which arising from the Plan’s aspirations for growth. (113) housing and employment 20. Barton Willmore on Behalf numbers are based. (113) The Council does not accept that the ‘true’ figure to of the Comeytrowe be planned for is 18,000 or even 18,500. The report Consortium (302) • Total housing numbers makes very clear that whilst the Council for 21. Strategic Land Partnerships should be derived from a sustainability reasons would wish to ensure that all (367) credible population model those working within the Borough could be housed 22. Oake Parish Council (195) and assessment of housing here, it has no means of ensuring this. Moreover, 23. Barton Willmore on Behalf need and not from a model the total Fordhams figure is 18,038 with the LBHP of De Virgo Ltd (414) led by the generation of Report explicitly stating that specialist employment. (129) (214) accommodation requirement should be treated with (298) (229) caution.

• Support the reduction in Therefore, it is not unreasonable to assume that housing numbers from that unless the entirety of the specialist requirement was originally proposed in the addressed through the provision of net additional RSS. (195) dwellings and all 11,900 jobs were delivered over the plan period that the housing target is sufficient. • Support for the Council’s Particularly since figures are expressed in the Core decision to rely on credible Strategy as ‘at least’. The NPPF remains a evidence in arriving at consultation document (and one that has attracted a 17,000 target. (367) significant volume of representation). Given that a good deal of this representation will relate to the ‘20% requirement’ very limited weight should be attached to this particular provision of the draft policy. Particularly, as there seems to be some uncertainty and confusion as to its application.

It should be noted that the reference to Fordhams writing off half a years worth of jobs creation is incorrect, Fordhams Addendum was based upon a similar addendum to work previously undertaken by Roger Tym which calculated a target of 11,900 jobs up to 2028.

Support noted.

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST The phasing of 1. Baker Asscs on Behalf of • Phasing should not be used Delete phasing requirement. Figures are expressed as ‘at least’ and phasing None housing Barratt Homes (112) solely on the basis of should not be taken as a cap on development over a requirements 2. DPDS on Behalf of Notaro employment creation, this particular time period where this accords with the New Homes (111) fails to take into account principles and policies set out in national planning 3. Persimmon Homes and other factors which drive policy and the Core Strategy. Redrow Homes (158,159) housing demand e.g. popn 4. APP on Behalf of Gadd change, demographic It should also be noted that the Council’s approach Properties Ltd (82) changes, affordable housing to phasing its housing requirements was recently 5. APP on Behalf of David need. (75) (82) (112) (111) supported at a Section 78 Planning Appeal. The Wilson Homes (75) Inspector noting that there was: “some logic in the 6. IJP Planning on Behalf of • There is no basis or approach given that economic activity affects to a Redrow Homes at justification for phasing. degree migration into and out of an area so that a Wellington (146) (302) (414) downturn would depress need as well as demand”. 7. PCL Planning on Behalf of Appeal Ref: APP/D3315/A/10/2140103 - Land at Shapland Trust (149) • Delivery rates of over 500 Maidenbrook Farm, Taunton (para 27) 8. Barton Willmore on Behalf have only been achieved of the Comeytrowe twice since 2002, therefore a Consortium (302) delivery rate of over 1,000 9. Barton Wilmore on Behalf of dwellings per annum in De Virgo Ltd (414) unachievable. (146)

Lack of five year 1. Baker Asscs on Behalf of • In-light-of representations on • Remove phasing requirement The Council is now in the process of reviewing its None deliverable Barratt Homes (112) the validity of housing for Broad Locations such as Strategic Housing Land Availability Assessment so supply of targets, use of phasing and Staplegrove (Baker Asscs) as to ensure it can provide a forward looking housing 2. APP on Behalf of Gadd implications of draft NPPF, assessment over the period April 2012 – March Properties Ltd (82) the Council is unable to • Provision should be made for 2017. Since the Council does not accept that either demonstrate a five year further early releases of its housing numbers are too low, nor that phasing is 3. APP on Behalf of David deliverable supply of strategic sites and rapid inappropriate, any assessment will be framed Wilson Homes (85) housing land. progress on the Site against the targets and phasing set out in the Allocations DPD (Gadd Published Plan Core Strategy. 4. Barton Willmore on Behalf • The Plan is inflexible in Properties Ltd) (David Wilson of the Comeytrowe relying excessively for Homes) The NPPF remains a consultation document (and Consortium (302) delivery on a small number one that has attracted a significant volume of of very large sites, and representation). Given that a good deal of this 5. Taunton Self-Build where both viability issues representation will relate to the ‘20% requirement’ Association (Appletree and market dynamics tend very limited weight should be attached to this Homes) (538) to restrict both supply and particular provision of the draft policy. Particularly, absorption of that supply as there seems to be some uncertainty and even when underway. confusion as to its application. The Council will

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST continue to take practical steps to identify sites which can come forward and make a contribution towards its five year deliverable supply of housing land, irrespective of changes to national planning policy.

The scope for the identification of further interim release sites will be considered as part of the SHLAA Review process. It should however be noted that the rationale behind the recognition of both Staplegrove and Comeytrowe/Trull as Broad Locations rather than strategic allocations was that it was considered neither was deliverable within five years at the time at which the Core Strategy was published.

Beyond the Core Strategy the Council will re- commence work on its Site Allocations DPD. This Plan will need to make provision for development on smaller, non-strategic sites which may not have been appropriate for allocation within the Core Strategy but which nonetheless can make a significant contribution to the meeting of strategic housing targets.

It should also be noted that beyond the first five years of the Plan Period the proposed reduction in the scale of development anticipated at the Monkton Heathfield Urban Extension from 5,000 to around 4,500 will have no negative impact on the deliverability of the 17,000 strategic housing target. In the first five years of the period, it is anticipated that around 1,000 new dwellings will be delivered at the Urban Extension (primarily through existing planning permissions). Beyond the first five years, the planned reduction will be absorbed through the contribution to be made by development at the Broad Locations of Comeytrowe and Staplegrove (as well as other sites identified through the Site Allocations process).

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST

Viability of 1. Persimmon Homes and • Affordable housing viability • Para 3.60 should be revised Affordable housing policy as with all other aspects of None affordable Redrow Homes (158, 159) should be kept under review to reflect that AH is one the plan will be kept under review so as to ensure housing to reflect market conditions aspect upon which that the policy remains justified and effective. PPS3 2. Taunton & District Civic and be dependent on contributions will sought, and relevant case law has established that any Society Group (96) infrastructure requirements. other infrastructure items will evidence supporting the viability of affordable affect the viability of housing should identify what is an appropriate target 3. Barton Willmore on Behalf • Viability will be affected by development. for the plan now, not what could be achieved should of the Comeytrowe when development takes market conditions be different. Consortium (302) place. If requirements are • Viability assessment and set in 2013 for example but consequent determination of The affordable housing target has been arrived at 4. Barton Wilmore on Behalf of development does not take the level of AH required following an Affordable Housing Viability Study, an De Virgo Ltd (414) place till 2016, viability could should be closely coupled to initial Viability Assessment as part of the have improved and AH offer a guaranteed delivery date of Infrastructure Delivery Plan and work undertaken as 5. Strategic Land Partnerships may be lesser. (96) housing. part of the Strategic Masterplanning Commission. (367) All three studies conclude that a 25% target is likely • The Policy should make to be broadly deliverable, taking into account likely clear that the target of up to infrastructure requirements. 25% will be the subject of negotiation and affordable It should be noted that in arriving at any assessment housing will not be sought at as to the level of developers contribution can be a level which it would make made through the Community Infrastructure Levy, development proposals regard will need to paid to the requirements of CP4 unviable. (414) as well as the form and tenure mix of affordable housing to be sought. • Welcome 25% target and desire to create sustainable, mixed communities but policy should make clear that affordable housing is subject to viability. (367)

Mix of housing Milverton Parish Council (36,56) Policy fails to recognise explicitly SO4/Policy should assert that Policy CP4 as worded in the Published Plan states: None required the types of housing required housing need in rural communities “New housing should help to contribute towards the particularly in rural areas where is different from the larger centres creation of sustainable, mixed communities offering the need is primarily for smaller and should therefore aim to high quality homes providing for a mix of new houses which cater for young deliver: housing types, sizes and tenures which meet the families. (36) needs of the Borough.” It is not considered 1) affordable housing necessary to explicitly refer to the types of housing

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST 2) 2-3 bed houses within the likely to be required in rural areas. This level of reach of low-middle detail may be more appropriately reserved for a income rural workers Neighbourhood Plan or background to a strategic 3) a smaller proportion of allocation. executive homes

Affordable 1. DW Alder Town Planning Target of 25% affordable housing A higher threshold of possibly 9 Accept – need to clarify wording of para 3.71, refer Amend Para 3.71: ““3.71 housing target Consultants on Behalf of is inconsistent with para. 3.71 dwellings should be introduced. more to need to bring forward affordable housing in Many of the Boroughs rural landowner: South of Harris’ which refers to new development rural areas. This can be delivered in a number of communities are Farm (129) in rural areas including a ‘high ways: cross-subsidised schemes, 100% affordable disadvantaged by barriers to 2. DW Alder Town Planning proportion of affordable housing’. developments etc. housing, poor access to Consultants on Behalf of (147) facilities and severely limited landowner: Broadlands Disagree, 25% target as evidenced through LBHP by public transport. New (136) CP4 conflicts with strategic would allow for affordable housing need to be met development in rural areas 3. DW Alder Town Planning objective 4. Applying a 25% over the plan period. The plan should not be must therefore include a high Consultants on Behalf of target will increase the number of seeking to address demand for affordable housing. proportion of affordable landowner: Cornhill, people requiring housing whilst Moreover, 25%, as evidenced through results of housing. There is therefore a Wellington (214) failing to meet demand. (129) viability assessments, is generally the highest need to bring forward 4. DW Alder Town Planning (214) (298) (229) affordable housing target that could be applied in affordable housing in rural Consultants on Behalf of current market conditions. areas and ensure all new landowner: Highlands, Threshold of 5 dwellings in urban development is well related to Cotford St. Luke (248) centres may result in lower The affordable housing threshold and target has existing facilities and 5. DW Alder Town Planning density schemes on small been informed by a high level assessment of services. It is also vital that Consultants on Behalf of regeneration sites or make such viability. This included the assessment of a number these communities have landowner: Foxes Meadow, sites unattractive for residential of smaller, urban sites. Where a genuine viability good access to utility Wellington (229) development. (149) issue arises on such sites, clearly the Council may infrastructure, such as gas, to 6. Blackdown Hills AONB wish to reconsider the affordable housing reduce dependency on oil, (147) The Plan makes insufficient requirements as set out in the Plan. energy efficient homes to 7. PCL Planning on Behalf of provision for affordable housing reduce fuel poverty, and Shapland Trust (149) in general, contrary to PPS3 and Core Policy CP4 merely sets out the affordable services such as high speed 8. Taunton Self-Build based on the evidence submitted housing threshold and target which will be applied to broadband to enable Association (Appletree in the Strategic Housing Market appropriate qualifying schemes through S106 community diversification and Homes Ltd 538) Assessment. (538) contributions. It does not preclude alternative support rural businesses, models of delivery despite not specifically services and facilities. The Plan specifically makes little responding to self-build. [new formatting] or no explicit provision to “3.72 A range of leverage innovation in the accommodation is vital funding and supply of affordable throughout the Borough to new homes for local people promote integration and

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) SUMMARY OF REP SOUNDNESS TEST through innovative delivery provide balanced models or tenures, in-particular, communities. Sustainable Community self-build. (538) (economically, socially and environmentally), mixed communities; which promote integration, for the benefit of all members of society are essential throughout the Borough. A range of transport modes; walking, cycling and excellent public transport is also essential for a balanced community by enabling good access to employment, services and facilities.

Delivery of DPDS on Behalf of Notaro New A clearer strategy is required for Include phasing mechanism to The Council is obliged to maintain a five year rolling None housing in rural Homes (352) the delivery of houses within rural facilitate the delivery of non- deliverable supply of housing sites. The 2010 villages villages. How demand for both strategic sites within rural villages SHLAA indicated that a substantive proportion of the market and affordable dwellings during early stages of the plan supply could be drawn from rural parts of the over period 2011 – 2017 can be period. Borough. It would be inappropriate and un- met should be questioned without necessary to pre-judge the outcomes of consultation such an approach. This will help and undermine principles of the localism agenda in to ensure consistency with NPPF identifying early release sites in rural parts of the RE: five year supply plus 20%. Borough.

Housing in Wiveliscombe Parish Council With pp for 80 units already None sought. Comments noted. Since publication of the Core None Wiveliscombe (193) granted for town, proposals for Strategy, Wiveliscombe Parish Council have 150-200 set out in settlement expressed some interest in preparing a hierarchy need to be carefully Neighbourhood Plan for the town. This would be an planned. appropriate mechanism within which for future growth of the town to be planned.

50 POLICY CP5: Inclusive Communities

ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets)

Places of Taunton Vale Specific reference is made to Development proposals will The national Planning Policy Framework was not Development proposals will promote Worship Gospel Hall Trust places of worship elsewhere in the promote sustainable development published when the Core Strategy went out for sustainable development that creates social (353) document but there is no reference that creates social cohesion and consultation. As an emerging document it has cohesion and inclusive communities; to the need of places of worship in inclusive communities; reduces limited weight. reduces inequalities, promotes personal well- CP5. PPS1 recognises the inequalities, promotes personal being and addresses accessibility to health, importance of provision of religious well-being and addresses However, accept comments and suggested inclusive housing, training, education, places buildings. Places of worship are accessibility to health, inclusive changes. of worship, leisure and other community also recognised in the Draft housing, training, education, facilities ensuring better quality of life for National Planning Policy places of worship, leisure and everyone both now and for future Framework. other community facilities ensuring generations. better quality of life for everyone both now and for future generations.

The Elderly Tetlow King There is little emphasis on older A specific Development The Core Strategy should be read in its entirety. Accompanying text to CP5 Planning people that encourages a full Management Policy later in the …which will require adaptability of homes, (187) range of care and accommodation document: CP5 refers to a range of housing for the settled and a range of specialist housing as well as for older people. The and travelling community. such as provision of Care and Residential government’s policy is to ensure Taunton Deane Borough Council Institutions including Extra Care Housing that people have a choice and will encourage the provision of The supporting text states that “The population of Schemes, Close Care, Assisted Care opportunity in old age with their housing for the elderly and for the Borough is older than the national average housing and Continuing Care Retirement care and accommodation options. people with special needs. The which will require adaptability of homes as well as Communities. Increased demand…. Council will, through the provision of Care and Residential institutions.” It identification of sites through the also refers to “life time hones principles, granting of planning consents in adaptability and energy efficiency”. However the sustainable locations provide for text in 3.74 could be amended to include development of residential homes, reference to the range of accommodation. Extra Care Housing Schemes, Close Care, Assisted Care The Core Strategy evidence base includes a housing and Continuing Care paper on Locally Balanced Housing Projections Retirement Communities. points out that it is harder to predict the needs of older persons with the same degree of accuracy as mainstream element of housing. However, the study model infers that there is a need arising for up to 1,760 specialist units. It continues that

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) taking into account that many older people wish to remain in their own homes this figure should not mealy be added to the market and affordable requirement, as there will be a commuting in the housing stock and provision of specialist accommodation should therefore be integral part of the total 17,000 new homes in the Borough up to 2028 making a mixed balanced community.

Residential Institutions are picked up in CP2 Employment as part of a balanced economy. CP4 Housing states that 17,000 new homes will be sustainable, mixed communities offering high quality homes of a mixed type, tenure and size. SP1 Sustainable Development states that development should be in the most accessible and sustainable locations.

The policy SS1 for Monkton Heathfield includes allocation within the district centre for sheltered housing. This can be broadened to include Care and Residential Accommodation.

Supporting text for Policy CP4 makes reference to the SHMA and LBHP studies providing indication on size tenure of market, affordable and specialist housing accommodation over the plan period.

Impact of NHS Somerset (92) Policy should make reference to Policy should make reference to Health is included in the policy. None housing on the impact that housing and the impact that housing and human health associated population growth has associated population growth has on health provision. (92) on health provision.

1. Economy Milverton Parish 1. We find very little to disagree 1. None 1. Support noted 1. None Council with…The need to encourage 2. Home (57) individuals and employers to set Working up small businesses in rural areas, to discourage the need to

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) 3. Community travel to work is supported, and support for the requirement to ensure that Elderly everyone working out of thier locality has transport to work is equally necessary. 2. There needs to be more 2. The drive to achieve high speed 2. The mobile phone network, unlike 2. None emphasis on home working broadband is encouraging, as landline/broadband supply, is unlikely to be a through improved would be a similar statement to requirement of development. Broadband was communication and ensure that the mobile phone reflected in policy as Central Government had network is improved. stated their committed to the role out of high- speed broadband across the country. In addition to this provision of mobile coverage is complicated by individual providers to not routinely share infrastructure or equipment and that mobile phone usage is a choice rather than a necessity in Central Governments view. 3. A greater commitment to 3. A commitment to looking after 3. The Core Strategy addresses issues relating to 3. None supporting elderly. the elderly residents close to or adaptability of new homes, energy efficiency; within their home as far as sustainable locations, etc which will reduce fuel possible would be welcome. poverty and isolation as well as enable the elderly to have their homes adapted to their needs. Reference to Specialist Accommodation for the elderly is also made in the document. References in Policy and supporting text of CP5, CP4, CP1.

Noise impact Somerset Scientific 1. Consideration of noise impact The area of consideration should 1. This is a matter of detail and not strategic; None Services from recreation and sports be extended to include those therefore, it is not a Core Strategy issue. (26) development is not adequately adversely affected by associated covered in the Core Strategy development. 2. CP5 should provide 2. Consideration of noise impact would be dealt consideration to those with at application stage with reference to immediately affected by any PPG24 as impact of noise can be a material development. consideration in determining planning applications.

Sport and Sport England Support for the provision of sport Indoor sports facilities should be The evidence for provision of indoor sports Services, Community and Social Facilities –

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) Recreation (167) and recreation facilities, however added to the list under the heading facilities is within the evidence base – TDBC Build providing a range of education, health, recommendation to strengthen the “Services, Community and Social Sports Facilities Strategy Adopted 2010. Formal indoor sports, retail and meeting spaces as Policy in regard to indoor sports Facilities”, as indoor provision Sports Facilities is also referenced in the well as access to sustainable transport and facilities should be separate form outdoor supporting text. high speed broadband. facilities which appear under the heading “Recreation Space” Therefore we accept comments and suggested changes.

1. Green Space Priory Community 1. CP5 should include reference to None 1. Informal green space is an important part of a In CP5 Association informal green space. Safe sustainable community; we had not listed all Recreational Space – improving health and 2. Urban and (13) guard all real green living green space types as these are covered in the interaction through provision of formal and Rural infrastructure. TDBC Green Space Strategy which is part of informal green space such as, play spaces, the evidence base. We can include a list of allotments, playing pitches, sports facilities green spaces in the Policy and explanation text as well as promoting walking and cycling. in CP5 and include a table of green space standards along with other measures which will Included in SO5 Measuring success promote inclusive communities (from TDBC Total green space 6.85 ha per 1000 Adopted Strategies) in Strategic Objective 5, in population. a table Measuring Success. TDBC could not and should not blanket protect all green space, the TDBC Green Space Strategy states that green space can be disposed of where it is low value, surplus to requirements and will not undermine opportunities for access to open space. TDBC will consider for another open space type or for built development with 80% of the receipts going into open space provision. The strategy also states low value space requiring protection should be upgraded. 2. last sentence of Policy CP5 2. Inclusive communities’ policy is applicable to should say “urban and rural” rural and urban communities; therefore the addition of the words “urban and rural” to the last sentence is not necessary.

Spatial Issues Strategic Land Concerns over whether the Policy The Core Strategy is a Spatial Plan not solely a None for Core Strategy Partnership CP5 rightly sits within the Core Land Use Plan; therefore it should consider the

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) (368) Strategy or whether it should apply impact of proposals on its communities. to the Council’s Strategic Plans Policy CP5 and other polices related to inclusive communities should be retained in the Core Strategy in line with PPS1 which states that Planning should facilitate and promote sustainable and inclusive patterns of development which includes ensuring development contributes to creation of safe, sustainable, liveable and mixed communities with good access to jobs and key services for all members of the community (PPS1 Sect:5)

Development Plans should promote development which creates socially inclusive communities…Plan Policies should (inter alia): seek to reduce inequality, address accessibility in terms of location and physical access to jobs, health, housing, education, shops, leisure and community facilities, take account of need of al the community, including particular requirements relating to age, sex, ethnic background, religion, disability or income, deliver safe, attractive and healthy places to live, support promotion of health and well being by making provision for physical activity. (PPS1 Sect:16)

Requirements Persimmon Homes 1. CP5 introduces a range of Whist planning obligations have a The Core Strategy is a spatial plan not solely a 1. None that create and Redrow requirements that may place role in securing new infrastructure land use plan; therefore, it should consider the sustainable, Homes unreasonable burdens on associated with development the impact of development on communities. It is inclusive (344) development proposals and go contributions sought will have to consistent with PPS1 (Sect:16); promoting development beyond land use planning accord with Circular 05/2005 and development which creates socially inclusive considerations. will need to be i) relevant to communities. The Plan includes Policies which planning; ii) necessary to making seek to reduce inequality, address accessibility to Barton Willmore on the proposed development jobs, health, housing, education, shops, leisure behalf of Devergo acceptable in planning terms; iii) and community facilities, as well as account of

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) (412) directory related to the proposed need of al the community, including particular development; iv) fairly and requirements relating to age, sex, ethnic reasonable related in scale and in background, religion, disability or income, and kind to the proposed development; deliver safe, attractive and healthy places to live, and v) reasonable in all other which support promotion of health and well being respects. by making provision for physical activity

Barton Willmore on 2. Any policy requirement to enter Section 106 of the Town and Policies are developed from a robust and credible 2. None behalf of into Section 106 must meet the Country Planning Act and Circular evidence base which includes information on Comeytrowe three legal tests in Regulation 05/05 Regulation 122 of the CIL services and facilities required to make a Consortium 122 Regulations must be considered developments acceptable. Requirements are (303) and contributions only sought deliverable, flexible and able to be monitored. where they are reasonable having Issues of individual site viability are dealt with at regard to site specific matters Development Management stage. including viability and more over meet national policy tests. 3. CIL charges should be An infrastructure Delivery Plan was published for 3. None introduced via a Development consultation at the same time as the Core Plan Document that requires Strategy and CIL is being prepared in line with the Examination in Public. national policy and guidance.

Policy is not 1. DW Alder Town Policy is not effective as it largely None The Core Strategy should be read in its entirety. None Specific, Planning just repeated strategic objective Deliverable or Consultatants without expanding. Do not contain The Core Strategy is a Spatial Policy which can Measurable on behalf of clear actions that are deliverable have land use interpretations. The policy and land owner and measurable. Which accompanying text contain information on what Charles French communities does it refer to? creates sustainable, cohesive and inclusive (135) communities. This is applicable to all 2. DW Alder Town communities. These are deliverable and can be Planning monitored. Consultatants on behalf of Issues of individual site viability are dealt with at land owner Development Management stage. Rayglow Securities (213) 3. DW Alder Town Planning

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) Consultatants on behalf of land owner Haunch Lane Development Hillcommon (120) 4. DW Alder Town Planning Consultatants on behalf of land owner South Western Property (228) 5. DW Alder Town Planning Consultatants on behalf of landowner Highlands (247)

Affordable Somerset County 1. The first two sentences in None proposed Accept – need to clarify wording of para 3.71, Many of the Boroughs rural communities are Housing in Council paragraph 3.71 when red refer more to need to bring forward affordable disadvantaged by barriers to housing, poor Rural Areas (529) together suggest that there housing in rural areas. This can be delivered in a access to facilities and severely limited by might be high levels of number of ways: cross-subsidised schemes, public transport. New development in rural affordable housing in the rural 100% affordable devts etc. areas must therefore include a high areas but public transport proportion of affordable housing. There is would be limited. This would therefore a need to bring forward affordable be a worrying combination housing in rural areas and ensure al new since it is known that those on development is well related to existing or lower incomes have less facilities and services. It is also vital that access to a private car and these communities have good access to rely more on public transport. utility infrastructure, such as gas, to reduce A mitigation technique would dependency on oil, energy efficient homes to be to deliver these as mixed reduce fuel poverty, and services such as use, rather than housing in high speed broadband to enable community isolation. diversification and support rural businesses, services and facilities 2. Regarding paragraph 3.73,

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) reference to embedding [new formatting] walking and cycling is A range of accommodation is vital welcome. throughout the Borough to promote integration and provide balanced communities. Sustainable (economically, socially and environmentally), mixed communities; which promote integration, for the benefit of all members of society are essential throughout the Borough. A range of transport modes; walking, cycling and excellent public transport is also essential for a balanced community by enabling good access to employment, services and facilities.

1. Social NHS Somerset 1. NHS Somerset is pleased to see 1. Substitute “where ever possible 1. Core Strategy policies must be deliverable 1. None inequalities (93) the promotion of high quality and viable” to “”will make (Pg.17 PPS12) and the most appropriate when and inclusive design will involve a provision for all”. considered against the reasonable alternatives disadvantage range of environmental and (Pg15 PPS12). It is not viable or realistic for social determinants of development to reduce all social inequalities 2. Energy health…However…it would be and disadvantages. Efficiency preferable to increase the priority of “a reduction in social 3. Mitigation of inequalities and disadvantage” access to 2. The Strategy should ensure 2. None 2. The energy efficiency of the Council’s existing 2. None services and appropriate standards of energy housing stock is not a matter for the Core facilities efficient throughout Taunton Strategy. Deane’s existing housing stock. 4. Employment 3. Many of the rural communities 3. None 3. The Core Strategy focuses growth in the towns 3. None are disadvantaged by poor because these are the most sustainable 5. Transport access to facilities and severely locations with good public transport links and limited public transport but the access to a range of facilities. Policy SP1 sets 6. Cycling and strategy omits to say how the out the most sustainable locations for walking Council will mitigate this development in rural areas. problem. 4. Employment is a key 4. A strategic option which 4. CP4 Employment addresses issues of local 4. None determinate of health. For this maximises local access to employment opportunities. reason we would support the employment opportunities

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ISSUE ORGANISATION( SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE S) (insert SOUNDNESS TEST comment id in brackets) inclusion in Policy CP5, a strategic option which maximises local access to employment opportunities. 5. We suggest connectivity by a 5. connectivity by a range 5. Accept comments and suggested changes. 5. Last sentence of 3.71 is used to start range transport modes should transport modes should include new paragraph: 3.72 include not only walking and not only walking and cycling, but [new formatting] cycling, but also public transport also public transport A range of accommodation is vital options for enabling longer throughout the Borough to promote distance commuting. integration and provide balanced communities. Sustainable (economically, socially and environmentally), mixed communities; which promote integration, for the benefit of all members of society are essential throughout the Borough. A range of transport modes; walking, cycling and excellent public transport is also essential for a balanced community by enabling good access to employment, services and facilities. 6. NHS Somerset is pleased to 6. None suggested 6. Support noted 6. None read the recognition of health and social needs and inequalities amongst Taunton Deane’s population. The recognition of addressing this by accessing green space embedding walking and cycling into developments and providing playing pitches and sports facilities is reassuring. This supports NHS Somerset’s objective of providing the right facilities and health-enabling environments in local areas…this is a cost effective solution to improve the populations health.

59 POLICY CP 6: Transport and Accessibility

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Reflect the Taunton & District Civic 1. Need to acknowledge the dominant role Revise the approach towards The Core Strategy is not concerned with the direct None dominant role of Society (100) of the private car within Somerset for the public transport to be more provision of transport services but with the land use the private car foreseeable future. realistic and deliverable. context for movement. As such, it is a long-term 2. Parking standards at home and places of strategy which aims to ensure that development employment should reflect the dominant facilitates or encourages desirable transport role of the private car. outcomes and does not preclude them.

3. Lack of car parking will have an adverse 1. There is a difference between conditions in rural None effect on retailing in Taunton town centre. parts of the County and those in the main towns 4. There is not sufficient scope within of Taunton Deane, where it is not physically Taunton for significant bus priority possible to cater for unlimited access and use of measures. the private car. Transport modelling has 5. There is no indication that the West demonstrated that a modal shift from the car is Somerset Railway will become a regular necessary to accommodate the scale of growth and comprehensive transport provider. proposed in the Taunton area. A significant proportion of car trips within and around the main urban areas are less than 2 miles long and capable of being made by other modes. 2 .Parking standards within towns are limited by None available space and highway capacity. The standards for commercial development contained in the adopted Taunton Town Centre Area Action Plan aim to strike a balance between the level of demand and the practicalities involved in meeting it. Parking standards in residential development should take account of the HCA document ‘Car Parking: ‘What Works Where’ – note that this does not endorse open-ended parking provision. 3. There is no evidence to suggest that unrestricted None car access is necessary to sustain the retail vitality of town centres. CP6 proposes a balanced approach in line with national and/or local standards. Within Taunton, two major park and ride sites have been developed over the past decade as alternatives to town centre parking. 4. There is scope for bus priority measures within None Taunton; for example within the town centre (already identified in the TTCAAP) and

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST associated with major new developments, and these will be progressively introduced over the life of the Core Strategy. 5. In terms of the West Somerset Railway, there are None examples elsewhere in the UK of private railways moving towards regular train operation linked to the national rail network. To a limited extent this has already happened with the WSR, and there is no reason to think that this aspect will not be developed further over the life of the Core Strategy, or that land use development should ignore such potential. A policy in the Core Strategy would also enable funding to be allocated towards relevant improvements on the railway at some future date. Recognise link NHS Somerset (94) There is a lack of recognition of the links Refer to the way that reducing Whilst tackling climate change is referred to in CP6, Add new paragraph after between between sustainable transport and greenhouse gas emissions can it is accepted that there is no direct reference to the 3.84: sustainable accessibility, and public health policies. bring collateral health benefits to public health benefits of this. There is a clear link transport and Health promotion strategies need to be the Taunton Deane population. between sustainable public health embedded in future transport plans transport and policies throughout Taunton Deane to promote accessibility, and public primary prevention of poor health. health policies. Health promotion strategies need to be embedded in future transport plans throughout Taunton Deane to promote primary prevention of poor health. Reductions in bus Milverton Parish Council Reductions in bus services at weekends and Real improvements to long term Agree; however, public transport services are None services (38) the threat to weekday services undermines sustainable public transport are outside the control of the Borough Council. The the credibility of the policy. needed before there is any Core Strategy does aim to avoid locating significant development in development where there is no realistic prospect of Milverton and other minor rural adequate public transport being provided. centres. Viability will affect Pegasus Planning The viability of the urban extension at An additional sentence should be This issue is acknowledged; however as it applies to None the level of Group on behalf of Monkton Heathfield needs to be borne in added to recognise the potential all types of infrastructure, and the Plan should be developer Persimmon Homes and mind when determining the level of impact of CIL on development read as a whole, there is no need to amend 3.85 as contributions Redrow Homes (345) contributions from developers towards viability. suggested. sustainable transport.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST No evidence to Highways Agency (333) Detailed transport assessments of Reference to any aspiration for a It is accepted that there is no evidence at present None support new M5 development proposals are required to new motorway junction should be that a new motorway junction will be needed within junction demonstrate that all reasonable alternatives deleted. the Core Strategy period, but there is evidence of have been explored to mitigate impacts of need for limited capacity improvements at Junction development before works to motorway 25 and the scale of development proposed in junctions are considered. Taunton suggests that the position should be kept under review. 3.83 suggests that a new motorway junction may be required at some point in the future and is a possibility. There is no evidence to support this and it is contrary to Circular 02/2007. New M5 Junction D Bradley (504) Taking the long term view another motorway Paragraph 3.83 should be There is no proven need for a new motorway None needed junction will be needed. strengthened to emphasise the junction although the scale of development need for a new motorway proposed in Taunton suggests that the position junction. should be kept under review. Support Strategic Land Policy CP6 is welcomed. Successful None Support noted None Partnerships (380) development will be well located and served by all forms of transport, increasingly in a world of higher oil prices by public transport. Technical details Somerset County Comments on technical detail and points of In CP6, reword ‘address climate Agree Amend first sentence of Council (528) accuracy. change’ as ‘mitigate and adapt to CP6 to read: ‘…and climate change’. mitigate and adapt to climate change.’

Clarify first bullet point in CP6. The policy is intended to ensure that developments Amend second sentence which are likely to generate longer-distance trips are in 3.82 to read: ‘In located where use of the railway is a realistic option, particular, efforts are rather than being located where they will inevitably needed to encourage encourage use of the strategic road network longer-distance journeys (particularly the M5). In practice this means to be made by train, and concentrating travel-intensive commercial the adopted Taunton development, such as offices, retailing, and Town Centre Area commercial leisure within Taunton town centre, Action Plan…’ particularly at Firepool as identified in the TTCAAP, and avoiding such developments at peripheral locations close to strategic roads. New housing also needs to be located where it will not simply result in use of the strategic road network for travel to remote locations for employment and, shopping etc., rather

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST than use of more local facilities. There will be a need to safeguard sites, such as Wellington station, for transport measures that provide alternatives to use of the strategic road network. It is accepted that new residential areas should have good access by sustainable modes. However, new residential areas are not primarily a destination.

Add reference to ‘new residential Agree None areas’ to second bullet point of CP6 It is unnecessary to refer to Agree Delete ‘which are likely ‘significant transport implications’ to have significant as guidance on Travel transport implications’ in Assessments and Travel Plans fourth bullet point of provides thresholds for different CP6. levels of travel plan.

Reference should be made in the Agree Add ‘and the County fourth bullet point of CP6 to the Council’s Travel Plan County Council’s forthcoming SPD’ at end of fourth Travel Plan SPD. bullet point of CP6.

National parking standards are 3.81 does refers to reducing the impact of short Amend sixth bullet point being removed – it would be more distance trips. There is also a need to encourage of CP6 to read ‘…in appropriate to refer to the ‘Local modal shift for longer distance journeys – for accordance with the Transport Strategy’. example, trips over 5 miles long produce the majority Local Transport Strategy of greenhouse gas emissions. to reduce congestion and pollution…’. Paragraph 3.81 should refer to None the problem of use of the strategic road network for short distance journeys. Rural cycle routes Paul Partington (384) There is no provision for the aspirations of the None The Core Strategy does not contain detailed At the end of the second community for a cycle route to connect proposals for individual cycle routes; however a bullet point in CP7, add: Bishops Lydeard to Taunton and Cotford St reference to the need for high-quality cycle routes ‘…and Taunton East, Luke. between Taunton, Wellington and surrounding rural and from rural centres centres and villages could be added to the second and villages to the main bullet point of CP7. towns;’

63 CORE POLICY 7: Infrastructure

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets)

Include green Environment Agency CP7 should include ‘green CP7 should be amended to include Whilst green infrastructure would fall under None infrastructure (285) infrastructure’ within priority number 2 ‘green infrastructure’ within priority priority number 2, it would be inappropriate to (where viability is a constraint) to number 2 (where viability is a identify in the Core Strategy what elements provide clarity on where this important constraint) to provide clarity on where would comprise priorities 1-4, as these will vary element will be prioritised. this important element will be between individual developments. prioritised.

IDP and S106 Barton Wiillmore LLP on Policy CP7 and supporting text refers None The IDP will be submitted with the Core None negotiations behalf of the to the IDP as accompanying but not Strategy but is not bound in with it as it will Comeytrowe Consortium being part of the Core Strategy. It is require more frequent review. (304) therefore assumed that it will not be relied upon in S106 negotiations. The IDP will form a key element in any discussion with developers about planning obligations; however, many of its requirements will be funded through CIL and will thus not be negotiated through S106.

In 3.92 it is of concern that the Borough None The Council has prepared a wide-ranging None Council proposes to ensure that evidence base to justify the level of contributions from development are set contributions that will be sought. In terms of at the maximum level that can be setting the level of CIL the Council will have achieved without rendering schemes regard to the CIL regulations. There is no unviable, without any reference to the logical reason for setting it any lower than the reasonableness of those requests or maximum that it appears to the Council can be the tests set out in CIL Reg 122. achieved, taking account of the viability of development in Taunton Deane as a whole. Support Quantock Hills AONB Support the inclusion of green None Support noted None (270) infrastructure as an integral part of overall infrastructure and the intention to seek contributions to secure its provision. Affordable housing will Tetlow King Planning on Policy CP7 fails to make any reference The Council should set out clearly that There appears to be some misunderstanding None affect CIL contributions behalf of SW Harp (186) to the role that affordable housing will any future contributions from CIL will about CIL – the Council’s proposals for this are play in the priorities for setting impact on the delivery of affordable not being examined as part of the Core contributions. This is not the intention housing. The Core Strategy should Strategy, but will be examined at a later date of the Government. frame the future CIL charging schedule following publication of the draft Charging by clearly stating the Government’s Schedule.

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) intention for affordable housing and CIL. Affordable housing is excluded from CP7 as it is not strictly infrastructure and was not within the scope of CIL at the time of preparing the Core Strategy. The viability assessment for the IDP does however make allowance for the provision of affordable housing. If affordable housing becomes eligible for the use of CIL then it would be included in a review of the IDP. Absence of IDP PCL Planning (157) Concern about the absence of None The IDP will be submitted with the Core None infrastructure delivery plan as the Strategy. By definition, CIL is a pooling of aspirations for CIL may not be realised. contributions – developers will pay a set price Concern that the strategy appears to per unit of floorspace which will then be spent be seeking pooled contributions which on a ‘basket’ of schemes. will be limited by CIL. Support Sport England (168) There is strong support for CP7, and None Contributions towards these facilities are None contributions towards sport and included in the IDP and will be eligible for the recreation provision should be included use of money raised through CIL. within the IDP and as part of the introduction of the CIL. Support GVA (164) The inclusion of priorities for None Contributions on a pooled basis are intended None infrastructure and approach to the to be sought via CIL, and the level of charge Phase 1 development is welcomed. will be subject to a viability assessment. Whilst In the current economic climate it is the CIL charging schedule has not yet been essential that any infrastructure prepared it is likely that at least some forms of requirement obligations do not stifle or commercial development will be exempt on prohibit early commercial development viability grounds. and economic regeneration. It is, therefore, essential that contributions in a tariff format are only sought from residential development. Support Blackdown Hills AONB Support for the identification and None Support noted None (182) inclusion of green infrastructure as an essential part of infrastructure and the intention to seek contributions towards its provision. Wrong prioritisation Milverton Parish Council The viability criteria are wrongly Criteria should be dropped. The comments appear to be based on a None. (42) prioritised with the needs of the new Developers should have to sign up misunderstanding of the planning process and population being considered last. This contractually to deliver what is required. the role of developer contributions within it.

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) prioritisation runs the risk of making the The planning system can only legally require developer the beneficiary, not the developers to fund those measures that are community. necessary for development to take place. If priority is not given to this then development will not be able to happen. In practice, the criteria in CP7 mean that the immediate needs of the development for flood alleviation, access, on-site provision of open space etc, will be given priority and off-site works less closely related to the development are likely to receive lower priority. Support Pegasus Planning Group Broadly support the approach to None CIL will be introduced in accordance with the None on behalf of Persimmon infrastructure set out in CP7. The CIL Regulations which require publication of a Homes and Redrow charges should be introduced via DPD charging schedule and an examination. Homes (346) (or such replacement) that requires an EIP or other rigorous assessment. Discussions with Baker Associates on In paragraph 3.92 it is very important None There will be discussions with the development None development industry behalf of Barratt plc (347) that discussions with the development industry during the preparation of the Council’s industry are held before the level of CIL charging schedule, which will also be contributions from development is set. subject to an examination. Barratt’s land manager attended a workshop on CIL which was organised by the Council for developers in summer 2011. Delete reference to Strategic Land The interim policy referred to in the fifth Reference to an interim policy should As the fifth bullet point in CP7 refers to the None Interim Policy Partnerships (366) bullet point of CP7 is not included in either be deleted or else the interim interim policy, it is not necessary to include the the Plan, which is considered to make policy should be included. detail of the policy in the Core Strategy. it unsound. The interim policy is optional – prior to the intoduction of CIL developers can still opt for the S106 approach. Support RPS on behalf of the Support SO7 and CP7 – the Police as None Support noted. The Police will be invited to None Avon and Somerset a social infrastructure provider are participate in the formation of the CIL. Constabulary (568) pleased to be included in the IDP and have made separate representations on this document. The Constabulary use the ACPO toolkit as a way of securing developer contributions and would welcome the opportunity to be involved in the production of CIL. CIL will not cover DW Alder Planning The plan states that many of its None The final paragraph of Policy CP7 sets out how None everything Consultants on behalf of objectives will be funded by CIL. priorities will be determined where there are

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) Highlands (257), South However this is not due to be brought insufficient resources to fund all elements that Western Property (238), in for some time and even then it will may be desirable. Charles French (145), not cover everything. There is no Haunch Lane suggestion of how it is intended to Developments (130), cover the shortfall. Rayglow Securities (223)

Technical comment Somerset County Council Paragraph 3.96 should not refer to the Agree Amend paragraph 3.96 (528) Local Sustainable Transport Fund – it to read: ‘…Somerset’s should instead refer to Somerset’s Local Investment Plan; Future Transport Plan. Somerset’s Future Transport Plan…’

67 POLICY CP8: Environment

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Historic English Heritage 1. CP8 fails to provide any depth to its 1. Suggested policy wording: 1. The place for detailed Development 1. None Environment (207) scope in relation to historic “Designated historic assets and their Management policies such as this is in environment. There is no indication of settings, including Listed Buildings, the Site Allocations DPD, not the Core what overarching strategies will be put Conservation Areas, Scheduled Ancient Strategy. Only strategic, high level in place for the heritage assets of the Monuments and Registered Parks and policies are appropriate in the Core Borough – no strategy for the Gardens will be conserved and where Strategy. management of Heritage at Risk, appropriate, enhanced. undertaking conservation area In considering development proposals, the appraisals or management plans or the Council will seek to protect other features of creation of a local list of historic assets local historic value and interest throughout that should all be managed through the the Borough. Core Strategy. This lack of regard to Distinctive elements of Taunton Deane’s the local character of the Borough historic environment will be conserved and could be most damaging to its historic where appropriate, enhanced and their environment. potential to contribute towards the economy, tourism, education and community identity will be exploited. These include: • The individual and distinctive character and appearance of Taunton Deane’s Market Towns and villages • Large Country houses and associated estates and estate villages, with Hestercombe House and Gardens being of national significance. • The striking perpendicular church towers of Taunton that create visual landmarks within the townscape. (Other specifically distinctive examples of heritage assets within the Borough.) To assist in protecting the Borough’s historic assets and features, the Council will: • Encourage the sensitive re-use and adaptation of historic buildings and will, where appropriate, support flexible solutions to the re-use of those historic buildings identified as at risk where this would remove

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST a building from English Heritage’s at risk register or local records of buildings at risk. • Seek to ensure the sensitive expansion, growth and land use change in and around the Market Towns and villages, safeguarding elements of the historic character and value within their built up areas, including Visually Important Undeveloped Areas, as well as surrounding historic landscape character and setting of individual settlements • Work with Somerset County highways, Town and Parish Council’s to provide highway improvements and street furniture that are appropriate to the historic context of individual towns and villages • Work with and support local estates to identify appropriate ways in which to manage their historic landscapes, features and buildings • Work with local communities to identify local features of historic interest and value in Parish Plans and Village Design Statements • Support new development proposals aimed at educating and raising awareness of Taunton Deane’s historic environment. Alternatively the previous policy should be reinstated with amendments to comply with PPS5. 2. The Proposals Map for the whole 2. Conservation areas should be plotted on the 2. Due to its scale of 1:50,000 it is 2. None district fails to map conservation areas. map of the whole District as this would allow impractical to plot conservation areas on an immediate picture of the variety and the Proposals Map for the Borough as a quantity of heritage assets within the whole, but they are shown on all the Inset Borough and would help to identify the more Maps which generally have scales of historically sensitive settlements at a glance 1:2,500 or 1:5,000. holistically. CP8 Third and Natural England 1. Green wedges and corridors have a 1. The Core Strategy would be clearer and 1. Agreed 1. Amend CP8 third fourth paras (565) key role in the retention and more effective in protecting the full range of paragraph: enhancement of green infrastructure green infrastructure assets with the following “A network of green assets, but not all such assets lie within wording change to the third paragraph: “A infrastructure assets has

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST such areas. network of green infrastructure assets has been identified and should been identified and should be retained and be retained and enhanced, including through the enhanced, including development of green wedges and corridors through the development as envisaged through the Taunton Deane of green wedges and Green Infrastructure Strategy.” corridors as envisaged through the Taunton Deane Green Infrastructure Strategy.” 2. It would be helpful to underline the fact 2. For added effectiveness, we propose the 2. Agreed 2. Amend CP8 third that development will be expected to following additional wording to the third paragraph: contribute to the realisation of the paragraph: “Developments will be expected “Developments will be green infrastructure creation and to adopt Natural England’s Accessible expected to adopt Natural enhancement opportunities mentioned Natural Green Space Standards (ANGSt) England’s Accessible in the policy. While shown on the and contribute to realising the opportunities Natural Green Space opportunities map on page 46, not all identified within the Taunton Deane Green Standards (ANGSt) and creation and enhancement Infrastructure Strategy.” contribute to realising the opportunities appear to be depicted on opportunities identified the Core Strategy proposals Map. within the Taunton Deane Green Infrastructure Strategy.” 3. National planning policy explains that, 3. For added effectiveness, and greater 3. Agree 3. Amend CP8 fourth for biodiversity, compensatory consistency with national policy, we propose paragraph: measures should be used as a last the following wording to the fourth “Development will need to resort (see for example PPS9, paragraph: “Development will need to mitigate or and where paragraph 1). It is also clear that mitigate or and where necessary, necessary, compensate biodiversity and geological compensate for adverse impacts on for adverse impacts on conservation interests that should be protected or important species, important protected or important protected from harm extend beyond habitats and natural networks , river and species, important legally protected species (see for ground water quality and quantity so that habitats and natural example PPS9 paragraphs 6 to 12). there are no residual effects.” networks , river and ground water quality and quantity so that there are no residual effects.” CP8 Fourth para Somerset County 1. Request change to 4th paragraph: 1. Agree – this point is covered by the 1. See 3 above. Council (527) ‘Development will be supported at agreed amendment proposed by Natural sustainable locations to improve green England in 3 above. infrastructure, public access, visual amenity and the overall quality of the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST natural environment. Development will need to mitigate or compensate for adverse impacts on ecological networks protected and Somerset priority species, river and ground water quality and quantity so that there are no residual effects. The addition of the phrase ecological networks Regulation 39 of the Habitats Regulations 2010 states that; For the purpose of the planning enactments (the Town and Country Planning Acts) , policies in the respect of the conservation of the natural beauty and amenity of the land shall be taken to include policies encouraging the management of features of the landscape which are of major importance for wild flora and fauna, (ie. those compromising ecological networks). 2. With regards to the amended phrase ‘ 2. Agree – Somerset Priority Species would 2. See 3 above. protected and Somerset Priority be covered by the term ‘important Species’ Somerset Priority Species are species’ recommended by Natural those identified by the Somerset England above. Biodiversity Strategy and include local conservation priorities for the County. A list is available on the Somerset Environmental Records Centre web- site. This would then support the Governments objective of ‘ no net biodiversity loss’ stated in its White Paper on the Natural Environment, The Natural Choice; securing the value of nature’. 3. Paragraph 3.116 Mapping of Bat 3. Para 3.118 states that the Bat 3. None Consultation Zone should be included. Consultation Zone is marked on the Proposals Map.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST CP8 Third para Strategic Land Development of the urban extensions Re-word the policy to state it may not be This is not the case. The land for the None Partnerships (365) involves a large number of different possible for developers to deliver green country park and green necklace landowners. The land identified for infrastructure. proposals is in the same ownership as the country parks and green necklaces development areas, so it will be possible may not be in the same ownership and to provide both. There will be further therefore would not be possible for discussion with landowners and developers to provide. developers about this. Bats Mr Graham Ward It appears that a relatively small Seek the most rational and balanced course The plan must have regard to the EC None on Behalf of number of animals, bats in particular, of action allowed under the law to further the Habitats Directive (92/43/EEC). Many Taunton & District will exert more influence on interests of the citizens of Taunton Deane as protected species occur in and adjoining Civic Society development within Taunton Deane well as protect wildlife and habitat. the towns, so the sustainable strategy to planning Group than the majority of the human focus growth on the urban areas has (101) population could ever do. This required Habitat Regulations imbalance, and the disproportionate Assessment. The Core Strategy does effect it has on planning cannot be in seek to strike a balance. The woodland the interests of the people of the planting required to compensate for the Deane. While animal environments loss of bat foraging areas will also benefit should be protected, and mitigation people through the creation of informal measures applied when development recreation opportunities and an attractive occurs, a better balance must be landscape setting for the new struck, because this approach will development. cause development to be prioritised towards areas that are not heavily frequented by protected species, to the detriment of those areas and their human population. The practice of requiring nearly every planning application in an affected zone to perform an assessment seems wasteful of resources. Cannot zonal assessments be applied? Flooding Environment 1. The provision of a strategic flood 1. Policy CP8 should be amended to the 1. Agreed – amend the latter part of fifth 1. Amend fifth para as Agency (284) attenuation scheme is primarily following text which will give more clarity as para of Policy CP8. follows: required to address the long-term to how each risk of flooding (both surface “as set out in the Strategic objective of TDBC to reduce flood and fluvial) is intended to be mitigated within Flood Risk Assessment risk in Taunton and mitigate for the new development sites across the Borough, Level2. Site specific impacts of climate change. Whilst both at the strategic and site-specific level: measures within development this scheme may also provide the “The Council will seek to direct development sites will not be sufficient opportunity to reduce the impacts of away from land at risk of fluvial or other mitigation to accord with

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST surface water run-off and volumes causes of flooding (including areas likely to PPS25. Development sites for allocated sites, it is not be subject to flood risk in the future as a will need to ensure that flood necessarily a requirement to ensure result of climate change) adopting a risk is not exacerbated from that flood risk is not exacerbated by sequential approach to the location of increased surface water flows new Greenfield allocations. Until the development, as set out in the SFRA Level by ensuring that existing specific details of a strategic flood 2. Greenfield rates and volumes attenuation scheme have been Development sites will need to ensure that are not increased off-site agreed, development sites should be flood risk is not exacerbated from increased through the adoption of multi- able to mitigate the impacts of surface water flows by ensuring that existing functional SuDs. increased surface water run-off rates Greenfield rates and volumes are not The Council will seek to and volumes by attenuating these increased off-site through the adoption of improve flood risk and flows on site. multi-functional SuDs. mitigate for the impacts of More assessment needs to take The Council will seek to improve flood risk climate change within place to confirm the exact nature, and mitigate for the impacts of climate Taunton Deane (and in location and scale of flood risk change within Taunton Deane (and in particular the Taunton urban infrastructure which is required to particular the Taunton urban area) through area) through the provision of reduce flooding and the impacts of the provision of a strategic flood attenuation a strategic flood attenuation climate change in the Taunton urban scheme. Development sites which have a scheme to which area. Without this, the scheme will reliance on the services and infrastructure development sites will need not fulfill the requirements of PPS12 provided by the Taunton urban area will to contribute. A strategic by identifying likely costs, phasing need to contribute to this objective.” flood attenuation scheme, and delivery. The following should be included within the funded by contributions from supporting text for Policy CP8 to reflect our development, is proposed on ongoing discussions and the conclusions of the River Tone between the Green Infrastructure Strategy, SFRA Taunton and Wellington to Level 2 and Inception Study, which are all reduce flood risks key components of the Evidence Base: downstream. “We have been working closely with the Environment Agency who support our long- Add to para 3.103: term objective of reducing flood risk and the “We have been working impacts of climate change in the Taunton closely with the Environment urban area. An initial inception study has Agency who support our been completed which identifies a preferred long-term objective of option of long term storage on the River reducing flood risk and the Tone between Taunton and Wellington to impacts of climate change in reduce flood risks downstream. The Council the Taunton urban area. An will also consider the use of green spaces to initial inception study has contribute to flood alleviation (as been completed which recommended by the Green Infrastructure identifies a preferred option of Strategy and paragraph 3.12 of the Core long term storage on the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Strategy) as well as the modification of River Tone between Taunton existing infrastructure (for example, de- and Wellington to reduce culverting of watercourses and improving flood risks downstream. The existing flood risk infrastructure) to alleviate Council will also consider the flooding.” use of green spaces to contribute to flood alleviation The following amendment to Policy CP8 This proposed amendment omits the (as recommended by the should be included: ‘The Borough Council second and third paragraphs of the policy, Green Infrastructure Strategy will conserve and enhance the natural and which are considered to be important and and paragraph 3.12 of the historic environment, and will not permit should be retained. Core Strategy) as well as the development proposals that would harm modification of existing these interests or the setting of the towns infrastructure (for example, and rural centres. Where other planning de-culverting of watercourses considerations are deemed to over-ride their and improving existing flood importance, development will need to risk infrastructure) to alleviate mitigate or compensate for adverse impacts flooding.” on protected species, river and ground water quality and quantity so that there are no residual effects’.

2. Paragraph 1 of policy CP8 as 2. CP8 needs to make it explicitly clear that 2. The agreed changes recommended by 2. See above currently worded does not reflect the development which will harm the natural Natural England to CP8 covers this point. principles of PPS9 as it appears to environment will not be acceptable unless suggest that development which mitigation and/or compensation is provided would harm natural and historic on, as a minimum, a like-for-like ratio. interests is acceptable if other factors override their importance. CP8 does not articulate the need for mitigation and/or compensation until paragraph 4. 3. The reference to the need to include 3. See above. 3. The agreed changes recommended by 3. See above the provision for circumstances Natural England to CP8 covers this point. where there are over-riding factors should not be included as in the DM process each development needs to be assessed in the context of relevant planning policies and considerations. By accounting for over-riding factors CP8 could be seen as to acknowledge that the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST historic and natural environment are likely to be given less weight. 4. It is not clear why paragraph 3 in 4. Paragraph 3 in Policy CP8 should be 4. This comment and suggested 4. None policy CO8 has been included within included in the supporting text instead in the amendment which seeks to make the the actual policy itself as it may be policy. Also, a diagrammatic map could be policy more concise by omitting better placed in the supporting text, included to show where each of the schemes paragraphs 2 and 3 of Policy CP8 is not allowing the actual requirements of set out in paragraph 3 (and in the Green agreed because the content of these Policy CP8 set out in the other Infrastructure Strategy) are located in paragraphs sets out the requirements paragraphs to be much more relation to development, or make reference within the Bat Consultation Zone and from concise and therefore more effective. to the accompanying Inset Maps. the Green Infrastructure Strategy.

5. Support the intention to retain and 5. Support noted. 5. None enhance green infrastructure assets in paragraph 3, and this particular sentence should be retained. 6. Support for the reference to mitigate 6. The Water Framework Directive is required 6. Support noted. 6. None the impacts of river and groundwater to be taken into account within spatial plans. quality and quantity. Material factors Gwilym Wren on The policy opens the door to The policy requires all assessments to be Paragraph 3.98 makes it clear that in the None Behalf of development affecting the natural and submitted where a Natura or Ramsar site is policy natural environment includes wildlife Milverton Parish historic environment if “other material concerned but really a wildlife survey should sites of international, national and local Council (104) factors are sufficient to override their be a prerequisite of all applications importance. SSSIs are therefore included. In importance”. Without any context as to especially those on greenfield sites. Any taking decisions, local planning authorities what these might be it would make any proposal outside a settlement limit on should ensure that appropriate weight is development in open country or greenfield must pass an integration test that attached to sites of international, national Conservation Areas difficult to oppose. recognises the natural value, maps the and local importance. A wide range of There is no mention of SSSIs which features and incorporates them into a final physical, social and economic material enjoy protection from national layout. This may involve taking more land planning factors have been included in the legislation. This is a regression from but using it more widely. site selection and sustainability appraisal the previous plan where SSSIs along processes which underpin the plan’s with local nature reserves and County proposals for sustainable development. Wildlife sites all enjoyed policy protection. The policy is inconsistent in its treatment of “unallocated greenfield land outside of settlement boundaries” – developments should be designed to integrate with the environment and habitat, not mitigate losses with the odd pond and patch of scrub.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST AONBs 1. Blackdown Hills 1. Comments: 1. None 1. Response: 1. None AONB (177) a) Although supported in principle, a) The Core Strategy should not repeat or there should be reference to the reformulate national policy for nationally additional weight which should be protected landscapes. given to the AONB. b) Noted b) In particular the new green links c) Para 3.107 is factual and does not intend between Taunton and the AONBs or need to explain the purpose of are strongly supported. landscape character assessment. c) The section on landscape character d) At its nearest point Policy SS1 Monkton assessment paragraph 3.107 Heathfield is over 3 kilometres from the appears muddled, and does not Quantocks AONB. There is no conflict accurately reflect the purpose of with the Vision for Taunton. Taunton LCA. Urban Extension Study on page 23 notes d) The point made about none of the that the AONB boundaries are well strategic sites being close enough to beyond the possible location of any urban the AONBs to have any adverse extension and any possible impact on impact is contrary to references in views can be considered as part of the visions for Taunton, Wellington detailed masterplanning. The 2 strategic and some of the site allocation sites at Taunton have been designed to policies regarding setting and views. protect views from the Quantock Hills with the ‘green necklace’ proposals including both a 20m wide buffer of woodland planting around site boundaries and off- site woodland planting. 2. Quantock Hills 2. Comments: 2. Comments: 2. Response: 2. AONB (269) a) The policy fails to make explicit a) The policy should make explicit reference to a) The policy does refer to the AONBs. a) None reference to AONBs. AONBs. b) Although CP8 makes a reference to b) There appears to be a bias towards b) The plan should be read as a whole and b) In fourth para of CP8 add the need for development to mitigate biodiversity and a balance must be struck to Policies SS1 and SS2 include landscape “landscape,” after “adverse or compensate for adverse impacts ensure the landscape is suitably considered. mitigation measures in respect of the impacts on” on protected species etc, no Quantock Hills. Agree landscape be mitigation or compensation added to fourth para of CP8 measures are mentioned in respect of the landscape or townscape and visual impacts or indeed landscape features and elements. There appears to be a bias towards biodiversity. c) CP8 fails to make a detailed c) As Taunton has traditionally been successful c) The Green Infrastructure Strategy has had c) None reference to avoiding an ‘urban in largely avoiding an ‘urban sprawl’ a considerable influence on shaping the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST sprawl’. This is particularly important character, CP8 should include a reference to proposals. The masterplanning for the as poor assimilation of built form into detailed landscape proposals forming an strategic sites makes provision for the the landscape through inadequate integral part of planning applications to implementation of the green infrastructure master planning and insufficient ensure that the sense of containment and in detail as set out in the policies for the structural planting may result in arrival into the town remains a fundamental strategic sites and broad locations for adverse impacts on views from the part of its character. development. protected landscapes. d) Support for the proposal for new d) Support noted d) None green links, improving sustainable access to the Borough’s two AONBs. e) Paragraph 3.107 does not outline the e) The chapter on LCA needs to be addressed e) Landscape Character Assessment has e) None key purposes or principles of as it is inadequate as its stands and should helped to shape the proposals for Landscape Character Assessment outline key purposes or principles of LCA strategic sites. It is not considered and how it forms a useful tool for and how it forms a useful tool for spatial necessary for the Core Strategy to outline spatial planning or indeed for the planning or for the development of the Core the purposes and principles of landscape development of the Core Strategy. Strategy. The purpose of the LCA should not character assessment. These are set out The main purpose of CLA is not to outline landscape designations as it is not in the Landscape Character Assessment outline landscape designations. the main purpose of LCA. of Taunton’s Rural-Urban Fringe (2005) and Taunton Deane Landscape Character Assessment (2011). f) The CP8 is unsound by stating that f) The Core Strategy should not state that none f) See response to 1 d) above. All the f) None none of the strategic sites are close of the strategic sites are close enough the strategic sites are kilometres away from enough to the AONB designations to AONB designations to have any adverse the boundaries of the AONBs. Also parts have any adverse impact as this is a impact as the impact will be wholly of the existing urban areas of Taunton sweeping statement and will be dependent on the exact proposals of the and Wellington are closer to either the wholly dependent on the exact schemes. Quantocks AONB or the Blackdowns proposals of the schemes. Much of AONB boundaries than the proposed the character of the Quantocks Hills strategic sites. AONB is borrowed character taken from views and interrelationships with the Vale of Taunton Deane and development within this area must understand the sensitivities of this relationship. Strategic sites 1. DW Alder Town The supporting text does not mention that None The green wedge policy allows for the None encroach into Planning strategic sites at Priorswood and development of sustainable sites provided the green wedge Consultants on Monkton Heathfield encroach into the the integrity and function of the green wedge Behalf of green wedge and erode it. The Council is maintained. All previous local plans in landowner: South should not be considering sites that Taunton Deane have allocated sites which

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST of Harris’ Farm, conflict with their objectives and policies resulted in the loss of some green wedge Hillcommon when there are better performing sites land, but the objectives of the policy, as set (124) available. out in para 3.104 of the Core Strategy have 2. DW Alder Town not been undermined. Planning Consultants on Behalf of landowner: Broadlands, Trull (140) 3. DW Alder Town Planning Consultants on Behalf of landowner: Cornhill, Wellington (218) 4. DW Alder Town Planning Consultants on Behalf of landowner: Highlands, Cotford St. Luke (252) 5. DW Alder Town Planning Consultants on Behalf of landowner: Foxes Meadow, Wellington (233) Green Pegasus Planning 1. Support CP8 – it balances the need None Support noted. None Infrastructure Group on Behalf for development with environmental Strategy, green of Persimmon conservation and management. The wedge and Homes and principles in the Taunton Deane green necklace Redrow Homes Green Infrastructure Strategy are para 3.114 (348 and 349) supported along with the development of the new country park which is

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST proposed to be provided as part of the urban extensions at Monkton Heathfield and Nerrols. The proposed urban extensions SPD will need to establish in more detail the landscape and nature conservation principles that are to be reflected in the individual development proposals based on the approach set out in the Core Strategy. 2. Hestercombe House Appropriate Assessment identified bat foraging areas. Persimmon and Redrow note that the Core Strategy identifies a Green Wedge to the south and west of Monkton Heathfield urban extension linking to areas which form a green necklace around the proposed development. These areas will enable positive management in conjunction with the strategic site proposals. Green Wedge IJP Planning (169) Objection to the policy CP8 on the basis The Council should undertake a thorough The Green Wedge policy has been reviewed None that the Taunton Deane Green review of the existing areas of Green Wedge to in the context of para 25 of PPS7 and was Infrastructure Strategy appears to treat see if they are still fit for purpose, or if the found to be justified because it is a planning the existing areas of Green Wedge as boundaries can be amended to enable policy to prevent the coalescence of sacrosanct and does not review them to development without affecting the overall settlements and is therefore not just a local see if they are fit for purpose. It is function of the designation. For example the landscape designation. The Green Wedge is acknowledged that there was a review of provision of the additional housing that is not sacrosanct and both this Core Strategy the Green Wedge designations around required during the early part of the plan period and previous local plans have allocated sites Taunton as part of the Taunton Sub Area in order to maintain a 5-year supply of within it. The Wellington Green Wedge Study. However, a similar exercise does deliverable sites. One such site is at land referred to has been reviewed, indeed the not appear to have been carried out in adjoining the A38 and Popes Lane at Core Strategy proposes to extend it relation to the rest of the Borough. The Wellington. The site is considered deliverable northwards. The site referred to is too small policy is, therefore, considered unsound but its falls within an area of Green Wedge that to be allocated in the Core Strategy and the as it is not justified. It also conflicts with seeks to prevent coalescence between green wedge will not preclude an paragraph 25 of PPS7 which states that ‘ Rockwell Green and Wellington. However, assessment of its suitability for allocation as when reviewing their local area-wide there has not been a review of the Green part of the Site Allocations DPD. development plans and LDDs, planning Wedge designation to see if its still fit for

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST authorities should rigorously consider the purpose. Overall the site contributes little to the justification for retaining existing local objectives of designating land as Green Wedge landscape designations. and, therefore, should be considered suitable for development. Green Wedge 1. Greenslade 1. Land at Long Run Farm should not be All three of these sites are too small to be None Taylor Hunt on included in the Green Wedge and the allocated in the Core Strategy. The fact that Behalf of Mr C 2010 SHLAA considered it deliverable they are all within Green Wedges will not Wilkins (422) and capable of providing around 100 preclude an assessment of their suitability for dwellings. It should be allocated in the allocation as part of the Site Allocations Site Allocations DPD. DPD. 2. Greenslade 2. Land at Wild Oak Lane Trull should Taylor Hunt on not be included in the Vivary Green Behalf of Mrs J Wedge and is suitable for allocation in Penny (431) the Site Allocations DPD 3. Greenslade 3. Land north of Gypsy Lane should not Taylor Hunt on be included in the Staplegrove Green Behalf of Haimes Wedge and is suitable for allocation in Family Trust the Site Allocations DPD (429) Woodland Mr J Milward on Policy CP8: Environment Whilst we are We would therefore like to see sixth bullet point Agree amend sixth bullet point. Amend as follows: Behalf of pleased to see the protection effectively of Policy CP8 amended to read - protect “ - protect habitats and QWoodland Trust given to ancient and native woodland habitats and species, including those listed in species, including those listed (18) under sub para f) of Policy CP8 - protect UK and Local Biodiversity Action Plans, and in UK and Local Biodiversity habitats and species, including those conserve and expand the biodiversity of the Action Plans, and conserve listed Plan Area. and enhance expand the in UK and Local Biodiversity Action biodiversity of the Plan Area. Plans, and conserve and enhance the biodiversity of the Plan Area – we would like to see this policy more clearly support the expansion of priority UK Biodiversity Action Plan habitats like native woodland. The UK is one of the least wooded areas of Europe, with just 11.8% woodland cover compared to around 44% for Europe as a whole. The Woodland Trust is therefore working to achieve its ambitious aim of doubling native woodland cover over the next 50 years. Woodland creation is especially important

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST because of the unique ability of woodland to deliver across a wide range of benefits – see our publication Woodland Creation – why it matters. Also quotes from: The UK Biodiversity Action Plan; section 40 of the Natural Environment and Rural Communities Act 2006; Caroline Spelman letter to all Local Authorities calling for support for the Government’s National Tree Planting Campaign; Forestry Commission, The Case for Trees in development and the urban environment (July 2010); The South West Forestry Framework Implementation Plan 2009-2012 (Forestry Commission, 2009); an example of more positive wording on habitat expansion is provided by South Staffordshire Core Strategy publication document - March 2011 Policy EQ1: Protecting, Enhancing and Expanding Natural Assets – The restoration or creation of new habitats and the expansion of habitats in South Staffordshire will be supported where these contribute to priorities in the UK Biodiversity Action Plan and the Staffordshire Biodiversity Action Plan including priority habitats such as native woodland, hedgerows, and lowland heathland. Areas or sites for the restoration or creation of biodiversity priority habitats will be identified through Biodiversity Opportunity Mapping working in partnership with Natural England, Staffordshire Wildlife Trust and Staffordshire County Council. Trees can Mr J Milward on In relation to Paragraph 3.103 Flood Risk, We would like to see Paragraph 3.103 include The final sentence of para 3.103 recognises Amend final sentence of reduce flood risk Behalf of we would like to see reference to the role a reference to the role of trees & woodland in the benefits of green infrastructure for flood 3.103 to read: QWoodland Trust that woodland can play as a water risk flood risk management. storage. The Green Infrastructure Strategy ‘Risk should be reduced by

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST (19) management tool. Trees can reduce the recognises: ”the considerable potential for safeguarding land from likelihood of surface water flooding, when natural flood attenuation through woodland development that is required rain water overwhelms the local drainage and wetland creation” at French Weir for current and future flood system, by regulating the rate at which Country Park and elsewhere. Agreed this management, incorporating rainfall reaches the ground and could be more explicit by adding to the final sustainable drainage systems contributes to run off. Slowing the flow sentence. (SUDS) and using increases the possibility of infiltration and opportunities offered by new the ability of engineered drains to take development to reduce the away any excess water. This is causes and impacts of particularly the case with large crowned flooding, such as making the trees. The Woodland Trust believes that most of benefits of green trees and woodlands can deliver a major infrastructure for natural flood contribution to resolving a range of water attenuation through woodland management issues. They offer and wetland creation, flood opportunities to make positive water use storage, conveyance and change whilst also contributing to other SUDS.’ objectives, such as biodiversity, timber & green infrastructure. Woodland can help adaptation strategies cope with the high profile threats to water quality and volume resulting from climate change. Paras Mrs D Bradley 1. Support 3.105 extension to None 1. Support noted None 3.105,3.107 and (509) Staplegrove green wedge 3.110 2. Disagree with 3.107 that no strategic 2. See response d) to Blackdown Hills site is close enough to affect AONB or AONB above. The SSSI at Quants, SSSI. Holme Moor and Clean Moor and the Somerset Levels are all a considerable distance from the proposed strategic sites. 3. Question the statement in para 3.110 3. This is part of the definition of green ‘protected sites, nature reserves, infrastructure quoted from the Taunton green spaces and greenway linkages Deane Green Infrastructure Strategy. which should where possible, provide multi-functional uses” Health Miss Louise NHS Somerset is disappointed that there None The health benefits of a high quality None Webber on Behalf is a lack of acknowledgment of the environment are recognised in national of NHS Somerset natural environment as a significant policy statements and do not need to be (95) determinant of health. The recently repeated in the Core Strategy. The purpose published government White Paper ‘The of Policy CP8 is to conserve and enhance

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Natural Choice: Securing the Value of the environment and prevent development Nature’ recognises that the quality of the proposals from harming it. In so doing the environment, including the availability of public health benefits of the environment will green space affects people’s health and be safeguarded. wellbeing. As improving public health and reconnecting people with nature will become a future duty of local authority, the value of the natural environment to health needs to be incorporated. The White Paper encourages and supports the formation of Local Nature Partnerships (LNPs). As such, Somerset Wildlife Trust has submitted an ‘Expression of Intent’ to DEFRA’s Local Nature Partnership Fund on behalf of all interested Somerset LNP partners. As such, NHS Somerset recommends that Taunton Deane include within the Strategy, support for the LNP, together with the existing Somerset Biodiversity Partnership (SBP).

83 POLICY SP1 Sustainable Development Locations

ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST Policy SP1 provides the overarching spatial policy None Delineation of 1. Mr Nigel Wright (43) • Text / Key Diagram should make a • Text should be included from for the Borough. It does not define site/allocation Key Diagram 2. Mr James Olney (184) firm commitment to see the M5 as current Local Plan, Policy T1, boundaries. The settlement limit for Taunton is 3. Mr Peter Jones (21) the barrier to long-term development Para 8.2: “The Motorway identified on Inset Map 1, and currently follows the 4. Mrs Candida Adkins (551) of Taunton. continues to act as a strong M5 motorway (as per the local Plan). Henlade and 5. Mr John Thompson (557) physical and psychological are identified as villages in policy SP1 6. Mrs Amanda Knight (547) barrier to the eastwards and (as per the Local Plan) 7. Mr Mark Adkins (555) southwards development of 8. Mr Terence Ravenor (539) Taunton. Development which The Core Strategy’s role is to deliver the ‘Vision 9. Mrs June Ravenor (543) would be physically severed for the Borough’, a key element being 10. Mrs Sally Ravenor (542) from Taunton by the M5 is not employment led growth. 11. Ashleigh Adkins (552) favoured.” 12. Henlade and Stoke Road • The Key Diagram identifies a second • None specified. Policy SP2 (Spatial policy for Taunton) recognises Residents’ Association (545) new railway station west of Taunton. the need for a ‘search’ for a potential new 13. J Hunt (455) Clarification is needed to confirm that strategic employment site for Taunton towards the 14. Mr Brian Thompson (453) this is in connection with the end of the Plan period. This is reflected in policy 15. Mr and Mrs Ashbaugh (456) proposed development Ford Farm SS8. Policy SS8 does not allocate a site (see 16. Mr and Mrs Goldstone (460) and the connection to the railway. above comments). 17. Mrs Karen Ryan (462) (525) 18. Mary Lowe (465) In order to meet the future needs of the Borough, 19. Doug Lowe (470) any allocation would be sought in a sustainable 20. N.R.P Brunt (471) location, with good access to the town centre and 21. Mr Mike Marshall (473) the national route network. This may (or may not) 22. Mr Roy Bulgin (476) require breaching the motorway in a future Plan 23. Ruishton Ladies Coffee Club review. This has already happened (eg Park and (496) Ride and previous planning approvals and Local 24. Ruishton and Plan allocation at Henlade) and elsewhere in the Parish Council (492) UK urban areas lie either side of a motorway. 25. Mr Robert Horn (490) 26. Mr Paul Branfield (488) The Plan may be found unsound if it did not 27. P.J Kiss (487) recognise the potential future needs of the 28. Parish Council Borough and the long lead-in times for (486) development to be implemented without a hiatus 29. T.S McEwen (484) of available land. If land around Henlade is 30. Mrs P Lawton (481) required in future the settlement limit would be 31. Mr and Mrs Glew (458) redrawn (as per current Core Strategy 32. Mrs Nicole Owsianka (479) allocations). Clearly such a site would be beyond 33. Somerset County Council the scale of employment requirements for the (525) ‘needs’ of Henlade/Ruishton residents (or other

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST settlements around the urban edge) but would serve the future employment needs of the County town and surrounding catchment.

The proposed new railway station is that which is being actively progressed by the West Somerset Railway in conjunction with the proposed development at Ford Farm. Please see para 3.82 for more details. Appropriateness 1. PCL Planning on Behalf of • General support to the hierarchy of • None Even prior to closure of the Post Office, Oake did of Settlement The Shapland Trust (151) centres as set out in SP1. (151) not fully demonstrate the characteristics of a Hierarchy 2. Pegasus Planning Group on (204) (394) (441) (437) (426) (419) Minor Rural Centre (since it does not benefit from Behalf of Persimmon Homes • Oake should be recognised as a • Policy SP1 should be a Drs Surgery). Notwithstanding the apparent and Redrow Homes (394) Minor Rural Centre since it can amended to reinstate Oake appetite to retain provision within the village, at 3. Mr John Houghton (204) demonstrate a range of facilities within the list of Minor Rural the time of the Core Strategy’s publication, there 4. Greenslade Taylor Hunt on locally and it fulfils the role and Centres with land East of was no guarantee that the village would Behalf of Mr David Martin function of a service centre for the Saxon Close allocated demonstrate Minor Rural Centre characteristics (174) (452) Parish and surrounding area. through a subsequent Site over the plan period and hence was proposed for 5. Wiveliscombe Parish Council (174) Allocations DPD. downgraded its status to a village. (194) • A comprehensive survey will be Note the concerns of Wiveliscombe Parish 6. Country Land & Business needed to identify how the future Council regarding to ability of the town to realise Association (27) needs of Wiveliscombe and the growth. The SHLAA has identified potential at the 7. Bath & Wells Diocesan Board surrounding community can be town to accommodate growth but quite clearly, of Finance C/O (45, 29) met over the plan period, and further work will be required through the Site 8. Hoddell Associates on Behalf growth be accommodated. (194) Allocations DPD (and possibly as part of a of Comeytrowe Landowners Neighbourhood Plan) to ensure that the town can (33) meet its own needs and those of the surrounding 9. Cotford St Luke Parish community over the plan period. Council (442) • Policy does not adequately reflect • The policy should reflect the Disagree that the Policy does not reflect the 10. Barton Wilmore on Behalf of the Government’s new approach presumption in favour of principles of the NPPF. The Council has retained De Virgo Ltd (413) to sustainable development. sustainable development. existing settlement boundaries for a number of 11. Strategic Land Partnerships Current wording implies that the villages below the hierarchy of major and minor (364) only places where development rural centres within which a presumption in favour 12. Highways Agency (329) can be sustainable is within the of development will apply. In open countryside, 13. Barton Willmore on Behalf of specified hierarchy. This has the there is not necessarily a presumption against The Comeytrowe Consortium potential to create a presumption development, rather such proposals will need to (309) against approving development in be considered against Policy DM2: Development 14. D. Bradley (503) more rural areas, particularly in the Countryside. 15. Greenslade Taylor Hunt on economic development proposals Behalf of Mr G Cossey (426) such as agricultural development 16. Greenslade Taylor Hunt on and farm-based diversification.

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST Behalf of Estate of WG King (45) (27) (441) • Policy should make provision for • The policy should be The Core Strategy does not propose the removal 17. Greenslade Taylor Hunt on amendments to existing settlement amended to reflect the of existing settlement limits. Through the Site Behalf of Mr J Sweeting (437) limits and should not remove retention of all existing Allocations DPD we would anticipate that there 18. Greenslade Taylor Hunt on settlement boundaries from other settlement limits. It should will need to be some provision made to review Behalf of Comeytrowe villages. Such an approach is allow for development existing settlement limits. Landowners (419) inconsistent with the dRSS and beyond existing limits where dNPPF and the Council’s vision for it meets an identified local the Borough which seeks to need that cannot be met improve self-containment and within existing limits. provide essential infrastructure and community facilities. (33) • Cotford should not be regarded as • Amend settlement hierarchy Cotford St Luke is larger and has a better range of a Minor Rural Centre. It should be to remove Cotford St Luke facilities than other villages. It has been identified accepted as a village with further from list of Minor Rural as a Minor Rural Centre on the basis that it does development deemed Centres and place in list of not fulfil the same service centre function carried unsustainable. (442) villages. out by Bishops Lydeard and Wiveliscombe (for • Cotford should be recognised as a • Amend settlement hierarchy example, there is only limited employment Major Rural Centre, consistent to reinstate Cotford St Luke available within the village). Notwithstanding this, with the Regulation 25 Core in list of Major Rural the community does appear to meet with the Strategy. (413) Centres. characteristics of a Minor Rural Centre. With the • Support for the policy which above in mind, it is not considered that it would be accords with NPPF and existing appropriate to recognise the settlement as either policy framework. (364) a Major Rural Centre or a village. • Support for the policy in relation to Support noted. the spatial distribution and location of development proposed to achieve sustainable development. (329) • Whilst Taunton should be the primary focus for growth, any deviation from RSS requirements will need to be justified. (309) • Policy makes reference to further allocations to villages which should recognise that development in small settlements is not viable. • Reference to sustainable, balanced communities should recognise optimum size and

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST critical mass. Appropriateness 1. DPDS on Behalf of Notaro • Inconsistency between wording of • Wording of SP1 should be Comments accepted. There is an unintended Amend first paragraph of of housing and New Homes (396) CP4 and SP1 which refers to amended to state that inconsistency between the wording of CP4 and SP1 as follows: employment 2. North Curry Parish Council ‘about’ 17,000 new homes rather housing targets are SP1. Targets should be expressed as ‘at least’. numbers and (10) than ‘at least’. Reference should expressed as minimum “In order to create and distribution 3. Milverton Parish Council (70) be to at least. (396) requirements. maintain sustainable, (56) • New dwelling numbers for balanced communities, 4. APP Planning Ltd on Behalf individual settlements within the provision will be made for of David Wilson Homes (76) hierarchy should not represent the delivery of new 5. APP Planning Ltd on Behalf ‘ceiling figures’ where further services, facilities and of Gadd Properties Ltd (83) development is supported by local infrastructure including the (85) need. creation of at least 11,900 6. Hoddell Associates on Behalf • New market housing should not be • Wording of SP1 should be Development at Minor Rural Centres will be jobs and about at least of Comeytrowe Landowners restricted to within existing amended to reflect that new identified through the subsequent Site Allocations 17,000 new homes… (33) settlement limits of Minor Rural housing in Minor Rural DPD. Any allocation will not necessarily be 7. Mr Peter Jones (22) Centres. Centres should not be confined to a site(s) within current settlement 8. Parish Council restricted to within existing limits. Where allocations are proposed outside (259) settlement limits. current (Adopted Plan) settlement limits, changes to the Proposals Map and accompanying Insets will be required to incorporate sites within settlement limits. • North Curry Parish Council feel • Amend allocation of houses Text relating to Minor Rural Centres clearly refers that a figure of up to 30 dwellings for North Curry to 30 houses to allocations of up to 50 net additional dwellings. may be more appropriate to North spread over 5 or 6 sites. That is not to suggest that in some Minor Rural Curry. This development would be Centres that provision for 50 units should spread across 5 or 6 smaller sites, • The policy should explicitly necessarily be made, similarly, the policy does not this would ensure development is assert that rural villages will imply that housing provision should solely be met more in-keeping with the character only accept housing that will through one allocated site. Further work will be of the village. (10) benefit the local population. required through the Site Allocations DPD (and • Milverton Parish Council feel that TDBC should discourage the possibly as part of a Neighbourhood Plan) to an allocation of up to 50 dwellings building of executive homes reach such conclusions. (or more – reflecting the capacities in favour of smaller, family The settlement hierarchy as set out in SP1 of developable SHLAA site and orientated properties within reflects the range of services and facilities present extant PP at Creedwell Orchard), the reach of average in the Borough’s towns and villages. This is inappropriate and will cause homebuyers. Affordable information is available separately in xxxxxxx. planning blight and threaten the housing provision should be Policy CP4 as worded in the Published Plan village’s historic and social fabric. encouraged to meet housing states: “New housing should help to contribute Local neighbourhood plans should need defined by local needs towards the creation of sustainable, mixed be encouraged to identify areas surveys. communities offering high quality homes providing where villages can grow for a mix of new housing types, sizes and tenures organically and sustainably in a which meet the needs of the Borough.” It is not

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST sequential manner. (70) considered necessary to explicitly refer to the • Milverton Parish Council question types of housing likely to be required in rural consistency applied in areas. This level of detail may be more identification of the settlement appropriately reserved for a Neighbourhood Plan hierarchy. Why have some or background to a strategic allocation. roughly equivalent villages been included for additional It is considered that a range of up to 50 net development while others have additional dwellings should represent the upward been excluded? (56) limit in Minor Rural Centres. The identification of • Whilst it is helpful to indicate the • Amend policy to make clear preferred sites would prejudge the outcome of the scale of development to be allocations for Minor Rural Site Allocation process and any Neighbourhood accommodated in Minor Rural Centres should not be Plan-making activity. It should be noted that Centres. These figures should not expressed as maximums. whilst the 2010 SHLAA (and previous iterations), be expressed as ‘maximums’, the Alternatively, preferred sites did in some cases, indicate only one potential size of allocation should be should be indicated in the developable site per settlement, all sites, dependent on the size of the plan. excepted and rejected will be presented through centre, level of local facilities and consultation on the Site Allocations DPD with capacity of potential SHLAA site. adequate opportunity for all to be considered and assessed.

• In-light-of housing objection, there • SP1 should be amended to Against RSS Proposed Changes reqm of 21,800, is a need to increase dwelling reflect a requirement of at only 2,280 completions have taken place in first provision to at least 18,500. This least 18,500 new dwellings five years. This means that average annual increase should be met in part with 14,000 at Taunton, and delivery rate would have to exceed 1,300 (1,301) through the accommodation of an provision for an increase of per annum to meet Proposed Changes. additional 1,000 dwellings at a further 500 dwellings in the Para 4.6.19 of Panel Report acknowledges that Taunton with a further 500 shared rural area. whilst the Borough has achieved build rates of across the rural area. (83) (76) 800 dwellings per annum in the past, it cannot be • In-light-of housing objection, there • SP1 should be amended to expected that rate can be significantly exceeded is a need to increase dwelling reflect a requirement of consistently over a 20 year period at Taunton provision to 20,500. This increase 20,500 new dwellings. This itself. should be met in part through the increase should be met in There is no realistic prospect of the RSS accommodation of additional part through the Proposed Changes being adopted into the formal dwellings at Taunton with Broad accommodation of additional development plan. The letter of the DCLG Chief Locations and Strategic Sites dwellings at Taunton with Planner makes clear that the evidence base coming forward earlier in the plan Broad Locations and supporting RSS is still valid. However, in the case period with remaining dwellings Strategic Sites coming of the RSS Proposed Changes, some 35,000 shared across the rural area. forward earlier in the plan representations were made to its consultation and • Stated projections for housing and period with remaining the validity upon which the uplift in housing employment are highly speculative dwellings shared across the numbers was based as never been formally and carry a high scope for error rural area. rebutted by DCLG (nor is it likely to be). The Fordhams LBHP is based upon a locally

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST and variation. • The DPD should derived approach drawing upon over 2,000 acknowledge that growth household surveys undertaken as part of the • Support for the policy as it applies projections will need to be Council’s SHMA. It is contended that by running to Nynehead. (259) kept under frequent periodic the latest ONS projections and replacing local review, over shorter time employment migration elements with primary data periods (e.g. looking no derived from the SHMA before applying the more than five years ahead). Councils jobs-led scenario, the Council can rely This will improve accuracy, upon a realistic but still challenging housing target credibility and relevance of which will meet housing need over the plan period forecasting and the planning and demand arising from the Plan’s aspirations of actions. for growth. The Council does not accept that the ‘true’ figure to be planned for is 18,000 or even 18,500. The report makes very clear that whilst the Council for sustainability reasons would wish to ensure that all those working within the Borough could be housed here, it has no means of ensuring this. Moreover, the total Fordhams figure is 18,038 with the LBHP Report explicitly stating that specialist accommodation requirement should be treated with caution.

Therefore, it is not unreasonable to assume that unless the entirety of the specialist requirement was addressed through the provision of net additional dwellings and all 11,900 jobs were delivered over the plan period that the housing target is sufficient. Particularly since figures are expressed in the Core Strategy as ‘at least’ and taking into account potential changes arising from the NPPF and the likely requirement to ensure a five year deliverable supply of housing land plus 20%. It should be noted that the reference to Fordhams writing off half a years worth of jobs creation is incorrect, Fordhams Addendum was based upon a similar addendum to work previously undertaken by Roger Tym which calculated a target of 11,900 jobs up to 2028. Inconsistency / • Pegasus Planning Group • There is some inconsistency A minor change is required to Comments accepted. Amend Paragraph 4.12 as errors in on Behalf of Persimmon between the wording of para 4.12 clarify the anticipated date of follows: supporting text Homes and Redrow Homes and 3.69 regarding the date at adoption of the Urban Extensions “Site Allocations and

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ISSUE ORGANISATION(S) (insert SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment id in brackets) TEST (393) which the Urban Extensions SPD SPD. Development Management will be adopted Plan Document to be • Somerset County Council • Apparent inconsistency as to adopted in 2014; Urban (526) status of Monkton Heathfield. It is Extensions SPD to be referred to as a secondary focus adopted in 2012 2013” for growth in Section 3.3 but this is not carried through into the Spatial Policy. other issues Quantock Hills AONB (268) • Core Strategy fails to make • Include a reference as The Core Strategy should be read as a whole. None relating to reference to Bishops Lydeard as a noted. Policy CP8 provides ample protection to the detailed policy gateway to the Quantock Hills setting of the AONB, as such no amendment to wording AONB, recognising its sensitive SP1 is considered necessary. location. Rural settlement Mrs Alexandra Munday (on Development distribution is at odds All rural settlements with existing Agreed. The existing settlement limits are retained None boundaries behalf of Bath and Wells with NPPF, Regional Strategy and limits should see those limits around all existing settlements identified in the Diocesan Board) (29) Vision 1, it being important for rural retained in order to allow minor Local Plan. These will be reviewed during the settlements to receive a small amount infill. Small scale development future Site Allocation DPD. Under existing policies of development, particularly economic. should be permitted at the small residential infill can continue and new, small This cannot be achieved with a policy villages and other minor rural businesses locate within or adjoining existing that does not allow for changes to settlements and small businesses rural settlements. settlement boundaries and removes allowed to grow in these areas. boundaries from other villages. Self containment Wiveliscombe Civic Society (297) Development in the area is important None Noted. Wiveliscommbe does have thriving None to keep the community alive but employment estates and an extant concern that the town may just become permission/Local Plan allocation for an additional a dormitory. Whatever is planned must c4.5 hectares remains to be implemented. This be in keeping with the place. should ensure opportunity for continued self containment over the Plan period.

The Council is keen to ensure future development is in keeping with the character and identity of existing settlements. Policy DM4 and the emergence of Neighbourhood Planning will help this to happen.

90 POLICY SP2 Taunton

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Spatial Portrait Somerset County Council Although the Core Strategy is None This information has come from one of None (524) considered sound the first two the SCC transport policy documents. If sentences of paragraph 4.21 sounds SCC wish to propose an alternative an odd formulation and we would wording the Council will agree it. appreciate the opportunity to review how accurately this text represents the evidence on which it is based. Vision for Taunton 1. Blackdown Hills AONB 1. Support for the Vision for Taunton, in 1. Insert “AONB” after Quantock Hills 1. Agree 1. Insert “AONB” after (242) particular preserving the setting and Quantock Hills. Quantock Hills AONB character of the AONB – note there (263) are two of them 2. Quantock Hills AONB 2. SP2 fails to recognise the 2. SP2 should recognise the 2. is not within the 2. None (263) sensitivities of the Quantock Hills sensitivities of the nearby AONB and AONB and at its closest point the AONB and the measures (such as the measures (such as detailed AONB is over 3 kilometres from the detailed masterplanning) that will be landscape masterplanning) that will Monkton Heathfield allocation site. taken to protect their setting and be taken to ensure protection of the Considerable care has been taken character. This is important given the setting and character of the through landscape character extensive amount of development at Quantock Hills, as outlined in the assessment and masterplanning to Monkton Heathfield (which falls vision 2. ensure protection of the setting and within the Quantock Hills parts of character of the Quantock Hills. The West Monkton). green necklace proposed around the allocated sites will include both a 20m wide belt of trees and shrubs and blocks of off-site woodland planting which will create a soft green edge to the urban extensions. Policy SP2 – second 1. Max Hebditch on 1. Culture and sport should be 1. SP2 second bullet point insert 1. Agree 1. SP2 second bullet point bullet point Behalf of Taunton separately identified, and not “culture, sport” after “leisure". insert “culture, sport” after Cultural Consortium subsumed under leisure (which “leisure". (48) includes other pursuits) 2. Mrs D. Bradley (500) 2. Specify culture i.e. recognise niche 2. See comment 2. Agree as above 2. As above (501) (502) markets and need for superior cultural offer based on Museum, Brewhouse Theatre and music. Include tourism 3. Amend to be consistent with PPS4: 3. The policies of the adopted 3. None 3. Montagu Evans LLP 3. The second bullet point is “Focus shopping, leisure and other Taunton Town Centre Area Action

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST (201) inconsistent with the sequential employment growth towards town Plan (TTCAAP) are consistent with approach in PPS4 centre and then other identified PPS4 and will continue to apply until regeneration opportunities outside of the completion of its review, which the town centre delivered through will commence as part of the Site the adopted Town Centre Area Allocations DPD following the Action Plan”. The alternative is to adoption of the Core Strategy. The separate out reference to other suggested amendment is therefore employment growth in another bullet. unnecessary.

Policy SP2 - third bullet 1. Barton Willmore on 1. There is a need for much greater 1. None 1. Greater detail is not appropriate in 1. None point Behalf of the detail on Comeytrowe and it should this SP policy, but is appropriate in Comeytrowe reflect the specific proposals put the SS policy. The suggested Consortium (310) forward by the Comeytrowe changes to SS7 are not supported. Consortium. 2. PCL Planning on 2. Areas for development should be 2. None 2. All areas for development are 2. None Behalf of Shapland subject to masterplanning, but this subject to masterplanning and Trust (152) would be difficult to secure if these piecemeal development in advance allocations were to come forward in a of this is not supported. piecemeal and unregulated fashion. 3. Strategic Land 3. The strategy to concentrate housing 3. If suitable sites can come forward in 3. The Core Strategy only allocates 3. None Partnerships (443) proposals within a small number of the first 5 and probably up to the first strategic urban extensions of 900 very large sites will cause difficulties 10 years of the plan without dwellings and above. Smaller sites in terms of the projected delivery undermining the strategic direction of of below this size have been rates in the first 5 and probably up to the plan, then flexibility must be built identified in the Reg 25 consultation the first 10 years of the plan. into the Core Strategy to enable this on the Core Strategy and Small to happen. Sites Consultation document and the SHLAA. Small sites will be included in the Site Allocations DPD on which work will recommence early in 2012, enabling appropriate sites to come forward within the first five years of the plan and beyond. This range of site sizes and locations will assist delivery and provide a flexible and robust plan. 4. Baker Associates on 4. The housing figures are below that 4. The overall provision at Taunton 4. There is no justification for 4. None Behalf of Barratt plc necessary to ensure flexibility in the should be increased to provide increasing housing provision at (395) approach to housing delivery and “around 14,000 dwellings”. The Taunton to 14,000 dwellings. The choice of sites. Also the distribution provision of dwellings at Staplegrove figure of 13,000 dwellings is

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST between sites is questioned, should be increased to considered to be a very challenging particularly for Monkton Heathfield. approximately 2,000 dwellings and growth target. To accommodate The overall provision for Taunton the site included as a Strategic Site 2,000 dwellings the Staplegrove site should be increased and that for so that delivery can commence on would have to extend further north Staplegrove increased to 2,000 site in the period before 2016. Key than previously envisaged. This dwellings. The phasing should allow Diagram 2 should be amended so would be likely to increase the sites to come forward as strategic that Staplegrove is shown as a landscape impact and could breach infrastructure is provided and there is Strategic Site. the ridge of the Rag Hill special market demand. landscape feature designated in the Local Plan. The Council would not be prepared to accept a figure higher than 1,500 dwellings until a masterplan has been prepared with stakeholder and community engagement which demonstrates that a higher figure can be satisfactorily accommodated. For the reasons set out under policy SS6 it is not considered feasible to bring this site forward before 2016. 5. West Monkton Parish 5. These three objections relate to both 5. None 5. These representations are 5. None Council (411) SP2 and SS1. Concerns relate to considered in detail under Policy Mr J. Reeves, former lack of consultation, the balance SS1. Numerous studies, including Chair of West between homes and employment, transport modelling, from 2004 Monkton PC (403) infrastructure including roads and onwards, which have been the Mr and Mrs M. Besley sewers, traffic congestion, the need subject of public consultation, have (406) for a new M5 junction and concluded that Monkton Heathfield improvements to M5 J25 and the is the most sustainable location for a adequacy of transport infrastructure strategic mixed use urban extension proposed. at Taunton. 6. Pegasus Planning 6. Persimmon Homes and Redrow 6. None 6. The economic viability of the 6. None Group on Behalf of Homes support the spatial vision for proposals has been assessed in Persimmon Homes Taunton as expressed in SP2 and detail as part of the masterplanning and Redrow Homes the strategic site of Monkton work, affordable housing viability (392) Heathfield. It is consistent with the study and the Infrastructure Delivery identification of Taunton as a Growth Plan. More detailed viability Point and the RSS EIP Panel assessments will be carried out as recommendations which were part of the CIL. confirmed by the Secretary of State in the Proposed Changes to the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST RSS. There is a need to ensure that what is proposed is viable and deliverable - in addition to contributing to a significant part of a new Country Park in the green wedge and new woodland planting to mitigate the effect of the development on the foraging area for the lesser horseshoe bats, there is also a range of sustainable transport infrastructure proposed. Policy SP2 – fifth bullet Mrs D. Bradley (500) In relation to provision of facilities See comment Agree, but it would be more SP2 fifth bullet point insert point fails to mention churches, they are inclusive to refer to places of “places of worship” after not just faith centres but worship rather than churches. “community halls” architecturally significant and part of the history and identity of Somerset Policy SP2 Transport 1. Highways Agency 1. Support for the policy in general, but 1. The final two bullet points should be 1. Taunton has only one motorway 1. None bullet points (330) in relation to the final two bullet amended or deleted. junction, whereas much smaller points, detailed transport assessment towns, such as Bridgwater have of development proposals need to be two. The capacity of M5 Junction 25 provided in order to demonstrate that has been recognised as a problem all reasonable alternatives have been for many years by the Highway provided/explored before Authority. The government has consideration of works to motorway identified Taunton as a Growth Point junctions are considered in order to and supported significant future mitigate the impact of development. growth in the RSS. The small size of Also, Circ 02/2007 states there is a the J25 roundabout represents a general presumption against new significant constraint to increasing accesses to motorways other than the capacity of the junction. The for services or major transport Infrastructure Delivery Plan includes interchanges – as drafted the policy provision for improvements to J25. implies that at some point in the Given these existing capacity future a junction may be required. issues, these bullet points simply The policy also fails to provide a identify the need for future justification for the need. improvements to J25 if the town is to accommodate continued growth and to have a future review of the need for a new or improved motorway junction.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST 2. Mrs D. Bradley (500) 2. In the final bullet point reference to 2. See comments 2. It is appropriate to review the need 2. None “review the need” should be to gather evidence to justify strengthened to recognise the need improvements. for Junction 25. The Staplegrove broad location for In relation to the Staplegrove link to development provides the Kingston Road, there are no links to opportunity for a local link, but no link up round south Taunton development is proposed in south Taunton. 3. Somerset County 3. Although the Core Strategy is 3. N/A 3. In relation to the comments: 3. Council (523) considered sound, the following • Henlade bypass is referred to in • None comments regarding technical detail Somerset Future Transport Plan and accuracy: 2011 – 2026, but no alignment for it • Henlade bypass is mentioned in is identified. The Council supports the text, but not shown on key the provision of a Henlade bypass, diagram 2 – it would be useful to but relies on the County Highway clarify whether any land is being Authority to provide a new road safeguarded. alignment before it can be shown on • A second new railway station west the key diagram. of Taunton is shown on key • West Somerset Railway propose a • None diagram 2. new railway station on this land • Para 4.28 – the firm stance on the which they own at approach to development in • Support noted • None Comeytrowe is welcomed, along with a requirement to develop a detailed masterplan in the first instance. • Para 4.31 – suggest the sentence • Suggestion agreed. • Para 4.31 add to end: ends as follows: “with the optimum “with the optimum solution solution being identified and identified and secured through a secured through a robust travel robust travel plan.” plan.”

Key Diagram 2 1. Barton Willmore on 1. The key diagram should be None 1. This representation suggests that a 1. None Behalf of the amended to show a specific site for 2,000 dwellings be allocated Comeytrowe allocation at Comeytrowe (based without adequate community and Consortium (310) on the Consortium’s draft stakeholder engagement or a masterplan) as well as the wider comprehensive masterplan for the area which will be the subject of whole area with potential for 8,000 further masterplanning. dwellings. In 2010 both GOSW and

95

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST PINS advised that Comeytrowe be identified as a broad location for growth and should not be allocated as a strategic site until the totality of the infrastructure requirements to serve 8,000 dwellings was properly understood. To release part of Comeytrowe in advance of agreeing a comprehensive masterplan which has been subject to full public consultation would risk failure to make adequate developer contributions towards provision of the infrastructure required to serve an urban extension of up to 8,000 dwellings. The proposal to allocate 2,000 dwellings now is based on utilising the limited capacity in existing infrastructure systems. This could undermine the viability of major new infrastructure required to serve the urban extension of up to 8,000 dwellings, but also by using up all the existing capacity could prevent small sites in the south western sector of Taunton from coming forward. A piecemeal approach to development of Comeytrowe/Trull would represent cherry picking and is therefore resisted. It is difficult to respond properly to the Consortium’s studies because whilst the representation states that the studies dated August 2011 were submitted, they were not received until September and the Council has had no previous involvement with or knowledge of these studies.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST 2. Strategic Land 2. In the Key Diagram 2 Taunton is 2. The Core Strategy should make it 2. Key Diagram 2 is not on an OS 2. None Partnerships (443) drawn with such precision to run clear that these diagrams are base – it is a diagram. It identifies (444) (363) the risk of being able to identify schematic and that the subsequent strategic sites and broad locations specific sites and locations rather Site Allocations DPD will define for development and does not than being of a diagrammatic and settlement and Green Wedge preclude the possibility that the Site schematic nature. It would be boundaries. Allocations DPD will identify small wrong if a modest site which could sites for development within the be demonstrated to make no Green Wedge. meaningful contribution to the existing or proposed Green Wedge, and was in all other respects suitable and available for development, were to be unintentionally precluded by the manner in which the Core Strategy diagrams are drawn.

97 POLICY SP3 Wellington

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) Spatial Portrait Blackdown Hills 1. Support – paragraph 4.35 and reference 1. None 1. Support noted 1. None AONB in final section of Vision Statement. (243) 2. In 4.44 Blackdown Hills should be referenced in full 2. Replacement of Blackdowns 2. Agreed 2. 4.44…Wellington in view of its with Blackdown Hills sensitive location as a gateway to the Blackdowns Blackdown Hills as well as the rich array of wildlife and biodiversity at the fringe.

Spatial Portrait: “Wellington is the second largest settlement in Taunton Deane Borough and the sixth biggest settlement in Somerset.” Wellington Vision Blackdown Hills It is intended that it is to be the 6th biggest None Reference to Wellington as 6th biggest town “The beautiful market town of AONB settlement in Somerset. is in regard to its current position in Wellington is the second largest in (243) Somerset. This reference should be in the the Borough and the 6th biggest spatial portrait and removed from the vision. settlement in Somerset, supporting a wide rural hinterland extending into adjoining districts to the west and south…” Wellington Vision John Houghton Strong support in particular; None Support noted None (205) (206) New development to be in walking distance of the compact town centre. Developments to be exemplars of green design and construction and respectful of the towns historic buildings, wildlife and landscape setting. Green Wedges between different areas of the town will be retained and enhanced. Natural boundaries to development of Wellington provided by the River Tone to the north. Wellington Vision: Milverton Parish Whilst opening of the station is welcome; 1.There needs to be explicit 1. The Core Strategy through its policies sets 1. None Council concern that this will increase traffic passing acknowledgement of the issue of out how future development will reduce the (66) through Milverton accessing station from increasing traffic on narrow rural need to travel. Transport and traffic rural areas north and west of the village. roads. management is the responsibility of

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) Somerset County Council. 2.The whole strategy talks about 2.A significant number of the Core Strategy 2. None reducing traffic but offers little states how reduction in car travel will be alternative to the car. achieved. See Policy CP6, CP5, CP3, SP1, SP2, SP3, SP4, SS1, SS2, SS3, SS4.

1. TDBC should develop policies 1. The Core Strategy has a significant 1. None and plans that support the use number of policies that support use of of public transport. public transport. 2. This strategy needs to make 2. The Core Strategy commits to increasing 2. None commitments towards the sustainable modes of travel, sustainable development of regular, reliable developments, rail and bus infrastructure. public transport with partners 3. TDBC needs a policy to increase car numbers through 3. The plan supports public transport, but 3. None innovative transport schemes seeks to reduce use of the private car. like Wivey Link, Rural Mini bus, Taxibus service SP3: Wellington as Strategic Land Support – Wellington justifies itself as a None Support noted None a focus for Partnerships focus for development…it is a successful, development (362) cohesive and balanced community. Additional development iwelcomed as a way of ensuring that Wellington continues to be successful.

SP3: Housing John Houghton 1. Strong support for Policy SP3 in particular 1. None proposed 1. Support noted 1. None numbers for (203) the delivery of net additional dwellings. Wellington PCL Planning 2. Not effective. 2,500 additional dwellings 2. On a population pro-rata basis 2. The strategy does not distribute growth 2. Amend SP3, third bullet point: (153) is a significant under allocation and may some 3,500 net additional on a pro-rata basis. The primary focus for • “Deliver around at least 2,500 undermine the certainly of projects such dwellings for Wellington would development is Taunton, with Wellington net additional dwellings…” as the reopening of the railway station. be appropriate. as a secondary focus. The allocation of “around 2,500” is consistent with Wellington’s role and function. It is agreed that “around” be replaced with “at least”. SP3: Flood Risk Environment The reference for long-term potential for Omit reference to long-term The reference to Tonedale was not land Amend last sentence of third bullet Agency Tonedale should be omitted as it doesn’t potential of Tonedale. around the river or Fox Brothers factory site point: “Assuming tThe relocation of (283) relate to the plan period (anticipated beyond but to land immediately north of the railway Relyon and Swallowfield to the 2028). Moreover much of this area is within line. However, it is agreed that latter part of eastern part of Longforth and the functional floodplain (flood zone 3b) where the sentence should be omitted as it does mixed use regeneration of their

99

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) employment use is not permitted. Not not refer to development that would be within existing premises to the include a sufficient justification or evidence to include the Plan Period. new local centre on Station Road has in SP3. been completed, beyond 2028 the Vision indicated longer-term potential for growth to the north of the Town at Tonedale; “

SP3: Railway Network Rail 1. Network Rail notes TDBC aspiration for 1. None 1. Support noted. 1. None Station at (397) the reopening of Wellington Railway Wellington Station and note that it has been included in the Great Western Route Utilisation Strategy as a stakeholder aspiration.

Somerset County 2. Para 4.45 suggests high degree of 2. Acknowledge subject to various 2. Support noted. This is a strategic plan. 2. None Council certainty over reopening of railway station, feasibility studies and would be Wellington is a significantly large town on (519) this would be subject to various feasibility contingent on identifying an operational railway line. Although studies and would be contingent on funding, securing support of rail detailed feasibility studies will need to be identifying funding, securing support of rail industry bodies and gaining undertaken into a future station at industry bodies and gaining agreement to agreement to stop services Wellington informal discussions with the stop services there. We support it but are there. Also reference to locating rail industry suggest that additional train concerned about false expectations. railway station in existing services are likely to be introduced during location would be conditional on the Plan period which would have the studies and relocation of capability to stop at Wellington. Network existing facilities None proposed Rail has also included the proposal for a station at Wellington in a number of strategic documentation. The degree of commitment by local authorities and willingness to use their own powers and resources to help deliver a station is itself likely to influence the prospects of delivery. TDBC has included costs for some feasibility studies in the IDP. SP3: Relief Roads Somerset County The “eastern relief road” is not relieving None Agreed amend ninth bullet point to “eastern Amend SP3 ninth bullet point: Council anything, as it is a residential road. link road” to accord with the description in • “Provide a Northern Relief Road (519) Key Diagram 3 for Wellington as an integral part of the proposed development at Longforth and an eastern relief link road as an integral part of the development at Cades/Jurston; and”

100

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) Key diagram 3 Terence O’Rourke on Behalf of Bloor 1. Alignment of the northern relief road is 1. Key diagram needs to be 1. and 2. The Key Diagram is a reflection of 1. and 2. Addition to glossary: Key Homes not compatible with objective of updated to reflect August 2011 the strategic aspiration for Wellington. It Diagram is a strategic (49) delivering a traditional street (para 5.39) Longforth Farm masterplan is not prescriptive but an indicative representation of development or with ensuring area develops as a prepared by Terrance O’Rourke concept plan. Details of design and proposals. whole inline with principles of good Plc on behalf of Bloor homes. alignment of roads and green wedge are design (para 5.43). Alignment fails to This plan has been subject of for the masterplaning stages of consider topography, sites landscape extensive consultation, it has development. This is to be clarified in an setting, commercial realities of delivering been informed by the findings of agreed addition to the Glossary of the one sided road or lighting implications an environmental impact Plan. for green wedge and protected species assessment and is considered in it. to be consistent with national 2. Extent of green wedge fails to consider policy on nature conservation commercial realities of delivering site issues, justified, deliverable and and need to exclude public access from effective. parts of green wedge 3. Taunton Deane key diagram should not 3. Taunton Deane key diagram 3. No development is shown north of the show any developed part of Wellington should not show any developed River, Lowmoor is located between the to the north of the River Tone since part of Wellington to the north of disused Great Western Canal and the 3. None there is no developed part of Wellington the River Tone River Tone. there.

4. Strong support for the key diagram 3 4. Support noted 4. None John Houghton showing a natural boundary to (206) development along the River Tone north of Low Moor However… General Comment: Mr & Mrs Dickinson Regrettable that small sites available for Inclusion of small sites in the core The Core Strategy sets the strategic None Small Sites in the (72) development within town’s urban boundary strategy. direction for development in the Borough. Core Strategy are excluded…the fact that they do not This does not preclude developers or provide major infrastructure development as individuals promoting submitting applications larger developers do is discriminatory… for smaller sites within the town’s development boundary for development. In addition smaller sites, which are not strategic but above 20 dwellings, may be reflected in the Site Allocations Development Plan document. Any sites for consideration should be sent to The Strategy Unit.

101

POLICY SP4 Realising the vision for the rural areas ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE SUGGESTED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE brackets) Rural Vision Mrs Alexandra Munday The approach focuses solely on Growth will largely focus on The NPPF is currently in draft. It would be wrong to None (on behalf of Bath and defined rural centres, supporting and enhancing base a Plan on proposals out for consultation and Wells Diocesan Board) suggesting all other areas existing sustainable rural which may change. However, consistent with (31) (29) should stagnate. This is contrary centres which act as hubs for existing policy the draft NPPF still seeks to protect to the new NPPF which wider rural community, in and enhance environmental assets and manage the encourages policy to take a addition to small scale patterns of growth to make fullest use of public positive approach to new development in other areas transport (para 19), avoid isolated homes in the development in rural areas. The that will support the countryside (para 113) and reduce carbon emissions Vision fails to recognise that sustainable growth of rural (para 150). The Plan does not prevent development sustainability is not only businesses, promote within existing smaller village settlement boundaries. measured in terms of access to development and Small infill can and will continue. However, it would services. Some development in diversification of agricultural not constitute sustainable development to actively rural villages can help in self businesses and support propose growth in small settlements and hamlets containment. sustainable tourism and lacking shops, schools, bus services etc. leisure development… Rural Vision Gwilym Wren (on behalf An admirable objective. None Within the rural areas these have limited land use None of Milverton Parish However, substantial and implications, although the Council agrees that these Council) (87) imaginative healthcare, social issues also have a role to play within the ‘Big service, educational and Society’. The Vision for the rural areas does already voluntary provision are also refer that “local services and facilities will be retained priorities. and enhanced where appropriate …”. This adequately covers the representation. Rural Vision Oake Parish Council Strong support for the Vision for None Noted. None (196) the rural areas as set out in SP4. Rural Vision D. Bradley (499) The Vision for the rural area None The ‘Vision’ refers to diversifying employment and Amend Policy SP4 makes reference to diversifying enhancing job opportunities. This would apply to bullet 1 (see ref 154 employment but fails to mention tourism. However, for clarity it is agreed to refer below) tourism or gardening. directly to tourism in Policy SP4 bullet 1. See response to submission ref 154 (above) Rural housing DPDS (on behalf of A clearer strategy for the The Plan should include a The Council would refute that the rural areas will None delivery Notaro New Homes) delivery of housing within rural phasing mechanism to have a ‘vacuum’ of housing supply over the period to (351) villages should be incorporated facilitate delivery of non 2017. The rural áreas, including rural centres have a into the Plan. As the delivery of strategic sites within rural number of outstanding commitments, including Local rural housing is through a future villages during the early Plan allocations that have yet to commence. This DPD scheduled for 2014 it stages of the Plan period to should provide a continuing supply over the period raises the question as to how ensure the delivery of a until the site allocation Plan is operational (estimated the delivery of affordable and ‘flexible, responsive supply of 2014). It would be wrong to infer that any allocation market housing will be provided land’. will not be advanced until 2017. The Council

102 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE SUGGESTED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE brackets) over the period 2011-2017 undertakes an annual ‘call for sites’ and is in regular (given small scale residential discussion with developers on advancing sites on takes 2-3 years from inception their merits and in progressing deliverable sites with to completion) minimum delay following adoption of the site allocation DPD. Rural housing DPDS (on behalf of The Core Strategy fails to None See above response (351) None delivery Notaro New Homes) facilitate delivery of non (351) strategic sites within rural villages in the early period of the Plan, thus adhering to national policy regarding flexible land supply (PPS3 para’s 10 and 52). There needs to be a rolling supply of 5 years +20% throughout the Borough and including rural centres. Rural housing Milverton Action Group SP4 makes a generalised None It would be misleading to simply divide a global total None numbers and (114) allocation of 1000 dwellings to by the number of settlements to provide a defensible distribution major and minor rural centres. If total of new dwellings that could/should be provided we assume 600 dwellings in a settlement. distributed evenly over the 8 lower order centres it would Within Milverton for example, an historic consent for result in 75 new dwellings per around 80 dwellings remain an extant permission. settlement which in Milverton’s The SHLAA process does not allocate land nor case is an 11.5% increase in the override existing planning permissions. housing stock which would have a detrimental effect on the Although the ‘Outstanding Heritage Settlement’ for conservation area and status of Milverton was made in the Structure Plan (which will Outstanding Heritage cease to be a valid planning document upon Settlement. In addition, the Plan enactment of the Localism Bill) the Creedwell ignores the SHLAA Orchard site lies beyond the Conservation area recommendation of a modest boundary. However, there is no evidence to suggest extension of 15 dwellings for the that the design of the extant permission would village nor explains why the undermine the conservation area nor the current SHLAA has been ignored. OHS status. Rural housing Andrew Penna (on The policy refers to delivering It is accepted that the totalling of housing Amend 3rd bullet numbers behalf of Gadd 1000 net new homes in the rural requirements for Taunton, Wellington and the Rural point in policy SP4 Properties and David areas. However, policy SP1 Area total 16,500 and not the 17,000 target as to read: Wilson Homes) (77), proposes 13,000 in Taunton and expressed in CP4 and SP1. To this end it is “Deliver at least (84) 2,500 in Wellington which must accepted that the strategic target for the rural areas around 1,000 1,500 therefore leave 1500 for the should be increased from 1,000 to 1,500, this net additional

103 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE SUGGESTED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE brackets) rural area. The overall housing amendment will allow for a greater contribution to be dwellings (including figure for the rural area should made in the rural areas and more fully reflect the existing planning thus be increased by a minimum Coalition Government’s desire to encourage consents and of 500 houses. development in rural areas through initiatives such allocations)” as Community Right to Build, Neighbourhood Plans and Neighbourhood Development Orders.

See also ref 391 below Rural housing DPDS (on behalf of Policy SP4 specifies the Policy SP4 should include Accepted. The policy should read consistently with Amend policy SP4, numbers and Notaro New Homes) housing target for rural areas to reference to the housing policy CP4 and the eventual number may exceed bullet 3 to read: distribution (391) be around 1000 net additional target for rural settlements is 1000 after future windfalls etc are built over the “Deliver around at dwellings (including existing a “minimum” of 1000 net period to 2028. least 1,000 1,500 consents and allocations). This additional dwellings. net additional is inconsistent with policy CP4 See also ref 77 and 84 above dwellings (including which refers to 17000 dwellings existing planning across the Borough “as a consents and minimum”. Policy SP4 should be allocations)” amended to clearly state that the rural housing target is a “minimum” of 1000 dwellings. Rural housing DPDS (on behalf of The Plan should allow for None The future Site Allocations DPD may need to identify Amend policy SP4, distribution Notaro New Homes) additional growth in the rural additional opportunities for affordable housing or bullet 3 (see (391) area where it can be cross subsidy sites to meet future local need which above). demonstrated that such may arise. The proposed wording above allows for development is supported by this (see ref 391 above). local need. It enhances residential choice, improves access to housing and promotes viability of local services. Rural housing DPDS (on behalf of In respect of Milverton, account None Noted. The extant permission for Creedwell Orchard None numbers Notaro New Homes) should be taken of the existing will be taken into account when assessing local (391) permission for 80 dwellings at requirements during preparation of the Site Creedwell Orchard. This should Allocation DPD. be taken into account before seeking to allocate additional sites. Rural housing and Gwilym Wren (on behalf The problem for Milverton Rural housing policy should Paragraph 4.53 refers to the “rural area around None traffic of Milverton Parish regarding housing accessibility seek to deliver a supply of Milverton”, not just Milverton, and is drawn from Council) (67) and road congestion is summed houses that are affordable as Super Output Areas used in the census. Thus for up in section 4.53 (within top well as Affordable Housing. example the rural area around Milverton extends 10% of barriers to access to Normally it is on bigger sites 3.5km west and 5km north (as the crow flies) and

104 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE SUGGESTED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE brackets) housing and service provision). that TDBC can agree a mix of includes farms, hamlets and small villages such as With potential development in house types and price (population c300) which has no shop, pub, the area this will make the brackets rather than on school and 2 busses a week. It is these areas, not situation worse. Growth at smaller village sites. This will Milverton itself which have barriers to accessibility. Wellington and Wiveliscombe impact on small communities. will make the traffic situation A different approach is House prices in rural areas are often ‘unaffordable’ worse. Development at required with CIL for rural and the Council is keen to provide a range of size Creedwell Orchard in Milverton areas, perhaps waiving it in and tenure to meet the needs of residents although (not mentioned in this order to secure a mix of types its ability to control size of units is limited. However, document) will make matters and prices to meet local the extant permission in Milverton (Creedwell worse. What Milverton lacks is a demand. Orchard) provides for a range of 2-4 bedroom supply of housing at the price properties (bungalow and 2 storey) although the range under £400K as the permission predates the affordable housing village is currently unaffordable. requirement. The future site allocation document can allocate a site for cross subsidy or affordable housing to meet any local need. Tourism PCL Planning (154) (on The policy makes no reference The policy needs to Tourism is an important element of the rural Amend Policy SP4, behalf of Shapland to tourism as a major element of acknowledge the benefits of economy, albeit often associated with diversification bullet point 1 to Trust) the rural economy. the tourism industry with of existing businesses. Apart from the West read: more than passing reference Somerset Railway the Borough lacks any large-scale Provide small-scale to rural diversification visitor attraction and due to the high quality of the local opportunities surrounding countryside it is unlikely that other large for employment scale attractions could be accommodated without growth including harming the natural environment. However, it would tourism and rural be appropriate to include reference to tourism as this diversification” would suitably cross reference with policy DM2 (3) Distinctiveness of Quantock Hills AONB Support reference to protecting None Noted. None rural environment (267) and enhancing the local character and distinctiveness of the built and natural environment. Distinctiveness of Milverton Action Group No mention is made to the draft Reference to the draft NPPF Government policy advice for Plan preparation is to None rural environment (114) NPPF to ‘protecting and objective of using the seek to avoid repeating national policy. However, enhancing our natural, built or planning system to protect the Plan should be read as a whole. Policy CP8 historic environment’. our natural, built and historic (Environment) does refer to conserving and environment should be made. enhancing the natural and historic environment. Rural employment Milverton Action Group The policy gives no indication of None Milverton provides a wide range of local services (eg None (114) how employment within or near shops, school, community facilities). It is also on a lower order settlements is to be public transport route with at least 8 busses in both practically augmented, resulting Taunton and Wiveliscombe directions per day, in an inconsistency between providing good access to local and wider

105 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE SUGGESTED COUNCIL RESPONSE PROPOSED comment ID in SOUNDNESS TEST CHANGE brackets) policies SP4 and SO4 – employment. Whilst there is limited employment reducing the need to travel. within the village (eg saw mills and herb farm), policy DM2 allows additional small scale employment provision adjoining such rural centres. There is no inconsistency between policy SP4 and SO4 (actually SO6) in allowing implementation of an extant housing permission and pursuing development patterns that reduce the need to travel. Rural service D. Bradley (498) Policy SP4 refers to Churches should be included Reference to shops and community halls are simply None provision encouraging provision of in policy SP4. examples of “services” and is not inclusive. It would additional services such as not preclude churches, or a range of other service community halls. Churches provision if the need arose. should be included as these were once community buildings and they need to recover this function.

106 POLICY SS1 Monkton Heathfield ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Support for urban Andrew Penna (on Support the allocation at Monkton None Noted. None extension behalf of David Heathfield. The site has been Wilson Homes) (78) extensively tested as a strategic location through the RSS and a series of other studies. Support for urban Baker Associates (on There is much supporting evidence that None Noted None extension behalf of Barratt plc) this is an appropriate location for (400) significant new development.:, Support for urban Pegasus Planning (on Support for the principle of policy SS1. None Noted None extension behalf of Persimmon / Many planning assessments have Redrow) (399) identified Monkton Heathfield as the future direction for growth and the Core Strategy identification is a sound proposal. Strategic highway Highways Agency Support for policy SS1. The HA do not None Noted. None support (331) anticipate any major issues arising. Strategic highway Pegasus Planning (on Note the Highways Agency preference None Agreed. None support behalf of Persimmon / for development to be located in centre Redrow) (399) and north of the town and supports the 3 Regional Funding Allocations identified in the Topic Paper. If these funding allocations are not forthcoming work needs to be in place to find other ways of securing funding of development. Traffic impact of Mr and Mrs RF The provision of transport infrastructure To accommodate the A range of detailed studies and modelling work None urban extension Cornish (24) and facilities to cope with the increase occupants of 5000 homes covering the transport requirements for the Core in population of Monkton Heathfield is on top of the other traffic Strategy and the urban extensions have been woefully inadequate. Those working trying to reach Taunton a undertaken over recent years including the Taunton locally will be small. Those who chose radical rethink of the Transport Strategy Review 2. The County Council have to go to Taunton for work, recreation or transport proposals are confirmed that the broad approach taken by the Core shopping by car will travel along the required. Even if very Strategy is appropriate from a transport planning A38 or A3259, both already busy. There significant widening and perspective (letter dated 22 August 2011) as have the is nothing to suggest roads will be other improvements were Highways Agency (by letter dated 16th June 2011. widened or radical changes to Creech made to the A38 and More detailed work will inform the SPD and a full Castle. It is not realistic expecting the A3259, this must not be Transport Assessment would be required with any problem to be solved by an increase in allowed to simply kick the submitted planning application. people walking or cycling. There will be problem down the road to congestion and people will look Creech Castle/Priorswood elsewhere for their shopping and leisure and beyond. It is

107 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) (eg Bristol and Exeter) necessary to look at the whole road system in Taunton. Highway issues Strategic Land Bullets 11-15 (Highways) will not make Delete these bullets The existing road infrastructure will be used where None Partnerships (381) the development more sustainable. practical and new roads constructed only where There shouldn’t be reliance on a required. The bullet point referred to reflect the predetermined access and highway Councils evidence base which has been tested and network. The default position should be agreed with the County Highway Authority. to use the existing road infrastructure and only build new roads where needed. Transport John Reeves (402) The delivery of infrastructure None A range of detailed studies and modelling work None infrastructure Max and Jaqui Besley requirements have not been thought covering the transport requirements for the Core (405, 403, 407) through. Poor consideration has been Strategy and the urban extensions have been Sarah White (407) given to traffic increases. There is undertaken over recent years including the Taunton Mrs Tricia Cavill already considerable congestion on Transport Strategy Review 2. The County Council have (West Monkton Parish A3259, A38, Creech Castle/Bathpool, confirmed that the broad approach taken by the Core Council) 410 A358/M5(Junction 25), Junction 24 Strategy is appropriate from a transport planning proposals in Bridgwater and this perspective (letter dated 22 August 2011) as have the development will exacerbate matters. Highways Agency (by letter dated 16th June 2011. The park and ride will be inadequate for More detailed work will inform the SPD and a full the scale of development and traffic Transport Assessment would be required with any already entering from Bridgwater. submitted planning application. Not against growth of Taunton but if it is to grow something must be done to Junction 25 and this linked to a workable ring road system. Simply adding 3 park and ride schemes is not good enough. New motorway Somerset County Welcome wording in paragraph 5.11 None Noted None junction Council (520) making clear that J24a is not needed to deliver the Core Strategy. Views to an AONB Quantock Hills AONB Policy SS1 fails to make reference to Policy SS1 should refer to This comment rather relates to paragraph 5.16 which None (266) protecting the views of the Quantocks. protecting views towards refers to protecting views south from the Quantocks. the hills in the masterplan This is entirely appropriate, as you will look down on as well as the already the development area and hence a landscaped stated views south, from belt/edge is sought. This is less relevant from the the hills development itself as this landscaped setting would not be visible from within most of the development. Actual views of the Quantocks from within the development itself are more of a detailed design issue to be covered

108 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) in the SPD or through development management. Impact on an AONB Quantock Hills AONB Although paragraph 5.16 recognises The policy should The extent and form of the landscaped belt around the None (266) the concept of a green necklace around incorporate significant tree development has been set following a range of the north to protect views from the planting and other meetings with specialists including the Borough and Quantocks the policy fails to provide landscaping to buffer County Councils, Natural England and Somerset significant tree planting and other development views from Wildlife Trust. The precise form and alignment of the landscaping to buffer development from the Quantocks development edge is a matter of detail, more the Quantocks. It is essential to avoid a appropriately addressed in the SPD. There will also be hard/abrupt interface between the farmland, hedgerows etc between the development urban and rural environment. boundary and the Quantocks providing a further natural ‘buffer’. Impact on an AONB Quantock Hills AONB The Core Strategy fails to make Reference to both day and Monkton Heathfield is not on the Quantocks. It is a None (266) reference to both day and night time night time views of the settlement of around 1500 dwellings already and on views as impact on the dark night skies Quantocks should be the edge of the urban area of Taunton. There will of the Quantocks have not been taken made. already be a degree of light pollution when viewed from into account. the Quantocks. The form of lighting from any new development is a detailed matter more appropriately covered in an SPD or through development management. Flood risk Environment Agency The policy is sound but suggest that Local flood risk Noted. This is a matter of detail more appropriately None improvements (282) local flood risk improvements for improvements for Bathpool addressed in the SPD or through the development Bathpool area are made within the area are made within the management process. country park through sympathetic country park through landscaping sympathetic landscaping Housing delivery Barton Willmore The Council will need to prove the None As a result of recent masterplanning work and SS1 Technical change. (on behalf of reasonableness of its assumptions in meetings with Persimmon and Redrow to agree the Amends “5,000” to Comeytrowe respect of deliverability . delivery assumptions, these have been revised and “4,500 new homes” and Consortium) (311) the Council has reduced Monkton Heathfield to 4,500 Table 5.1 dwellings. The UI commission includes work on economic viability and housing delivery (Taunton Urban Extensions Strategic Sites Delivery Plan April 2011 – document included in the revised evidence base). It is not considered that the comparative None The Urban Extension studies in 2004 and 2005 both None advantages over the Comeytrowe site concluded that Comeytrowe was the second most are significant. sustainable urban extension after Monkton Heathfield. However masterplanning and public consultation on Comeytrowe has not progressed to a comparable stage . Housing delivery Baker Associates (on The policy suggests delivery of around None The more recent Urban Initiatives work for the Core None behalf of Barratt plc) 5000 dwellings but partly relies on Strategy identifies over 150 hectares of residential land

109 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) (400) evidence from Bakers (2005) at Monkton Heathfield and supercedes the work of suggesting that only 3,500 dwellings Bakers in this respect. might come forward and on only 70 hectares. Housing delivery Baker Associates (on Delivery of the suggested 5000 houses None As a result of recent masterplanning work and See technical change behalf of Barratt plc) appears unreasonable. The Council meetings with Persimmon and Redrow to agree, the above (311) (400) suggest that this level has been tested delivery assumptions, these been revised and the by Urban Initiatives (paragraph 5.8) but Council has reduced Monkton Heathfield to 4,500 is not publicly available so the findings dwellings. The UI commission includes work on cannot be tested. economic viability and housing delivery (Taunton Urban Extensions Strategic Sites Delivery Plan April 2011 – document included in the revised evidence base). Housing delivery Baker Associates (on The Baker 2005 study identified a Reduce the overall The revised figure of 4,500 homes averages out at See technical change to behalf of Barratt plc) delivery rate of 350 dwellings per capacity for the Monkton about 280 dwellings per annum. The Plan assumes a Table 5.1 above (311) (400) annum. Today, around 250 dpa would Heathfield site to a more slower rate of delivery in the first five years of about be more realistic, however, the reasonable level to reflect 1,000 dwellings, about 1,600 in the next five years and Implementation and Monitoring section the constraints and speed about 1,900 in the final six years. suggests rather higher levels. Thus, with which dwellings might there are serious questions about the be delivered within the level and timing of delivery of this Plan period. strategic site. This will need to be subject Not agreed. None to further discussion once evidence from the Council is released. Housing delivery Pegasus Planning (on Support the delivery of 5000 new Delete the housing delivery See response above. It is agreed that market and See technical change to behalf of Persimmon / homes but object to the land use targets set out in Table 5.1 economic circumstances affect delivery rates. The Table 5.1 above (311) Redrow) (399) targets set out in Table 5.1 The market and economic assumed figures are not intended to restrain or cap the (Implementation and Monitoring). circumstances will affect housing achieved at the urban extension. Phasing is considered to be the delivery rates. inappropriate as the market and economic conditions will influence the number of dwellings built. Affordable housing Pegasus Planning (on The 25% affordable housing target for Amend second bullet point The UI commission includes work on economic viability None and viability behalf of Persimmon / the 4000 homes must be subject to to read: “25% of new and affordable housing (Taunton Urban Extensions Redrow) (399) viability. homes to be affordable Strategic Sites Delivery Plan April 2011 – document homes in line with Policy included in the revised evidence base). CP4: Housing and subject to viability;” Community Pegasus Planning (on Persimmon/Redrow must be involved in None Agreed. A range of stakeholders, including None Infrastructure Levy behalf of Persimmon / the process of reassessing Persimmon/Redrow are involved in developing

110 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Redrow) (399) infrastructure requirements with Urban proposals for Monkton Heathfield and CIL will likewise Initiatives to ensure the development is also include thorough public consultation. viable and consistent with CIL Regulations 122 and 123 and the NPPF in terms of viability and deliverability. Requirements and Pegasus Planning (on The SPD will be the vehicle to assess A specific reference to The UI commission includes work on economic viability None viability behalf of Persimmon / and determine the scale and type of viability is required in the and infrastructure costs (Taunton Urban Extensions Redrow) (399) community infrastructure but it is noted policy Strategic Sites Delivery Plan April 2011 – document that the Core Strategy and IDP set out included in the revised evidence base). the broad requirements. There is a need to take account of the viability of the development proposal in its entirety reflecting the infrastructure costs and opportunity for public/private arrangements to deliver certain components. Progression of SPD Pegasus Planning (on There is a need to progress the SPD so None Noted. Work is well underway on the SPD and None behalf of Persimmon / that planning applications can be Redrow/Persimmon and a number of other Redrow) (399) prepared and submitted to meet the stakeholders are fully engaged in the process. needs of the area and maintain land supply. This is particularly important in light of NPPF effort to boost housing supply by 20% in order to maintain a rolling supply of deliverable sites. Progression of SPD Pegasus Planning (on Reference to preparation and adoption Amend 11th bullet point to The policy sets out what will be required as a result of None behalf of Persimmon / of SPD is welcomed as is the inclusion read: the site being developed, not necessarily from a Redrow) (399) of a masterplan and design codes. Proportionate particular developer. Other parties may also be Redrow/Persimmon will engage in the implementation of the involved. The current wording is therefore correct. preparation of the SPD to ensure the A3259 corridor strategy” development is achievable and Amend 12th bullet point to deliverable. read: Proportionate improvements to the A38 to transform it into an urban street” Progression of SPD Pegasus Planning (on Broad support for the concept plan as Amend paragraph 5.14 Agreed, although this would be more appropriate as a Amend Plan with an behalf of Persimmon / set out on page 73 but it needs to be with a final sentence to new paragraph (after 5.16) as the SPD is not currently additional paragraph to Redrow) 398 flexible so it can be refined and guided read: referred to in the ‘Justification’. read: by more detailed work to determine “...with Policy CP7: “The concept plan for internal boundaries and the various Infrastructure. The concept Monkton Heathfield land uses. plan for Monkton shown on page 73 is

111 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Heathfield is evolving and evolving and further further engagement on the engagement will take concept plan will take place as the Masterplan place as the SPD is and SPD is progressed prepared and in the to guide the submission preparation of the planning of any planning application. The plan must application. The plan be viable and deliverable. must be viable and The justification for the deliverable and result in distribution of land uses a coordinated approach will be supported by the to development. The evidence base for the justification for the development of Monkton distribution of land uses Heathfield” will be supported by the evidence base for the development of Monkton Heathfield”. Energy reduction Pegasus Planning (on Persimmon and Redrow support the None Noted. However, government guidelines are likely to None and viability behalf of Persimmon / approach for new homes to be energy continue to be incorporated through Building Regs and Redrow) (399) efficient and built to government thus ‘non negotiable’ in terms of viability. guidelines to reduce carbon emissions as long as this produces a viable development proposal. Energy efficiency Strategic Land Bullet 7 (energy efficient) is not needed Delete as it is covered by National policy seeks a reduction in carbon emissions. None Partnerships (381) as it is covered in national policy national policy This can be sought in a variety of ways including renewable energy production. The Councils approach in the first instance is to seek a reduction in the need for energy as the priority. Energy supply Strategic Land Bullet 9 is an admirable aspiration Replace with a policy to The Councils evidence base suggests that the most None Partnerships (381) however energy policy means that provide a percentage of cost effective way of hitting carbon reduction targets consumers have the right to pick energy needs from would include a communal energy supply to serve all electrical supplier. renewable resources, as or parts of the development. It will be for the developer foreseen in the draft RSS to ultimately determine how requirements are delivered. This would not prevent an occupier from choosing his own electrical supplier as most energy centres would remain connected to the national grid. Park and ride Pegasus Planning (on It should be noted that development at Amend 10th bullet point to The policy sets out what will be required within the None behalf of Persimmon / Monkton Heathfield will help facilitate read: allocation, not necessarily from a particular developer. Redrow) (399) the park and ride, but not itself require “Facilitate Provision of a Other parties may also be involved. The current park and ride. Any contributions must ‘park and ride’ site south of wording is therefore correct. therefore be proportionate and viable. the A38 ...”

112 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Green necklace Pegasus Planning (on Concerns about the use of green None The ‘green necklace’ will provide a range of functions, None behalf of Persimmon / wedges/ green necklace and the including mitigation for bats, strategic landscaping to Redrow) (399) justification for these in the current mitigate the visual and environmental impact of the concept plan. This needs to be allocation and for recreational space for the urban addressed in the evidence base. extension that would otherwise have been required within the ‘development area’. Plan boundaries Pegasus Planning (on The concept plan appears to conflict None The concept plan is intended to illustrate the principles The Glossary should behalf of Persimmon / with the red line boundary as indicated of the proposed development, but not the precise include a definition of Redrow) (399) on the Site Boundary Plan. disposition of the development area and green wedge. the Concept Plan to clarify that it illustrates the principles of development but not the precise disposition of land uses.

Development Mrs Tricia Cavill A further 600 houses west of Greenway None The proposed housing west of Greenway will assist in None boundary (West Monkton Parish represents an incursion into the green securing the Country Park as it partly falls within the Council) (410) wedge, threatening wildlife and at odds same ownership and meeting the Plans housing with the Local Plan. requirements without affecting the integrity of the green wedge. Monkton Heathfield will still remain over 600 metres from Maidenbrook at this point and any required mitigation measures for wildlife made through a detailed appraisal accompanying any planning application. Densities Strategic Land Bullet point 1 is welcomed for use of the None This is the overall average density anticipated across None Partnerships (381) word “phased” but concerns about the the site. Some areas (outer) will be higher and some appropriateness of identifying a density (towards the centre) lower but overall, it is considered of 35-40 dwellings per ha. that such a range would be appropriate and in keeping with the character of the area. It is however a guide. Relevance of Strategic Land Use of the phrase “efficient use of land” None The term ‘efficient use of land’ is not used in policy None ‘efficient use of land’ Partnerships (381) should be deleted and reliance placed SS1. However, it is an appropriate term (as used in on Policy SP1 as applications are policy SP1), recognised in the context of sustainable received as the market is bound to development, It is especially appropriate within an change over the Plan period. urban extension, reducing the need for release of additional greenfield land and where the aim is to design an environment that provides easy access to

113 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) local services without the need to use a car. Relevance of stating Strategic Land Concern at whether it is appropriate for Reword to state This reflects the evidence and established formula for None required school Partnerships (381) the Core Strategy to identify the number appropriate provision. calculating requirements from new development provision of new primary and secondary schools received from the local education authority. needed (including bullet 5 of policy SS1) Relocation of cricket Strategic Land Bullet 8 (cricket club) will only apply if None Noted. However, the cricket club have sought to None club Partnerships (381) the cricket club wish to relocate. relocate. Evidence base John Reeves (402) Data used as evidence is based on the None The census only occurs every 10 years so in part, this None Mark and Jaqui 2001 census which is 10 years out of is correct. However, a range of other ‘evidence’ has Besley (405) date. been used in the Plan including mid year estimates, Sarah White (407) annual monitoring of development activity, surveys and Mrs Tricia Cavill (on other studies and research. The evidence base is as behalf of West accurate as it can be in the circumstances. Monkton Parish Council) 410 Age profile of new John Reeves (402) How will the community support itself None The population nationally is ageing. The Council None residents Mark and Jaqui when apparently a third of the homes cannot prevent certain age groups living in Taunton but Besley (405) will be occupied by the elderly? can seek to provide land and the economic Sarah White (407) environment to attract a range of job opportunities Mrs Tricia Cavill (on which attract a locally wide age profile to ‘support’ the behalf of West community without the need for significant in- Monkton Parish commuting and hence reduction in self containment. Council) 410 Non allocation of G Cossey (427) Support the proposal. Also offer site None This site is constrained by lesser horseshoe bat None adjoining land MHea/1 as a short term housing site foraging and therefore requires off site woodland planting to be established before it can be developed. Non allocation of St Margarets Object to the land south of Aginghills (Assume) extending Land south of the proposed western relief road was None adjoining land Somerset Hospice Farm Local Plan allocation (and subject proposed urban extension dismissed by the Planning Inspector at the Inquiry into and friends of of recent planning application for allocation the Local Plan. This is a critical part of the green Musgrove Park (439) residential) to be excluded from the wedge, already on one of its narrower parts, acting as Core Strategy allocation and included a buffer to maintain the separation between Taunton as green wedge. The Local Plan and Monkton Heathfield. Proposals to develop on land recreational space allocation at to the immediate west of this has been dismissed on Maidenbrook provides sufficient appeal twice. This green wedge also provides a range landscape buffer from Taunton. of other functions including a wildlife corridor, a ‘tool’ to Residential proposals to the north and reduce the heat island effect from the surrounding south of this site and the western relief urban area and a landscape setting to the road will reduce the benefit of classing Taunton/Bridgwater canal, forming open, sloping land this as green wedge. containing the urban extension on a plateau beyond. Creation of Somerset County Core Strategy is sound. However, None The County Council have specified a range of None

114 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) walking/cycling Council (520) would suggest that the walking/cycle improvements for inclusion in the IDP, routes creation/enhancement of including improvements between the urban extension walking/cycling routes from Monkton to and Taunton centre. It will not just be the responsibility the town centre and railway station of the Monkton development to fund these links and should be required in policy and include thus it remains more appropriately covered through the a target (50%) of trips generated within IDP. the new neighbourhood by car and included within Table 5.1 Why is Monkton Mrs Tricia Cavill (on TDBC have worked with the community None The larger proposed urban extension at Monkton None Heathfield the behalf of West for 1000 houses, but since then we Heathfield has been in the public domain and preferred location? Monkton Parish haven’t been consulted at all as a local consulted on for a number of years: Council) (410) community. There was no clearly The Taunton Vision Commission 2002 proposed a Mark & Jacqui Besley defined point in the process when coordinated study of settlement growth which led to the (404) Monkton Heathfield was clearly Taunton Urban Extension Study (Terrence O’Rourke identified for additional growth. Why 2003/04) which weighed the comparative advantages aren’t our comments being taken into of locations, concluding in favour of Monkton account? The community is being Heathfield. The study included a range of consultation presented with a ‘done-deal’. There is events in June and September 2003 and public no Plan B exhibition in Nov/Dec 2003. Monkton was the preferred area of search and the only area with over 50% support. This was followed by the Taunton Sub Area Study (2004/06, Baker Assoc), looking at a range of options for Taunton’s growth and concluding in favour of an urban extension at Monkton Heathfield. This also included a well attended public meeting in St Andrews Hall and consultation with community groups and Councillors. The Baker report was agreed in 2005 as submitted advice to the draft RSS which itself was subject to an EIP in 2007, followed by commencement of the Core Strategy and Reg 25 consultation in Jan/Feb 2010 which included a public exhibition at Monkton Heathfield. The Council considers that there has been a clear process of evolution, a range of studies and options/alternative proposals considered and the public informed throughout the process over the past c8 years. Alternative locations Mrs Tricia Cavill (on Why not build some of the houses at None See above. Other areas of Taunton will experience None for urban extensions behalf of West Comeytrowe or east of the motorway? growth, including Comeytrowe which is proposed to

115 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Monkton Parish What makes Monkton Heathfield so commence post 2016 and will ultimately be larger than Council) (410) much better? Monkton has had its the Monkton Heathfield urban extension share of growth. Alternative locations Mrs Tricia Cavill (on Why not build a separate new town None It is more economically viable to build on existing None for urban extensions behalf of West rather than foister 4000 additional infrastructure (eg roads, schools etc) than create totally Monkton Parish homes on the community? new settlements. After town centre regeneration sites Council) (410) government policy recognises urban extensions as the most sustainable option. Alternative locations Mrs Tricia Cavill Why is the motorway regarded as such None Land east of Junction 25 has a number of constraints None for urban extensions (West Monkton Parish a physical barrier? Towns like Watford, including access and flooding which are extremely Council) (410) Dunstable and Luton have a motorway costly to resolve and could make delivery unviable, through them (M1) which doesn’t divide especially in the current economic climate. The Council the community. has not dismissed land to the east of Junction 25 for longer term growth (see policy SS8) but recognises that detailed longer term work is still required which will be covered in a future Plan review. Alternative strategy Mrs Tricia Cavill (on Why not put more houses in the villages None In addition to Taunton and Wellington the Plan None for growth behalf of West such as and proposes residential development in major and minor Monkton Parish Ruishton? rural centres which does include a large number of Council) (410) villages including Creech St Michael (part of the Monkton Heathfield urban extension also lies within Creech Parish). Policy SP1 refers. Within the smaller villages lacking a larger range of local services (such as Ruishton) smaller scale development will also be allowed within the settlement limit. The future Site Allocations DPD will provide more detail on location and numbers within the villages. Employment Mrs Tricia Cavill (on Houses aren’t a problem if we have None The Council can only make provision for employment None projections behalf of West jobs. Better links are needed to grow (and housing) land to come forward for development. Monkton Parish Taunton. How can the strategy be Growth in jobs over the Plan period whilst clearly Council) (410) employment led when the houses are dependent on market forces is evidenced from a coming first? Where is the evidence of number of sources including the Roger Tym Study job led growth? (2010) and the Councils Economic Development Strategy. Establishment of the LEP’s and local delivery teams will also work to integrate economic growth with Core Strategy proposals and will have a more direct role in job promotion. Employment John Reeves (402) Where are the new jobs coming from? It None The Roger Tym study notes that it is important to view None provision and Max and Jaqui Besley is doubtful many will be within walking the economy as cyclical. In the longer term, economic accessibility (405) distance of houses and thus more traffic and job growth is based on an overall annual increase Sarah White (407) problems. in GVA of around 2.8%. This is lower than the national

116 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Mrs Tricia Cavill (on 3% pa figure over the period 1996-2006 but is behalf of West considered a realistic target as the south west often Monkton Parish performs slightly better than the UK economy and as a Council) 410 focus for growth in the south west, Taunton should likewise be anticipated to perform well . Jobs will come from a range of sectors (see Core Strategy Table 3.1). The focus for employment growth will be the town centre, and at Monkton Heathfield; both with good public transport links and within walking distance of significant residential populations. This will reduce the need for private car use to access jobs. Employment land Mrs Tricia Cavill (on Why would 1000 homes require 14 None The Core Strategy proposes around 22 hectares of None behalf of West hectares of employment land yet raising employment development at Monkton Heathfield (and Monkton Parish it to 5000 homes would only require a further opportunities within the District Centre, eg Council) (410) total of 12 hectares? offices), not 12 hectares. An additional c10 hectares are identified for potential longer term growth opportunity at Walford Cross. It is also important to stress that the employment allocations, whilst providing local employment opportunity, are not purely for the needs of local residents, rather contributing to the wider growth requirements of the Taunton area Affordability Mrs Tricia Cavill (on Low paid employment mean that the None An aim of the Economic Development Strategy is to None behalf of West people will not be able to buy better raise the skills base of the local population and quality Monkton Parish homes, so the Plan is contradictory. and range of job opportunity, raising the average Council) (410) incomes to at least the regional average over the Plan period. Timing of Mrs Tricia Cavill (on The infrastructure (including roads and None Provision of infrastructure will be required at the None infrastructure behalf of West sewers) should be put in place first. appropriate time to cope with the scale and/or phasing Monkton Parish of development. This will be set through a legal Council) (410) agreement secured with the relevant authority (eg Highway Authority for road provision). However, it would not be legally acceptable to make requirements in advance of its need and could also jeopardise viability of the project.

117 POLICY SS2 Priorswood/Nerrols

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Site delivery A planning application for Nerrols is None In 2009 the Council recognised the None 1.DW Alder Town now being considered by the Local urgent need to address the five year Planning Consultants Planning Authority. The landowner is supply of deliverable land for housing. on Behalf of the Crown estate, who have a record of The Local Development Scheme, May landowner: South of holding back site delivery until the 2009 proposed an interim release of Harris’ Farm, optimum price can be achieved. sites in 2010 following the Regulation Hillcommon (126) Therefore the site is not likely to be 25 public consultation on the Core 2. DW Alder Town available for development until the Strategy and small sites. Following a Planning Consultants housing market is more secure. favourable consultation response and on Behalf of detailed discussion with the landowners landowner: and developers, in June 2010 Interim Broadlands, Trull Sites for 300 dwellings each at Nerrols (142) and Cades were released to contribute 3.DW Alder Town towards the shortfall in the 5 year Planning Consultants supply of housing land. Planning on Behalf of permission has been granted at Cades landowner: Cornhill, in Wellington and an application has Wellington (220) been submitted for a first phase of 4.DW Alder Town Nerrols. From discussion with the Planning Consultants Crown and their agents we have every on Behalf of reason to believe that the first phase of landowner: Highlands, Nerrols will contribute as intended Cotford St. Luke (254) towards the 5 year supply of housing 5. DW Alder Town land. Planning Consultants on Behalf of landowner: Foxes Meadow, Wellington (235) Renewable energy Strategic Land The policy is considered sound but This bullet point should be replaced by There is no intention to infringe the None Partnerships (361) bullet point 10 is considered an a policy to provide a percentage of consumer rights. admirable aspiration, however national energy needs from renewable energy policy means that consumers resources, as foreseen in the Draft have the right to pick their energy SWRSS. supplier.

118

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Storage of surface water Environment Agency The policy is considered sound and in None None None (281) connection with the current outline application for 630 dwellings the EA has sought the provision of long term surface water storage with development following the sequential approach. These principles would be similar for any future development of this site.

Masterplan PCL Planning on Behalf SS2 is not effective because it contains The policy should be re-written to set a The Council has commissioned a team None of Shapland Trust no requirement for a comprehensive clear requirement for masterplanning of consultants led by Urban Initiatives (landowners at Nerrols) masterplan for the area. and phasing showing the linkages to prepare a masterplan and design (155) between the various elements of codes for both Nerrols and Monkton residential development and the Heathfield urban extensions. This work provision of key elements of is progressing and will be the subject infrastructure and how this is to be of further stakeholder and community secured. engagement leading to its adoption as a Supplementary Planning Document to the Core Strategy. It is therefore unnecessary for the policy to include a requirement for a comprehensive masterplan for the area. Hestercombe House Baker Associates on Hestercombe House SAC will require None The Hestercombe House SAC Habitat None SAC Behalf of Barratt plc compensatory habitat for sites where Regulations Assessment 2009 (401) there is a loss of bat foraging. The indicated that lesser horseshoe bat habitat at Nerrols should be flight lines significantly affected the established by 2016, by which time northern part of the Nerrols site and Nerrols will have delivered 240 the eastern part of the Staplegrove dwellings. There is no objection to this site. Following discussions with approach, but there is an inconsistency Natural England it was agreed that the in the approach to this site and that at southern part of Nerrols could come Staplegrove, where the need for habitat forward as a first phase of establishment is considered to be a development in parallel with offset sufficient reason to delay the delivery habitat woodland planting. In a similar of development until after 2016. There fashion the western part of is no logic between these approaches Staplegrove could have provided a first to the different sites and this point is phase of development, but land developed further in response to Policy assembly issues prevent this area

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST SS6 Staplegrove. coming forward for at least five years. There is no inconsistency in the Council’s approach to these sites. Quantock Hills Quantock Hills AONB Although Quantock Hills are referenced The contextual information in the The purpose of the justification is to None (265) within SS2, the supporting text is not supporting text could be improved with provide a succinct explanation of the considered adequate. information on the proximity to the policy, rather than descriptive AONB and the potential impacts on information. The Landscape Character landscape character and visual Assessment of Taunton’s Rural-Urban amenity. Fringe 2005 informed the development proposals to minimise impacts on landscape character. Amendments to policy AMEC on Behalf of The The policy is supported, but: Amendments to SS2 and justification: SS2 and justification Crown Estate (98) • greater emphasis should be given to • recognise the “Interim release” Agreed – add text to the end of Add to 5.22: “In June 2010 the the “Interim release” and early status of the site paragraph 5.22 Council agreed that Interim delivery to contribute to the 5 year Sites of about 300 dwellings supply. The planning application is at each at Nerrols and Cades be an advanced stage. released to contribute towards the shortfall in the 5 year supply of housing land in Taunton Deane.” (Also to apply to SS4) • “Phased delivery of 900 homes at an • remove the density standard or at Agreed – amend SS2 first bullet point Amend first bullet to read: average of 40 homes per hectare” – least expressed as maximum to accord with first bullet point of SS1. “Phased delivery of around 900 an average density of 37 – 40 homes average density new homes at an overall per hectare is likely to be the average of 35-40 dwellings per maximum that is achievable or hectare”. (Change also to apply suitable to policies SS3 and SS4) • “1 hectare (gross) of additional • delete reference to B2 and B8 uses Agreed that general industrial (B2) be Delete reference in fourth bullet employment land” – the site is not and the requirement for 1ha of deleted, but not storage and point to “general industrial (B2)” suited to ‘heavier’ B2 or B8 uses employment land. distribution (B8). Not all B8 buildings and similarly delete reference given its nature, access and primarily are large crinkly tin sheds and there is on page 78 para 5.25. residential location. B1 uses are a demand from small businesses for more appropriate to a residential small storage and distribution units area and have a much higher job which would not be inappropriate in density, therefore the requirement of this location. 1 ha should be reconsidered. The The Nerrols Farm complex of listed current application includes a local buildings has been excluded from the centre with commercial, retail, outline application area and proposals. community uses and live work units, The Council would support its which PPS4 defines as economic conversion for B1 uses and if there

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST development. The masterplan was a firm commitment from The facilitates access to the ‘triangle site’ Crown Estate to this and the provision which could enable expansion of the of some freehold land for small local centre for B1 uses. The Nerrols businesses on the Crown Industrial Farm Listed Buildings could be Estate nearby on the other side of the converted to B1 uses and there are A3259 would be prepared to amend opportunities on other Crown Estate the requirement for 1 ha of land. employment land.

• “1 new primary school” – the need is • reword as “a financial contribution to The allocation of 900 dwellings would questioned since the development in offsite primary education generate the need for 180 primary its own right does not generate improvements” or delete the school places or a 6 class primary None demand for a whole school. There requirement school. Not all the Crown land within are also phasing and delivery issues. the allocation area has been included Funding towards off-site in their outline application for 630 improvements to education have dwellings, so the majority of the been suggested. primary school need will be generated by development on Crown land. It is vital that the Nerrols development provides a site for a new school relatively early in the phasing. The existing local primary schools have cramped sites and do not have the capacity to accommodate the 126 primary school places required from 630 dwellings. The provision of a site is important for the planning of this urban extension and takes priority over the provision of financial contributions.

• “A country park within the green • reword as “a contribution towards a The Green Infrastructure Strategy wedge between Priorswood and country park within the Green 2009 identified that the most deprived Monkton Heathfield” – the case for Wedge”. wards in North and East Taunton None this is created by the wider 5,000 (Halcon is the most deprived ward in home growth at Monkton Heathfield Somerset) have very poor access to and overall Nerrols allocation (not local open space and proposed a new just 630 dwellings on the Crown country park in the Green Wedge estate application). As part of the between Priorswood and Monkton current application 5ha alongside Heathfield, together with a strategic green link from Halcon to the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Maidenbrook could form the first Quantock Hills AONB. These phase of the country park. The recreation opportunities have been mechanism to deliver the ‘full’ agreed from the outset in our country park needs wider discussion discussions on Nerrols with the Crown involving the developers of Monkton and their submission in September Heathfield, recognising the tenancy 2008 includes the potential country issues and ownership of much of this park. All the land necessary to land by The Crown Estate. implement the proposal is controlled by landowners involved in the Nerrols and Monkton Heathfield sites and it is intended that both developments make appropriate contributions towards the implementation costs. It will fail to be delivered unless Policies SS1 and SS2 make provision for it.

• “Infrastructure for bus rapid transit” – • delete bullet point The bus rapid transit along the A3259 the need for infrastructure on from Monkton Heathfield to the town Yallands Hill/A3259 is not driven by centre also serves Nerrols. It is None development at Nerrols, but rather therefore appropriate that Nerrols growth at Monkton Heathfield, makes a contribution towards the therefore reference to this should be infrastructure. removed from the policy. The Crown Estate is in discussions with SCC to ensure that development at Nerrols does not compromise the ability to deliver improvements in the future by safeguarding land adjacent to the highway.

• “A new highway link between • amend wording to clarify that land The Highway Authority consider a local Bossington Drive and Lyngford only will need to be safeguarded link from Nerrols Drive to Cheddon Lane/Cheddon Road” – development within the Crown Estate Scheme. Road as shown on the Concept Plan is None at Nerrols does not create the need justified. Nerrols Drive will serve as a for a new highway link, but it is an distributor road for the allocation as a aspiration that can be facilitated by whole. The Crown Estate submitted safeguarding land for such a scheme outline application plan does not as part of the Nerrols masterplan. facilitate the comprehensive The current outline application allows development of the whole allocation and shows open space on the

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST the land for this. proposed link road alignment. The Council considers the plan should be amended to enable the comprehensive development of the allocation and construction of the first stage of the link road providing access to both the housing in the northern part of the site and subsequently to the remainder of the allocation.

• “A suitably located energy centre to • delete bullet point An energy centre provides both heat provide locally generated electricity and power. At the current time we to the new development” – an energy would regard this as an appropriate None centre would provide heat (in the first solution to the energy requirements. If instance) and then electricity if a the developer identifies an alternative Combined Heat and Power system viable solution we would support this. was used. CHP has yet to be widely Current government advice on delivered on residential-led schemes allowable solutions allows a range of with viability the main barrier given measures. The Council considers the significant upfront capital costs. enhanced on site energy efficiency as The policy therefore needs to be the most sustainable option. more flexible to allow other on-site opportunities as well as off-site approaches.

• “Justification, Delivery, • Amend supporting text in line with Only amendments set out above on Implementation, Monitoring and above comments, add text to reflect housing density, inclusion of reference Concept Plan” – all of the comments the Interim release of the site. to the Interim Site release and deleting Para 5.25 delete “general raised above also relate to the reference to general industrial B2 are industrial (B2)”. supporting text, paragraphs 5.21 to considered to be justified. 5.34 inclusive as well as table 5.2

123 POLICY SS3 Wellington Longforth

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Site cannot be delivered • Not effective – nature conservation None • Nature conservation interests are None 1.DW Alder Town interests have reduced the accommodated in the proposed Planning Consultants housing numbers, consequently green wedge and have not on Behalf of reducing community benefits that reduced housing numbers or landowner: South of can be delivered. community benefits. Bloor Homes Harris’ Farm (125) • The relocation of two factories is have submitted an application for 2.DW Alder Town not feasible due to cost and this a first phase of 503 dwellings Planning Consultants will affect delivery of the northern including a primary school, sports on Behalf of relief road. pitches with changing and parking landowner: facilities, allotments, community Broadlands (141) orchard, NEAP and LEAP, and a 3. DW Alder Town contribution towards a community Planning Consultants hall. on Behalf of • The two employers support the landowner: Cornhill, proposed relocation sites. The Wellington (219) relocation will be a later phase of 4.DW Alder Town development, but the first phase Planning Consultants will provide the first stage of the on Behalf of northern relief road up to the landowner: Highlands, Relyon car park, enabling the Cotford St. Luke (253) majority of HGVs to avoid the 5.DW Alder Town town centre. Surveys show that Planning Consultants Relyon has about 100 HGV on Behalf of movements per day, whereas landowner: Foxes Swallowfield at Station Road has Meadow, Wellington about 50 per day. (234) Longforth Concept Plan Terence O’Rourke on The alignment of the northern relief The Wellington Key Diagram and The Key Diagram and Concept Plan The Glossary should include a Behalf of Bloor Homes road is not compatible with the design Concept Plan should be amended to are intended to illustrate the principles definition of both Key Diagram (50) principles in the masterplan prepared reflect the August 2011 masterplan of the proposed development, but not and Concept Plan to clarify that by the developer following extensive which has been subject to extensive the precise alignment of the road or they illustrate the principles of consultation. consultation, prepared by Terence precise extent of the development area development, but not the O’Rourke on behalf of Bloor Homes. and green wedge. The masterplan has precise alignment of roads or been the subject of consultation and is disposition of land uses. a more up to date representation of the proposals.

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ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Renewable energy Strategic Land The policy is considered sound but The supporting text should provide a There is no intention to infringe the None Partnerships (360) para 5.42 is considered an admirable percentage of energy needs from consumer rights. aspiration, however national energy renewable resources as foreseen in the policy means that consumers have the Draft SWRSS. right to pick their energy supplier. Watercourses Environment Agency The policy is considered sound but None It is intended to retain existing None (280) existing watercourses should be watercourses and their importance for retained. wildlife is recognised. Wellington Railway Somerset County Council The policy is considered sound, but Caveat to wording. This simply states the delivery None Station (521) paragraph 5.46 makes it sound as if mechanism and does not imply any Wellington Railway Station will certainty. definitely be included in any new rail franchising agreement, when this is far from certain. Northern Relief Road Nynehead Parish Council The policy is considered sound and the None It would be prohibitively costly and None (260) Northern Relief Road is supported as it difficult for the new road to bridge the is hoped to remove some of the main railway line and extend through traffic from Milverton and northwards around Tonedale. Langford Budville. To be really effective it should cross the railway and join Milverton Road at Tonedale.

125 POLICY SS4 Wellington Cades/Jurston

ISSUE ORGANISATION(S) RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in brackets) SUMMARY OF REP SOUNDNESS TEST Concept Plan WYG Planning & Design • The precise disposition of the • The policy should make the • The Concept Plan is intended to • The Glossary should on Behalf of CG Fry & development area and green requirement for the green wedge illustrate the principles of the include a definition of the Son (446) wedge cuts across field clear and the value of the concept proposed development, but not Concept Plan to clarify boundaries should be part of a plan is questioned. the precise disposition of the that it illustrates the more rigorous assessment development area and green principles of development, process wedge. but not the precise disposition of land uses. • The requirement to contribute • Delete reference to developer • A sustainable transport strategy • None towards a feasibility study to contributions to the railway station has been developed in reopen Wellington Station is and replace with study to partnership with Somerset County unjustified investigate sustainable transport Council and this includes strategy to support the provision for a feasibility study to development of the site reopen Wellington Station, as well a local bus service for Wellington and improved walking and cycling links. Renewable energy Strategic Land The policy is considered sound but The supporting text should provide a There is no intention to infringe the None Partnerships (358) para 5.55 is considered an admirable percentage of energy needs from consumer rights. aspiration, however national energy renewable resources as foreseen in the policy means that consumers have the Draft SWRSS. right to pick their energy supplier. Storage of surface water Environment Agency The policy is considered sound but the None It is intended to maximise the potential None (279) area represents a good opportunity for for strategic SUDS infrastructure within long term storage of surface water. the green wedge.

126 POLICY SS5 Wellington Strategic Employment site ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST Visual impact of proposal Blackdown Hills AONB (181) Agree that is will be very None suggested Noted None necessary to carefully assess visual impact and design as the site will be visible from the AONB Support for increased self Strategic Land Partnership A welcomed way of None suggested Noted None containment (359) maintaining Wellington’s self containment and sustainability.

127 POLICY SS6 – Staplegrove Broad Location for Growth

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) Effect of traffic on AONB Quantock Hills AONB Concern about development at None. The overall strategy is based on None (264) Staplegrove and the pressure this may promoting urban self-containment so bring to Kingston Road, one of the that the need to travel outside the main main arterial routes into and over the settlements for employment, shopping Quantocks, both in terms of traffic or other services is minimised. (affecting tranquility) and changes to The strategy also contains proposals for landscape character. a country park at Priorswood to provide a closer alternative to the AONB for some informal recreation. Support Strategic Land If sites at Monkton Heathfield and None If allocated sites do not come forward None Partnerships (357) Nerrols do not come forward at all, or as anticipated, the need to bring fail to deliver at the rate required, then forward additional sites will be it is appropriate that these sites should considered when the Core Strategy is be considered for earlier release than reviewed. post-2016. Allocate east of site and Baker Associates on Whilst land at the western end of the Development of an urban extension at The Hestercombe House SAC Habitat None increase numbers behalf of Barratt plc (408) area may not be available in the short Staplegrove should be identified as a Regulations Assessment 2009 term, this need not prevent the area Strategic Site in the Core Strategy, indicated that lesser horseshoe bat east of the Mill Lease stream from enabling development to come forward foraging significantly affected the being brought forward earlier. The in the period before 2016. northern part of the Nerrols site and the need for off site woodland planting eastern part of the Staplegrove site. linked to the eastern area is no Following discussions with Natural different to the situation which exists at England it was agreed that the southern Priorswood/Nerrols which is being part of Nerrols could come forward as a brought forward for development first phase of development in parallel before 2016, yet it is assumed that the with offset habitat woodland planting. eastern area at Staplegrove cannot be This is not the case with the eastern developed before 2016. part of Staplegrove where the whole area is equally affected by bat foraging. Compensatory woodland planting will take at least 10 years to become established. There is no thus inconsistency in the Council’s approach to these sites. The overall quantum of development The quantum of development needs to within the urban extension should be be determined through an overall increased to provide for approximately masterplan and at this stage there is no 1800 dwellings (which should be the need to assume either a higher or lower subject of detailed masterplanning to range than indicated in SS6.

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) identify an appropriate and deliverable figure). Clarity and constraints Barton Willmore LLP on A greater degree of clarity is needed, None It is unnecessary to provide greater None behalf of the based on a robust assessment of the clarity for a broad location such as Comeytrowe Consortium site’s relationship with the strategic Staplegrove at this stage. (312) housing requirement and its ability to Only the western part of Staplegrove deliver within the plan period. has land assembly issues for the next Constraints at Staplegrove include land five years. There is no longer a assembly difficulties, a need to provide proposal for a northern outer distributor part of a northern outer distributor road, road, only local links. Impact of the the impact of the Hestercombe House Hestercombe SAC can be addressed SAC, and the fact that the area is not by compensatory woodland planting. available for early delivery. Green wedge, floodplain Environment Agency Policy SS6 does not fully meet the To comply fully with PPS9, SS6 should Paragraphs 5.68 and 5.69 provide a None and blue link (293) requirement to enhance biodiversity seek to retain existing green wedges general description of the form the under PPS9. and blue corridors in addition to development should take, including Being a broad location for growth providing new open space. reference to a green wedge along the rather than having defined boundaries, SS6 should make a reference to Mill Lease stream. This would ensure SS6 fails to make reference to including a buffer zone to local retention and extension of the existing including a buffer zone to local watercourses to continue blue links green wedge and ‘blue corridor’, and watercourses to continue blue links and and direct development away from the provision of a buffer zone to the stream. direct development away from the floodplain. Development would not be permitted floodplain. within the floodplain. There is thus no need to amend SS6. Support Greenslade Taylor Hunt Agree with Policy SS6. This is a None Support noted None on behalf of J Read (435) sustainable location and development would offer the opportunity to address local highway problems and deliver environmental enhancements in the Staplegrove Village Conservation Area. Diversion or Fulfords on behalf of Western Power strongly oppose None At a meeting with the Consents & A structural landscaping belt 20 undergrounding of Western Power paragraphs referring to a preference for Wayleaves Manager it was agreed to metres wide is proposed along overhead power lines Distribution 572) undergrounding or diverting power amend the first sentence of paragraph the outer edges of the lines as this could have major financial 5.69. The proposed change overcomes development areas. and The consequences for Western Power the objection. existing 132kv overhead lines Distribution. The Consents & are a design constraint Wayleaves Manager at Western Power proposed to be diverted. seeks a meeting to discuss amendments.

129 POLICY SS7 Comeytrowe/Trull Broad Location for Growth

ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST Public 1. DW Alder Town Planning Not effective – a public transport None This is not a site allocation for 2,000 houses, but rather None transport Consultants on Behalf of corridor needs to be provided, but an it is identified as a broad location for growth after 2016 corridor landowner: South of Harris’ allocation of only 2,000 houses are because the infrastructure requirements are not yet Farm, Hillcommon (127) unlikely to make delivery viable, which fully understood. It is possible that a new high 2. DW Alder Town Planning would be inconsistent with Policy CP6 frequency dedicated public transport link from the Consultants on Behalf of principle of corridor management on the Comeytrowe/Trull urban extension to the town centre landowner: Broadlands, Trull strategic road network. will be required if the full potential of 6,000 – 8,000 (143) dwellings is to be achieved. It is agreed that 2,000 3. DW Alder Town Planning houses are unlikely to deliver this, which is the reason Consultants on Behalf of why a masterplan should first be prepared to identify all landowner: Cornhill, the infrastructure requirements for an urban extension Wellington (222) of up to 8,000 homes, before there is any allocation of 4. DW Alder Town Planning part of the area. A piecemeal release of sites in Consultants on Behalf of advance of such a masterplan is likely to undermine landowner: Highlands, the viability of delivering a comprehensive development Cotford St. Luke (255) with the necessary infrastructure. 5. DW Alder Town Planning Consultants on Behalf of landowner: Foxes Meadow, Wellington (236) Traffic Bishops Hull Parish Council Concern that up to 2,000 dwellings at None The full transport implications of up to 8,000 dwellings None congestion (536) Comeytrowe will increase traffic on need to be understood in terms of the transport Wellington Road since the junction with infrastructure that will be required to serve a strategic Silk Mills Lane is overloaded now and urban extension at Comeytrowe before any part of the requires attention. site is allocated to ensure that any site released will contribute towards the overall transport solution. Transport Highways Agency (332) The plan is considered sound – None Agreed None strategy development of Comeytrowe/Trull later in the plan period will allow for the preparation of a comprehensive and deliverable transport solution – a robust and well evidenced plan is needed to demonstrate that there will not be an adverse impact on the M5. Infrastructure Hoddell Associates on Behalf of The plan is not sound because the Work on the Comeytrowe urban Work on the Comeytrowe urban extension will not be None problems Messrs/Mrs Sebastian & Council has failed to carry out the extension should be undertaken now left until 2016, but will continue now so that we are in a

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST Saunders/Smailes (34) necessary studies to establish the most rather than left until 2016. This position to allocate the site in the 2016 CS Review. appropriate solutions to the should include an assessment of The land west of Honiton Road/south of Claremont infrastructure problems of the land west of Honiton Road/south of Lane is designated as Urban Open Space, subject to Comeytrowe area – this needs to be Claremont Lane, which is considered policy EN24 in the adopted Taunton Deane Local done well in advance of the CS Review capable of making an early Plan. if development is to commence after contribution to the housing 2016. requirement whilst utilising existing infrastructure. The policy should refer to a site boundary plan and concept plan for Comeytrowe. Settlement Bishops Hull Parish Council Strong protection for the open None Strategic sites allocated in the plan are accompanied None limits (536) countryside is welcomed, but there do by a site boundary plan and a concept plan. The not seem to be any settlement limits on existing settlement limits of the urban areas will be the plans, which would delineate the extended to include these allocations. Comeytrowe is urban area from the countryside. not an allocation, but is identified as a broad location for growth after 2016 and therefore a site boundary is not yet identified. Delivery Strategic Land Partnerships The policy is considered sound, but if None There are many sites of up to 500 dwellings which are None (356) Monkton Heathfield and Nerrols fail to likely to be allocated in the Site Allocations DPD which come forward at all, or to deliver at the will contribute towards housing delivery before 2016. rate needed to maintain Taunton’s To release part of Comeytrowe in advance of agreeing success and sustainability then it is a comprehensive masterplan which has been subject appropriate that these sites should be to full public consultation would risk failure to make considered for earlier release than post adequate developer contributions towards provision of 2016. the infrastructure required to serve an urban extension of up to 8,000 dwellings. A piecemeal approach would represent cherry picking and is therefore resisted. Land available Greenslade Taylor Hunt on The policy is considered sound and is None Support noted None for Behalf of land owners at supported. This policy accords with the development Comeytrowe, Staplehay and findings of the Taunton Urban Trull (420) Extension Study (2004) and the Taunton Sub Area Study (2005). The proposals to prepare a cohesive masterplan for development post 2016 and for further community and stakeholder engagement are welcomed and will provide land owners, developers and community with greater certainty as to the extent of new

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ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST development. Our clients own land within the broad location which is available for development and has no obvious constraints. We fully understand that a comprehensive masterplanning approach will be necessary to ensure delivery of all the required infrastructure and recognise that a land equalisation agreement is likely to be required to assist with deliverability and confirm we are fully prepared to participate in this process. Timing of 1. Barton Willmore on Behalf of Consultants studies confirm that 8,000 New policies proposed: This representation suggests that a site for 2,000 None development Mactaggart & Mickel (298) dwellings and other complementary SS7A to allocated 2,000 dwellings, 5 dwellings be allocated without adequate community 2. Barton Willmore on behalf of development can be accommodated hectares of employment, a mixed use and stakeholder engagement or a comprehensive the Comeytrowe Consortium successfully within the wider defined district centre, 1 new primary school masterplan for the whole area with potential for 8,000 (Bovis Homes, area. The Core Strategy should make a and site for a secondary school dwellings. In 2010 both GOSW and PINS advised that Summerfield,Mactaggart & specific allocation for a “strategic site” SS7B to identify a broad location for Comeytrowe be identified as a broad location for Mickel, Taylor Wimpey) (300, on the northern part of Comeytrowe for a mixed use strategic urban growth and should not be allocated as a strategic site 317, 318, 319, 320) 2,000 dwellings. There is no good extension of up to 6,000 dwellings for until the totality of the infrastructure requirements to reason to delay the start of which a masterplan will be prepared. serve 8,000 dwellings was properly understood. To development until 2016 – it should start release part of Comeytrowe in advance of agreeing a as soon as possible. A masterplan comprehensive masterplan which has been subject to should still be required to identify the full public consultation would risk failure to make potential for the southern part of the adequate developer contributions towards provision of area, which should be identified as a the infrastructure required to serve an urban extension broad location for development of up to of up to 8,000 dwellings. The proposal to allocate 2,000 6,000 dwellings. The proposal for 2,000 dwellings now is based on utilising the limited capacity dwellings neither requires a in existing infrastructure systems. This could commitment to further development to undermine the viability of major new infrastructure make it viable and deliverable, nor required to serve the urban extension of up to 8,000 predetermines the outcome of the dwellings, but also by using up all the existing capacity subsequent masterplanning of the wider could prevent small sites in the south western sector of area. Taunton from coming forward. A piecemeal approach to development of Comeytrowe/Trull would represent cherry picking and is therefore resisted. The Consortium are suggesting that the whole area on which they have options is allocated now, but the western parts of the area include hilltops of the ridge of

132

ISSUE ORGANISATION(S) (insert RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED comment id in brackets) CHANGE SUMMARY OF REP SOUNDNESS TEST higher land, designated in the Local Plan as a special landscape feature. Development on these hilltops would have an unacceptable landscape impact. The proposal would also fail to secure a key part of the proposed green wedge along Galmington Stream. Also if the Consortium’s suggestion is agreed, they would have no interest in or commitment to future masterplanning of the remaining area of potential for up to 6,000 dwellings. It is difficult to respond properly to the Consortium’s studies because whilst the representation states that the studies dated August 2011 were submitted, they were not received until September and the Council has had no previous involvement with or knowledge of these studies.

133 POLICY SS8 Taunton - Broad Location for Strategic Employment (and relationship with policy SS1) ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED comment ID in brackets) TEST CHANGE CHANGE Consequence on Pegasus Planning (on behalf Support for policy but would object if a None Policy SS8 is not an allocation, nor does it propose a None delivery of urban of Persimmon / Redrow) proposal inadvertently frustrated the site. However, the supporting text refers to a number of extension (386) delivery of Monkton Heathfield. sites for further investigation including Monkton Heathfield. Any site would be post 2016. If Monkton Heathfield was the preferred location it would be masterplanned in partnership with the development consortium to integrate into the existing urban extension with minimum disruption. Impact on Henlade and Mr Nigel Wright (44) The Plan is unsound because it is Additional sentence The Council recognises that the Plan may be None Ruishton James Olney (183) acknowledged that east of Junction 25 to read: ‘unsound’ if an allocation were made without a defined Mike Marshall (Vice Chair, cannot be delivered until J25 is “Any allocation of evidence base or means of delivery. However, policy Ruishton and Thornfalcon improved and a Henlade by-pass is in land following on SS8 is not an allocation, nor does it recognise east of PC) (474),(493) place due to traffic flows and that public from the proposed Junction 25 (Henlade) as the only opportunity. The NRP Brunt (472) funding would not be in place until at 2016 review at Plan period extends to 2028 and it is envisaged that Doug Lowe (469) least 2020. J25/Henlade will be further employment provision may be required in the Mary Lowe (466) seen not to be in later stages of the Plan, and certainly beyond. Karen Ryan (463) line with the needs Len and Karen Goldstone of the defined Identifying potential future areas of search to meet the (461) village of Henlade, growth aspirations of the Council does not make the John and Lisa Ashbaugh be outside of the Plan ‘unsound’. On the contrary, it reflects The (457) limits of Taunton Borough Councils Executive (September 2009) Brian Thompson (454) and would be agreement to develop an evidence base for a second Roy Bulgin (477) contrary to the strategic employment site with good motorway access P Lawton (482) intentions of the to provide major employment opportunity in the TS McEwen (483) Core Strategy medium/longer term (arising from a June 2009 Task Barbara Wellwood (North (policy SP1)” and Finish Group). The need to develop and justify this Curry Parish Clerk) (485) case was again recognised in the Roger Tym study Paul Branfield (489) (2010) to inform the Core Strategy review in 2016. Robert Horn (491) V Moore (Ruishton Ladies Such sites have particularly long lead-in times. The Coffee Club) (495) Council would be failing in its duties and potentially Candida Adkins (550) create a future vacuum of employment land provision if John Thompson (558) it failed to recognise potential long term growth Mark Adkins (556) requirements well in advance of current need. Ashleigh Adkins (553) Amanda Knight (548) Mike Westlake (Lower Henlade and Stoke Road Residents Association) (546)

134 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED comment ID in brackets) TEST CHANGE CHANGE June Revenor (544) Sally Ravenor (541) Terence Ravenor (540) Nicole Owsianka (480) John and Teresa Glew (459) J Hunt (455) Impact on Henlade and Mr Nigel Wright (44) Policy SP1 does not define the limit of Additional sentence Policy SP1 provides the overarching spatial policy for None Ruishton James Olney (183) Taunton (which was included in the to read: “The the Borough. It does not define site/allocation Mike Marshall (Vice Chair, Local Plan). Henlade and Ruishton are motorway boundaries. The settlement limit for Taunton is Ruishton and Thornfalcon defined as villages. Any proposed continues to act as identified on Inset Map 1, and currently follows the M5 PC) (474),(493) allocation after 2016 would not be in a strong physical motorway (as per the local Plan). Henlade and NRP Brunt (472) line with the needs of the village. A firm and psychological Ruishton are identified as villages in policy SP1 (as per Doug Lowe (469) commitment to keep the M5 as a barrier barrier to the the Local Plan) Mary Lowe (466) is required to prevent sprawl, ensure eastwards and The Core Strategy’s role is to deliver the ‘Vision for the Karen Ryan (463) Taunton is not severed by the M5 and southwards Borough’, a key element being employment led growth. Len and Karen Goldstone to ensure the Plans soundness by development of Policy SP2 (Spatial policy for Taunton) recognises the (461) giving clarity to the town’s spatial Taunton. need for a ‘search’ for a potential new strategic John and Lisa Ashbaugh strategy. Development which employment site for Taunton towards the end of the (457) would be physically Plan period. This is reflected in policy SS8. Policy SS8 Brian Thompson (454) severed from does not allocate a site (see above comments). Roy Bulgin (477) Taunton by the M5 In order to meet the future needs of the Borough, any P Lawton (482) is not favoured”. allocation would be sought in a sustainable location, TS McEwen (483) with good access to the town centre and the national Barbara Wellwood (North route network. This may (or may not) require breaching Curry Parish Clerk) (485) the motorway in a future Plan review. This has already Paul Branfield (489) happened (eg Park and Ride and previous planning Robert Horn (491) approvals and Local Plan allocation at Henlade) and V Moore (Ruishton Ladies elsewhere in the UK urban areas lie either side of a Coffee Club) (495) motorway. Candida Adkins (550) The Plan may be found unsound if it did not recognise John Thompson (558) the potential future needs of the Borough and the long Mark Adkins (556) lead-in times for development to be implemented Ashleigh Adkins (553) without a hiatus of available land. If land around Amanda Knight (548) Henlade is required in future the settlement limit would Mike Westlake (Lower be redrawn (as per current Core Strategy allocations). Henlade and Stoke Road Clearly such a site would be beyond the scale of Residents Association) (546) employment requirements for the ‘needs’ of June Revenor (544) Henlade/Ruishton residents (or other settlements Sally Ravenor (541) around the urban edge) but would serve the future Terence Ravenor (540) employment needs of the County town and Nicole Owsianka (480) surrounding catchment. John and Teresa Glew (459)

135 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED COUNCIL RESPONSE PROPOSED comment ID in brackets) TEST CHANGE CHANGE Stated preference for Environment Agency (278) Due to the functional floodplain None Many areas around Taunton are affected by flooding None future search area constraints to the east of Junction 25, and clearly, functional floodplain would be avoided for the other two options (Monkton future development. This would not rule out the area Heathfield and Comeytrowe) should be around Junction 25 as large areas of land not at risk of considered instead. flooding also exist in the vicinity. Failure to identify a Strategic Land Partnership It is a weakness that the Plan does not None Th3e adopted Taunton Town Centre AAP allocates a None strategic employment (369) identify the strategic employment site. strategic employment site at Firepool. The AAP (and site The objectives of NPPF paragraphs 71- Core Strategy) forms part of the suite of documents in 81 are not met and there is therefore a the LDF. danger that the Plan could be found unsound. The NPPF is currently a draft and whilst a material consideration, not government policy. However, the Core Strategy meets the principles of the NPPF; an employment led strategy which plans positively for growth (including business), identifying sites and setting criteria for a second future strategic site through policy SS8 if an identified need is established. Incomplete evidence Roy Bulgin (477) The Core Strategy is out for None The SHLA is undertaken annually (since 2009). Whilst base consultation over a different timescale it informs Plan preparation it has a wider role (eg to the SHLA. The document is not assessment of the deliverable land supply). It does not therefore legally compliant because the establish housing requirements in Development Plans. evidence base is incomplete. The Core Strategy covers the period to 2028. In establishing housing ‘requirements’ over the Plan period, the 2010 and 2011 Fordhams work (‘Balanced Housing Projections’) provides the relevant evidence base. Possibility of future Somerset County Council Although the Plan is sound it should be Noted. However, alternative sites may equally fulfil the None employment site at (522) noted that policy SS8 leaves the door criteria set out in policy SS8. Henlade/Ruishton open for an employment site at Henlade in first review.

136 POLICY DM1 General Requirements ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED SUGGESTED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) Brownfield land Baker Associates (on Criterion a (prioritising brownfield Delete the words “giving As noted, the policy reflects current advice None behalf of Barratt plc) land) reflects current advice in PPS3. preference to the recycling in PPS3. The final version of NPPF has (390) However this will be replaced with of previously developed yet to be published and it would be wrong A.Penna (on behalf of the NPPF which makes no reference land where it is in a to base a Plan on supposition. However, Gadd Properties) (86) to brownfield or targets. Land should sustainable location” the policy cannot apply to Plan allocations, A.Penna (on behalf of now be assessed for development (eg Monkton Heathfield or Staplegrove) David Wilson Homes) based on characteristics and their but is rather a form of assessment to (79) needs. We should thus equally weigh adhoc proposals advanced outside support deliverable Greenfield and of the Plan system which may be brownfield as long as they support particularly pertinent if two competing the principles of sustainable proposals are submitted which may be development. Therefore Staplegrove equal in other regards. (Baker) and Monkton Heathfield (Penna) should not be restricted from coming forward in favour of brownfield locations. Density support Pegasus Planning (on Support policy DM1 and in particular None Noted None behalf of Persimmon / clause a. which states that density Redrow) 389 will reflect the characteristics of the area. Building for Life Graham Ward (Taunton Policy DM1 should also require Insert a requirement to This is covered under policy DM4 None and District Civic dwellings should score very highly observe BfL criteria and Society) (102) against the 20 Building for Life satisfy them in the policy. criteria Level of ‘harm’ caused Terence O’Rourke plc All development is likely to generate As the test for acceptability Agree in part. Some development Amend criterion d.e. and (51) some degree of harm to the should relate to whether proposals may enhance the appearance f. to include appearance and character of an the level of harm caused is of an area for example. However, agree “Unacceptable” before area. Criteria d. e. f. seem unacceptable, suggest that an unacceptable harm would be a the word “harm” or unnecessarily restrictive. “unacceptably” is inserted more appropriate test, implying a ‘tipping “harmed”. before the word “harm” point’ beyond which a proposal should not within these criteria. breach. Noise in areas of Mike Highfield (on behalf While the issue of ‘tranquility’ may be Add reference to policy See response above (ref 51). The County No change proposed tranquility of Somerset County addressed in Noise Action Plans it DM1 that a proposal shall Council, as Highway Authority, are a (other than ref to Council) (28) would be of benefit to provide policy not lead to any significant consultee on planning applications and response above – ref support in a Core Strategy. increase in noise to would respond accordingly. It is not 51). Residential development exposed to identified areas of necessary to clutter the Plan up with high traffic noise will need to be tranquillity and shall references or a list of sites covered in identified in the County Councils NAP recognise the objectives of other Plans and strategies in this instance. and further mitigation measures may national policies designed be needed to reduce noise exposure. to limit the effect of

137 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED SUGGESTED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) unwanted environmental impacts. Protection of industrial Mike Highfield (on behalf The protection afforded to existing Amend criterion f to read: This matter is adequately covered through None land of Somerset County industrial land in relation to noise and “The protection of health, changes proposed above (Terence O Council) (25) pollutant may not be apparent in the safety and amenity of any Rourke 51) policy. It is ambiguous as to whether users of a development will the presence of a noise maker not be harmed shall be (industry) acting reasonably would be sufficient to address the affected by the later arrival of a noise level of harm, pollution or receiver (housing). noise arising or expected to arise from an existing or committed use” Development within Environment Agency Policy DM1 does not adequately Ensure that development This matter is adequately addressed None flood areas (277) reflect PPS25, failing to make in the floodplain is avoided under policies CP1(f) and CP8. reference to avoiding development in and that where this is not the floodplain. possible, proposals must ensure that the safety of people and property is met and floodrisk is not increased elsewhere. Protection of controlled Environment Agency Policy DM1 fails to meet the Protection of controlled Policies CP1 c. and CP8 seek to protect Amend ‘Key’ on waters (277) requirements of PPS23 as it does not waters should be included. the quality, quantity and availability of the Proposals Map and Inset make reference to protecting water resource. These areas are shown Maps 1 and 3 to state controlled waters (i.e. surface and on the Proposals Map. “Water Source groundwaters) Protection Zone CP1, However, the key to Inset Map 1 & 3 CP8: Climate Change refers to the relevant policy as CP1 whilst and Environment” the Borough wide Proposals Map refers to Policy CP8. Both should be referenced on Amend Policy CP8 bullet the relevant map keys. 5 to read: “not exacerbate, and Also, for clarity, it may be appropriate to where possible improve reaffirm this commitment to the water the quality, quantity and resource in policy CP8 by amending bullet availability of the water 5. resource, reduce flood risk (fluvial and surface water); and” Remediation of land Environment Agency Policy DM1 fails to make reference to Reference to appropriately Local Plan policy EN32 covered the issue None from contamination (277) appropriately remediate green and remediating green and of contamination. The Council did not brownfield land where there is brownfield contamination request this as a ‘saved policy’ after the likelihood of previous contamination. should be made. 2007 ‘cut-off’ as it duplicated requirements

138 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED SUGGESTED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) from other legislation and statutory consultees. The Secretary of State accepted this position under Schedule 8 to the Planning and Compulsory Purchase Act 2004. (by letter dated 24.09.07.) Question need for Strategic Land This policy can apply to all None The policy does indeed apply to all None policy Partnerships (355) development and thus do not need to development but not just large strategic be replicated in the individual greenfield urban extension allocations. It sections of each urban extension is a development management policy also project. relevant for small infill in urban areas for example where detailed rather than strategic issues of amenity, visual impact and local character would also apply. Extend scope of policy Natural England (564) The Core Strategy is sound but Amend criterion c. to read: This is adequately covered in policy CP8 None biodiversity and geological “The proposal will not lead (Environment) conservation interests should extend to harm to protected or beyond legally protected species. important wildlife species or their habitats, important habitats and natural networks”. Loss of quality D. Bradley (514) Policy DM1 references ‘the most None Much of Taunton is surrounded by high None agricultural land effective and efficient use of land’. quality agricultural land. It is inevitable that This is not consistent with building on areas for potential food production will be top grade agricultural land. There is lost in order to meet the growth greensand which runs north to requirements over the period to 2028. northwest of Taunton. Is this However, the Plan framework seeks to protected for food growing? maximise opportunities for brownfield regeneration (eg Taunton Town Centre AAP) and seek appropriate densities and thus minimise loss of greenfield land. Lack of requirements Somerset County Disappointing that there is no Policy DM1 should include The Plan needs to be read as a whole. None for walking, cycling and Council (515) requirement for access by walking, wording about 1. all new Policies such as CP6 (Transport and public transport access. cycling or public transport, development providing for Accessibility) seeks to improve Ralph. I am not entirely particularly as it is referred to in the the needs of pedestrians, accessibility by public transport, cycling sure about my Justification (paragraph 6.4) cyclists and public and walking, as does CP1a. Policy CP6 response to the travel transport users and 2. the also refers to the need for travel planning planning aspect. Do requirement for programmes to ensure modal shift. In this you think this development over instance it is not considered necessary to adequately covers it? threshold sizes to produce specify thresholds in another authorities travel plans or travel plan documents (and which may change) . statements as detailed in

139 ISSUE RESPONDEE (insert SUMMARY OF REP SOUNDNESS RECOMMENDED SUGGESTED COUNCIL RESPONSE PROPOSED CHANGE comment ID in TEST CHANGE brackets) current County Council guidance. Lack of reference to RPS on Behalf of Avon The police fully support principles of None Agree See response in policy safety and Somerset ensuring a safe environment, DM4 Constabulary particularly through the use of design. Despite the use of a PSCO in the supporting picture to this policy it is disappointing that neither Policy DM1 nor Policy DM4 refer to matters of safety and design led principles to increase safety and meet the objective of a safe environment. Secured by Design is the UK Police flagship initiative supporting the principles of designing out crime and it is considered these policies should include reference to safety principles to enable further expansion in the development management policies document, cross referencing to Secured by Design. The Constabulary employ a Crime Prevention Design Officer to assist developers in dealing with crime risks and offers advice for designing out crime in the built environment.. This officer should be included as a stakeholder in the development of any masterplan, planning application or DPD.

140 POLICY DM2 Development in the countryside ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST CHANGE Employment and Somerset County Council The Plan is sound but would None To require employment provision in all affordable None. community provision (518) suggest that Policy DM2.6 housing schemes is unnecessary and could make within affordable (affordable housing) should the scheme unviable. Most rural centres already housing include provision for some provide employment opportunity. Policy DM2.2 community or employment use. also allows for new, small scale employment uses As it stands the policy could outside of settlement limits. All housing proposals lead to pockets of transport will also contribute towards community provision, deprivation. on site or through a commuted sum. AONB recognition Quantock Hills AONB (262) Support for reference in None Noted. None supporting text with regard to the two AONBs within the Borough. Local landscape Blackdown Hills AONB (176), The policy setting out a None In addition to the 22% nationally designated area None designations (241) sequential approach is useful. of the Borough, around 3% additional land is However, concerns with covered by local designations such as County paragraph 6.10 about accuracy wildlife sites. There are also important green of “much of remainder have wedges providing a range of functions including locally important landscape avoiding coalescene of settlements, parks, designations” recreational space and ancient woodlands for example. Housing targets D.Alder (on behalf of The policy makes no provision None PPS7 paragraph 9 states that sufficient land None Rayglow) (221), (128), (on for sites to be considered if the should be made available within or adjoining behalf of Western Properties) Council are not meeting their villages and new housebuilding in the countryside (237), (256), (on behalf of housing targets. This is should be strictly controlled. The Core Strategy Charles Friend) (144) inconsistent with the need to allocates a range of strategic sites within the deliver 17,000 houses. Borough and identifies a range of rural centres for future growth. The future Site Allocations DPD will identify these and other sites to meet evidenced housing requirements. This does not prevent additional applications being submitted and considered on their merits, as is currently the case. The proposal is therefore unnecessary. Affordable housing in Alexandra Munday (on behalf The draft NPPF requires lpa’s to Amend point 6 to As worded, the policy does not preclude provision None smaller villages of Bath and Wells Diocesan be responsive to local read: of affordable housing within settlement limits of Board) (30) circumstances and plan housing “a. adjoining well these smaller villages. However, it is appropriate development to reflect local related to settlement to prioritise larger affordable housing requirements, particularly limits, provided no developments (which may be more difficult to affordable housing. Policy DM2 suitable site is locate within identified settlement limits) to the does not do this, prioritising available within the nearest local centre since, unlike smaller villages, affordable housing to be rural centre; these centres provide a range of accessible local adjacent to a rural centre, b. in other locations services such as schools, doctors and shops.

141 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST CHANGE thereby overlooking affordable well related to existing need in other villages. facilities and to meet The proposed wording “well related” is imprecise an identified local and open to confusion: well related by bus as need which cannot be opposed to walking distance? Well related in met in the nearest landscape character? etc. Use of such wording identified rural centre” would undermine and negate the need for any settlement boundaries, potentially leading to adhoc, opportunistic development across the countryside, contrary to national policy Policy hierarchy Gwilym Wren (on behalf of It is not clear whether policy The Strategy should The Core Strategy sets the strategic planning None Milverton PC) (106), (107) DC1 or DM2 takes precedence clearly state the policy framework for the area. This is clear from national when planners and developers hierarchy. policy. Other policies, such as the Development get engaged in playing top Development Management ones, must be compatible with the trumps to establish which Management should strategic policies, resting lower in any ‘hierarchy’, policies are pre-eminent. be the most powerful providing more detailed application for the Plans and come before the Vision, Aims and Objectives. The Plans layout CP,SP and SS ones. reflects the required hierarchy.

There is no inconsistency between policies DC1 (DM1?) and DM2. Policy DM1 applies to all planning applications (within or outside of settlement limits) as general principles for consideration and, as stated, is considered “in addition to any other Development Management policies which apply ...” It clearly does not override any locational principles regarding development in the countryside. Rural exceptions Tetlow King (on behalf of The policy should reflect NPPF Housing Associations The NPPF is currently only in draft. It would be None South West HARP) (185) – removing rural exception should be allowed to inappropriate to formulate policy against a policy to allow cross subsidy use cross subsidy document that currently has limited status and from general market housing on where they think may change. Settlement limits will be reviewed rural exception schemes to appropriate under the site allocation DPD and redrawn allow wider range of needs to be accordingly to provide for ‘cross subsidy’, or met. Housing Associations ‘affordable housing’ allocations as/if appropriate should be allowed to use cross within settlements, avoiding the need for subsidy where they think ‘exception site consideration’ if this element of the appropriate NPPF is eventually adopted. Redundant buildings PCL Planning (on behalf of Concern that the policy could be Information is The hierarchy is consistent with PPS7. National None Shapland Trust) (156) overly restrictive. Point 7’s required as to how the policy seeks to make communities more hierarchy of preferred uses for uses in DM2.7 will be sustainable, by focussing services and other redundant buildings isn’t tested or demand facilities close together (paragraph 3), whilst consistent with PPS7 and there assessed. paragraph 4 seeks to meet local business and

142 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST CHANGE is no information on how these community needs to promote vitality. This is uses are to be tested or what reaffirmed in paragraph 18. Outside of demand there is for some of settlements new house building for reasons of them. sustainability and to protect the countryside. This principle would equally apply to conversions, as less sustainable than community and business uses, which also provide local employment opportunity.

This element of policy is largely ‘saved’ from the Local Plan. Regarding ‘testing’, development management already require evidence of suitability for conversion without affecting the intrinsic quality of the building and evidence of marketing at a market rate (often independently assessed) for employment/other uses, prior to consideration of residential use. Repair and Greenslade Taylor Hunt (170) Inconsistent with PPS7 in that Remove reference to Even if a building is visually unappealing it is a None replacement of the policy DM2.5 introduces a “uneconomic to bring sound principle of sustainability to ‘recycle’ where buildings requirement that it should be the dwelling to an possible. Retaining the structure of a building uneconomic to bring the acceptable state of would not inhibit visual improvements in keeping dwellings to an acceptable state repair” with the character of the area. However, if this is of repair. There may be other “uneconomic to bring the dwelling to an sound reasons for replacement, acceptable state of repair”, then a one-for-one such as sound but visually replacement would still be allowed, as currently unappealing building. worded. Reuse of buildings Greenslade Taylor Hunt (170) Whilst national policy expresses Revise policy to It is not the intention to repeat national policy in None a preference for economic reuse indicate that the Core Strategy. Applications would be treated of buildings, it recognises that in proposals for on their merits and it would be for the applicant to some situations residential residential re-use for demonstrate on a case by case basis how their conversion may be appropriate. buildings of historic or proposal has been considered against the Policy DM2.7 fails to recognise architectural interest, sequential hierarchy set out in policy. The criteria this. demonstrably at the end of the policy states that architectural unsuitable for and historic qualities of the building must not be alternative economic harmed. The policy does not preclude residential re-use will be conversion where appropriate. permitted. Reuse of buildings Greenslade Taylor Hunt (170) The policy fails to acknowledge None The policy does support the re-use of buildings: None re-use of buildings is desirable DM2.5 and 7. both include this preference. in terms of sustainable Further, policy DM5 also refers to the minimising development objectives. of waste and promoting reuse of materials in construction.

143 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST CHANGE Reuse of buildings Greenslade Taylor Hunt (170) The policy makes no provision Residential re-use Housing demand can be met within more None for residential conversion within 2km of country sustainable locations. This would clearly closely related to towns and towns and villages constitute development in the countryside. PPS7 villages unless the strict should be allowed aims to prevent urban sprawl and protect the sequential approach is followed. without needing the open countryside. Paragraph 10 of PPS7 refers to This is inconsistent with PPS7 sequential approach. the need for “special justification” for isolated new as it fails to recognise such housing General residential conversion up to developments can be these distances would also promote car travel, sustainable and contributing again not sustainable and would be contrary to towards housing demand national and local aims to address climate change. Reuse of buildings Greenslade Taylor Hunt (171) Inconsistent with GPG and Amend to permit re- The approach is consistent with PPS7. None PPS7 in that national policy use of any Policy DM2.7b.iv does provide for holiday and does not limit reuse of existing appropriate rural tourism use generally as part of conversion of buildings for holiday building for holiday existing buildings. Policy DM2.3 also allows for accommodation to proposals accommodation and caravan and camping accommodation in the associated with farms and other permit new build countryside. rural services. holiday accommodation where in accord with sustainable development objectives or associated with farms and other rural services. New build holiday Greenslade Taylor Hunt (171) Fails to recognise national None Paragraph 36 of PPS7 states that “wherever None accommodation policy also permits new build possible, tourist and visitor facilities should be holiday accommodation in rural housed in existing or replacement buildings ...”. areas. Whilst paragraph 6.19 Paragraph 37 expects “most tourist refers to a perceived imbalance accommodation requiring new buildings to be in supply/demand, it is the remit located in, or adjoining existing towns and of the market, not planning to villages”. National policy aims to protect the address this imbalance. countryside. The Core Strategy would allow new build within settlements. Outside of settlements priority should be given to reuse of buildings for reasons of sustainability, protection of rural landscape etc, although accommodation can also be provided in caravans etc. If it were left for the market to decide how much new build holiday accommodation were provided there would be adhoc development in the countryside and the

144 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in brackets) SOUNDNESS TEST CHANGE planning system would not be able to protect the “quality and character of the wider countryside” (PPS7 paragraph 15). The Council has been faced with proposals from private individuals to convert holiday accommodation to residential use due to oversupply. This is not sustainable and priority should be afforded to reuse and where possible, focussed on diversifying existing rural enterprise. The situation will continue to be monitored and adjusted in any future Plan review if required. Agricultural uses Greenslade Taylor Hunt (171) Policy DM2.4 refers to ‘new Amend to refer to new Agreed in part. Reference to “storage” should be Amend heading of policy storage buildings’ but fails to buildings to meet the replaced with “agricultural and forestry”, which DM2.4 to read: make provision for other identified needs of would include livestock facilities, polytunnels etc. 4. “Agriculture, forestry buildings such as livestock and agriculture or other and related” dairy facilities, polytunnels, farm rural businesses. It is generally considered appropriate to keep offices etc. It also fails to horses in rural areas and the Borough Council Amend policy DM2.4.a to address the needs of other rural currently considers a presumption in favour of read: enterprises, including forestry equestrian enterprises subject to normal “new storage non and equestrian. development management criteria such as residential agricultural protection of hedgrows, reuse of buildings etc. and forestry buildings This will be monitored for issues and a policy commensurate with the incorporated within the forthcoming Site Allocation role and function of the and Development Management DPD if required. agricultural or forestry unit”.

Utility development AMEC on behalf of National Policy DM2 does not refer to Policy DM2 should Agreed. At end of DM2 add Grid (IDP 30) development that National Grid include an additional additional category: 8. may need to undertake to meet category Development for its operational needs. ‘Development for essential utilities essential utilities infrastructure. infrastructure’.

145 POLICY DM3 Gypsy and Traveller Site Selection Criteria

ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id in SOUNDNESS TEST CHANGE brackets) Flood Risk Environment Agency Not consistent with national policy; Caravans for permanent The Plan should be read in its entirety. None (276) Policy fails to reference residential residential use are not permitted Policy CP8 refers to strategic principles for development in regard to sites being outside areas at high in Flood Zone 3 Flood Risk. risk of flooding. Policy DM3 its self refers to appropriate siting of a development taking Caravans for permanent into account flood risk. residential use are not permitted in Flood Zone 3 as per PPS25 table D2 and D3. Given the identified need for such sites in the Borough, the need to locate these outside of the floodplain to meet the requirements of the Government Policy. Burden on Barton Willmore LLP on The Policy is not consistent with None National Planning Policy, existing and emerging, says the Local Authority “Where sites are development behalf of the national policy and not effective has a duty to plan for all forms of identified residential accommodation not available proposals Comeytrowe No justification for land associated need and to identify appropriate locations for development which would consideration Consortium with urban extension to be used create strong, sustainable (economically, socially and environmentally), should be given (305) for Gypsy & Traveller occupancy mixed communities; for the benefit of all members of society. These to sites adjoining and it would place unreasonable locations should be achievable; have a reasonable prospect of being or adjacent to burden on the development delivered. existing proposals. Existing national policies states that the Core Strategy should set out settlements (and criteria for the location of G&T sites which will be used to guide the in particular land allocation of sites. associated with Emerging legislation adds that LA’s should ensure their policies promote strategic urban integration, co-existence, easy access to services and facilities, and at a extensions).” scale appropriate to the nearest settled community. The GTAA identified the need in Taunton Deane for 25 residential and 5 transit pitches up to 2015 and 19 residential up to 2020 as well as 2 showmen yards in Somerset. The authority has an obligation to identify sites. The Core Strategy identifies policies and locations to address this need. However, as there is no allocation at the strategic urban extension of Monkton Heathfield for consistency we will remove the reference to land associated with Urban Extensions Separate DM Mr Gordon Ansell Question the need for specific The policy should relate to There is significant legal documentation stemming from 1968 to today Policy is not (9) rules for Gypsy & Travellers “Mobile Homes and Associated recognising Gypsies, Travellers and Showmen as distinct groups; in required Gypsy & The Governments new policy Sites” and be applicable for addition, Romany Gypsy’s and Irish Travellers are a distinct ethnic

146

ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED (insert comment id in SOUNDNESS TEST CHANGE brackets) Travellers suggests that we “should all be everyone choosing to live in minority group under the Race Relations Act of 1976 and Amended Act equal under the planning law”, such accommodation. of 2000 and 2003. Gypsy’s, Travellers and Showmen are also defined which should preclude race-based under planning law precedent from 1977 up to the present day; including exceptions. the Draft Planning Policy for Traveller Sites published in April 2011 by the Coalition Government. These state that Gypsy, Traveller and Showmen status is a material consideration in planning. Government is committed to a fair and equitable system and aligning the planning system for G&T with that for settled housing. The authority has a duty to duty to plan for all forms of identified residential accommodation need and to identify appropriate locations for development. National Planning Policy also recognises that there is a need for additional guidance on G&T sites to address the historic under provision of G&T accommodation, poor social economic and educational outcomes as well as the controversial nature of the issue. They have therefore provided planning circulars in addition to the planning act and Planning policy Statement setting out LA’s duty and responsibility. Please see previous council response above.

147 POLICY DM4 - Design

ISSUE ORGANISATIO SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE N(S) (insert comment id in brackets) Flexible approach Pegasus Paragraph 6.27 is not consistent with paragraph The last sentence of There is a need to ensure that development produces None to density Planning Group 46 of PPS3 which enables a more flexible paragraph 6.27 should be balanced communities and not a preponderance of large, on behalf of approach to density. A balance needs to be deleted. low-density dwellings, which would not meet the overall Persimmon struck between the house type needed in the need for housing in Taunton Deane. This applies in Homes and locality and the recognition that the urban suburban locations as well as in Taunton and Wellington Redrow Homes extensions are to provide a complementary type town centres – it is not the case that all flats or small (306, 388) of housing to that proposed in the centre of dwellings should be, or indeed can be, in the town centres. Taunton. Paragraph 46 of PPS3 refers to a range of factors that need to be taken into account, including the need to use land efficiently, and it is considered that paragraph 6.27 strikes an appropriate balance between these.

Building for Life Taunton & The use of Building for Life criteria should be Insist on developments that Whilst the concern is understood, the details of how general None District Civic much more firmly applied. (when scored independently, design policies will be applied are a matter for the Society (105) or by TDBC, not the forthcoming Site Allocations and Development Management developer) score very highly Policies DPD. against the BfL criteria, particularly criteria 16-20. AONB design Blackdown Hills Policy DM4 is not consistent with paragraph 6.32 Add the words ‘and similar’ Agreed Add the words ‘and guides AONB (175, of the supporting text and section 6 of PPS12, after ‘Village design similar’ after ‘Village 240), Quantock allowing scope for design guides prepared by statements’ in the fourth design statements’ in Hills AONB (261) AONB Partnerships for example, and through bullet point of DM4, to ensure the fourth bullet point of other community-led planning responses. that documents produced by DM4. the Partnerships (for example) are covered by the policy. Too prescriptive Barton Willmore Policy DM4 and its related text should not unduly None The policy is intended to ensure that new development is None LLP on behalf of constrain the design of new development nor based on ‘best practice’ in urban design and avoids the use the Comeytrowe require overly complex processes for bringing of formulaic housing and highway solutions. Consortium forward site-specific design proposals. For The use of masterplans and design codes, and ensuring (409) example, it should not be prescriptive about the that development relates appropriately to the overall form of density of development (it currently suggests 40- settlements, is fundamental to this and does not constitute 50 dph, which may be inappropriate for urban an ‘overly complex’ process. extensions with a focus on family housing), public In line with PPS3 it is important to ensure that land is used art and specific green infrastructure requirements. efficiently, and it is therefore appropriate to specify a density range. Urban extensions should not focus solely on family housing, given that a high proportion of the need for housing

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ISSUE ORGANISATIO SUMMARY OF REP SOUNDNESS TEST RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE N(S) (insert comment id in brackets) in Taunton Deane is for 1- and 2-bed room dwellings, not all of which can (or should) be provided in town centres. The density figure of in 6.27 is considered to be appropriate in this context. In addition, lower density development is not able to support viable district heating or CHP schemes or public transport that is competitive with travel by private car. The Council has an adopted Public Art Code and a Green Infrastructure Strategy, with which it is reasonable for development to comply. Support Natural England Paragraph 6.28 is not effective enough. To be None Green Infrastructure is covered in greater detail in Policy None (566) consistent with PPS12 (for example, paragraph CP8; in particular paragraphs 3.109 - 3.112. The detail of 4.8) it should be made clear that the how green infrastructure should be managed is not recommendations of the Green Infrastructure appropriate in a strategic design policy. Strategy extend beyond allocated development.sites as well as within them. Regarding 6.29, reference could be made to Section 5 of the Green Infrastructure Strategy, which suggests what the innovative ways of providing and maintaining open space could be. Lack of reference RPS on Behalf The police fully support principles of ensuring a None Safety is referred to in the first bullet point of paragraph 6.25 Insert additional to safety of Avon and safe environment, particularly through the use of but additional emphasis could be provided. sentence at end of Somerset design. Despite the use of a PSCO in the paragraph 6.26: ‘It is Constabulary supporting picture to this policy it is disappointing also important to ‘design (571) that neither Policy DM1 nor Policy DM4 refer to out’ crime, and the matters of safety and design led principles to principles set down in increase safety and meet the objective of a safe the UK police initiative, environment. Secured by Design is the UK Police ‘Secured by Design’, flagship initiative supporting the principles of should be incorporated designing out crime and it is considered these into development policies should include reference to safety proposals.’ principles to enable further expansion in the development management policies document, cross referencing to Secured by Design. The Constabulary employ a Crime Prevention Design Officer to assist developers in dealing with crime risks and offers advice for designing out crime in the built environment.. This officer should be included as a stakeholder in the development of any masterplan, planning application or DPD.

149 POLICY DM5 Use of Resources and Sustainable Design ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) Extend the scope Somerset County Although the Plan is sound, policy None This ‘requirement’ would be too detailed for the None of DM5 Council (517) DM5 should include a requirement scope of this policy which deals with general for electric vehicle charging points requirements to deal with climate change such as (16 amp) carbon, water and waste reduction. Unnecessary Barton Willmore LLP Policy DM5 and associated text is None Correct in part. CO2 reduction does follow current Amend paragraph 6.40 to policy wording (416) (on behalf of unnecessary and unreasonable. It building regulation trajectories although the zero read: DeVirgo) duplicates the CfSH and Building carbon level for non domestic buildings (2019) is “The carbon reduction targets Regs. still believed to be an ‘aspiration’ set by se out in policy DM5 are Government in March 2008 and one that the based on current Council supports. In addition, Government policy requirements and policy is still evolving. Whilst Government is considering although it is acknowledged changes to the definition of zero carbon, at this that these may be subject to stage the Council is not aware that any change change or superceded by has been formally ‘adopted’. The current wording changes to national policy. is therefore accurate. Although the Council is keen However, these targets may be subject to change to encourage higher and or superceded by changes to national policy and faster …” the text needs to reflect this. Other elements of the policy (eg minimisation of pollutants, future adaptability, monitoring measures) cover wider ‘sustainable design’ matters not adequately covered at the national level. Unnecessary The Comeytrowe Policy DM5 and supporting text None See above response ( to Barton Willmore, 416). Agree amendment. See policy wording Consortium (307) introduces unnecessary and above response ( to Barton unreasonable duplication of the Willmore 416). CfSH and Building Regulations and there is a need for significant redrafting to ensure compliance with government policy in this respect. Strengthen policy Environment Agency Policy DM5 does not meet the Policy DM5 should Government policy advises against the need to None wording (275) requirements of PPS25 include the following duplicate national policy advice in Development requirements for new Plans. Policy CP1 (Climate Change) and CP8 development to meet the (Environment) also cover flooding and PPS25 requirements of PPS25: issues. “Sustainable development should avoid high flood risk areas where possible by

150 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) setting development back from all watercourses and utilise sustainable drainage systems” Amend supporting Tetlow King Planning Support for DM5 in attempting to The standard of Reuse of spare soil on site, reducing pollutants None text regarding (191) (on behalf of improve the levels of sustainable sustainable design and water consumption etc should be considered viability South West HARP) design but not ‘effective’ as not should only be required standard practice. There is no evidence to flexible enough. The standard where ‘viable’ or suggest this would affect the viability of a scheme. should only be required where ‘feasible’ on a case-by- Monitoring of measures to reduce energy use for ‘viable or feasible’ on a case-by- case basis in order to example should also be considered a standard case basis. ensure flexibility. requirement to ensure that a proposal performs to the building regulation requirements. If such matters clearly rendered a development demonstrably unviable the Council would consider the matter on its merits and strike a balance to ensure appropriate elements are undertaken without jeopardising the development. Amend supporting GVA (161) (on behalf The principle of incorporating An element of flexibility See response 191 above None text regarding of St Modwen) sustainable design features in new should be incorporated viability development is welcomed but the to take account of policy is not flexible as it should viability as a result of take into account ‘viability’, as a economic circumstances result of economic circumstances. at the time. Unnecessary Tetlow King Planning The requirement that development Building regulations The ARUP study does suggest Firepool may be None policy wording (191) (on behalf of in town centres and urban should be used to meet able to meet higher / advanced standards. South West HARP) extensions must be one level in the governments Likewise, as technologies improve, costs may well advance of the national program national timetable for the decline in future, enabling larger schemes to for CfSH is inconsistent with PPS1 CfSH implement higher codes at lower costs without which states that it must be affecting viability. supported by local evidence. This Nevertheless, importantly, policy DM5 already does not appear to have been does state that higher codes would only be sought produced. “where viable” Unnecessary WYG (199) (on behalf The policy is not consistent with None Government policy does not prevent higher codes None policy wording / of Sainsburys Ltd) national guidance as it states that being provided and policy DM5 states that higher inconsistent with the specified requirements to codes within larger schemes would only be sought government policy achieve CO2 reduction should be “where viable”. at least one code level higher than those set out in national standards. Amend supporting Pegasus Planning (on Paragraph 6.40 notes that it is not None As technologies improve over the Plan period, None text regarding behalf of viable to meet higher code levels costs may well decline in future, enabling larger

151 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) viability Persimmon/Redrow) in advance of government schemes to implement higher codes at lower (387) requirements yet the policy seeks costs without affecting viability. The policy does it on urban extensions unless it not “impose” accelerated targets without can be proven to make the overall consideration of viability. This is clearly stated in development unviable. the policy. Thus object to the imposition of targets in an accelerated form. The draft NPPF (para 70) states ‘lpa’s should avoid unnecessary conditions or obligations where this would undermine viability’. Viability is critical to timely delivery but partnership working can address these issues in order to bring forward development. Unnecessary Neil Hall, AMEC (99) The policy does not need to repeat This is not required and See above response (to Barton Willmore 416) Amendment agreed. See policy wording what is in Government policy via should be deleted. above response (to Barton changes through Building Regs. Willmore 416) Change policy Neil Hall, AMEC (99) The definition of zero carbon is out None Government policy is still evolving. Whilst None wording of date. Government is considering changes to the definition of zero carbon, at this stage the Council is not aware that any change has been formally ‘adopted’. The current wording is therefore accurate. Amend supporting Neil Hall, AMEC (99) The intention to seek one code Seeking a code level Reference to not affecting viability is already None text regarding level higher for urban extensions higher in urban referenced in policy. viability need to be balanced against extensions needs to be viability balanced against overall viability and reference added to this effect. Further Neil Hall, AMEC (99) The justification for the non- Justification for the non The 25% carbon reduction figure (2010) is already Amendment agreed. See explanatory text domestic timetable for zero carbon domestic timetable is set within Building Regulations. The zero carbon above response (to Barton required is unclear unclear and needs to be level for non domestic buildings (2019) is still Willmore) provided. believed to be an ‘aspiration’ set by Government in March 2008 and one that the Council supports. National policy is still evolving in this area and may change or be superceded by future statements and the policy needs to reflect this. Change policy Neil Hall, AMEC (99) The Crown Estate welcomes Delete specific reference On-site energy efficiency measures and on-site None wording recognition of role of allowable to prioritising ‘on-site’ renewable technologies fall within the ‘Allowable solutions and to this end there is energy. Solutions’ definition. Government proposals are

152 ISSUE RESPONDEE (insert SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE comment ID in SOUNDNESS TEST CHANGE brackets) no need to specify prioritisation of still evolving but as yet, there is no reference that on-site energy. prevents the Council seeking to prioritise these ‘allowable solutions’ in the first instance. Change policy Martin Miller, Terence Reservations about the ability of To be sound the policy Implementation of the CfSH are primarily set by Amendment agreed. See wording O’Rourke Plc (52) any development to meet Code must be justified by an national Building Regulations and therefore do above response to Barton level 6. evidence base. In its not form part of the Councils specific evidence Willmore) absence, it should be base. Government policy is still evolving. Whilst deleted. Government is considering changes to the definition of zero carbon, at this stage the Council is not aware that any change has been formally ‘adopted’. The current wording is therefore accurate. However, recognition needs to be given that these targets may be subject to future change. Change policy Martin Miller, Terence The objective of seeking CO2 None The ARUP study does suggest Firepool may be None wording O’Rourke Plc (52) reductions at least one code able to meet higher / advanced standards. higher in urban extensions is Likewise, as technologies improve, costs may well misguided, even if allowance for decline in future, enabling larger schemes to viability is made. The Core implement higher codes at lower costs without Strategy does not possess an affecting viability. Higher targets are not imposed. evidence base which National policy does not currently prevent the demonstrates that this is setting of higher / advanced standards. Inclusion achievable and is not supported by of reference to viability is considered relevant and national policy. appropriate.

153

Representations on Omission Sites

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) Suitability of site for 1. Barton Wilmore on • Site previously defined in Core • None. The relative merits of each of these None future allocation within Behalf of De Virgo Strategy as suitable for proposed omission sites is not a matter Site Allocations DPD Ltd development should be for the Core Strategy. Whilst the considered as part of the early Regulation 25 Core Strategy 2. Greenslade Taylor phasing for housing delivery. consultation also incorporated initial Hunt on Behalf of consultation on ‘small sites’ and other Mr Wilkins and • Land at Longrun Farm has been • None potential allocations, the Published SCAT considered deliverable through the Plan Core Strategy does not propose 2010 SHLAA. Therefore it should the allocation of any sites with a likely 3. Greenslade Taylor be considered for allocation yield of less than 500 dwellings. Hunt on Behalf of through the Site Allocations DPD. The Haimes Family Post adoption of the Core Strategy, the Trust • Land north of Cresswell Avenue • None. Council will undertake work on its Site should be considered for allocation Allocations Development Plan 4. Greenslade Taylor through the Site Allocations DPD. Document. It will be at this point that Hunt on Behalf of The SHLAA conclusion that the the consideration of these sites can be St Margarets site is not developable is carried out alongside all other sites put Hospice and challenged. forward through the Strategic Housing Friends of Land Availability Assessment. Taunton’s • Land to the south of Birds Farm • Remove Green Wedge Musgrove Park should not be designated as designation. It should be noted that the Council Hospital Green Wedge in view of proposals intends to consult upon all sites T37 and T38 and adjoining considered through the SHLAA, not just 5. Greenslade Taylor residential development. those deemed ‘developable’ through Hunt on Behalf of the process. Mrs J Penny • Land east of Wild Oak Lane, Trull • Remove Green Wedge should not be designated as designation. 6. DW Alder Town Green Wedge and should be Planning considered for allocation through Consultants on the Site Allocations DPD. Behalf of landowner: South of • Land South of Harris’ Farm should • None. Harris’ Farm be allocated through the Site Allocations DPD. It could provide 7. DW Alder Town affordable housing and community Planning benefits and would aid the Council Consultants on

154

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets) Behalf of in meeting their five year supply. landowner: Broadlands • Land at Broadlands, Taunton • None. should be allocated through the 8. DW Alder Town Site Allocations DPD. It could Planning provide affordable housing and Consultants on community benefits and would aid Behalf of the Council in meeting their five landowner: Cornhill, year supply. Wellington • Land at Wellesley Mews and 2-6 • None. 9. DW Alder Town Cornhill should be allocated Planning through the Site Allocations DPD. Consultants on It could provide affordable housing Behalf of and community benefits and would landowner: aid the Council in meeting their Highlands, Cotford five year supply. St. Luke • Land at Highlands, Cotford St. • None. 10. DW Alder Town Luke should be allocated through Planning the Site Allocations DPD. It could Consultants on provide affordable housing and Behalf of community benefits and would aid landowner: Foxes the Council in meeting their five Meadow, year supply. Wellington • Land at Foxes Meadow, • None. 11. IJP on Behalf of Wellington should be allocated Redrow Homes through the Site Allocations DPD. It could provide affordable housing 12. Greenslade Taylor and community benefits and would Hunt on Behalf of aid the Council in meeting their David Martin five year supply.

• Land at Popes Lane, Wellington • None. could provide for a mix of housing and employment uses. There are no physical or environmental constraints to development and as such it is considered ‘deliverable’.

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ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS RECOMMENDED CHANGE COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in TEST brackets)

• Land at Saxon Farm, Oake should • None. be allocated for around 20 dwellings. This would offer community benefits including affordable housing and potentially enhancing local services, provision of a footpath link, structured landscape planting, and the removal of unsightly redundant horticultural buildings.

Objection to non- WYG on Behalf of • Land at Ford Farm, Norton • Include site as strategic allocation The proposed allocation at Ford Farm allocation of site within Bellway Homes Ltd + Fitzwarren should be allocated as within Submitted Core Strategy. was not pursued in the Published Plan Published Plan Core Barratt Homes Exeter Ltd a strategic site within the Core Core Strategy on the basis of Strategy Strategy. The non-allocation is not representations made by the EA to the WYG on Behalf of justified and the vision and Regulation 25 document. The Summerfield strategic objectives cannot be document notes that: “Until the flood Developments Ltd achieved without this allocation. alleviation scheme is completed through the on site channel • Land at Killams, Taunton should • Include site as strategic allocation improvement works and ground raising be allocated as a strategic site within Submitted Core Strategy. it would be inappropriate to allocate within the Core Strategy. The non Ford Farm for development. Subject to allocation of the site at Killams is the completion of the flood alleviation not justified. scheme Ford Farm could be included in the Site Allocations DPD which will follow adoption of the Core Strategy.” The proposed allocation at Killams was not pursued in the Published Plan Core Strategy on the basis that the proposal attracted a substantial level of objection through the Regulation 25 document. The Council felt that given the scale of response, this could be taken to represent a demonstration of localism in practice and such the site was no longer promoted for allocation by the local authority.

156

Infrastructure Delivery Plan

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets)

Level of PCL Planning Ltd. on The level of contributions likely to be sought from None This is an issue to be tested at the CIL examination, not through None contributions behalf of the AW developers will have an adverse effect on the the Core Strategy. Paragraph 7.21 makes clear that preparation Shapland Will Trust release of land for development. of the CIL will require a separate and detailed viability and others (IDP28) assessment to support the charging schedule that is proposed.

Case for a CIL Given that the Council’s strategy is based on a None There is a requirement for infrastructure in Taunton Deane which None limited number of large sites, there is no real case cannot be met on a site-by-site basis and which it is legitimate to to be made for a Community Infrastructure Levy. secure funding for via CIL.

Scope of IDP With the exception of major transport infrastructure, None It is not accepted that the contents of the IDP amount to a ‘wish None the wide range of items in the IDP are a ‘wish list’ list’. Urban expansion at the scale proposed cannot realistically rather than essential elements associated with take place without improvements to a broad range of delivery of the Core Strategy. infrastructure, over and above transport improvements.

Number of The schedule of costs is misleading in that it None Paragraph 1.12 of the IDP makes clear that the infrastructure None dwellings appears to be based on 17,000 dwellings rather requirements have been identified for 11,000 dwellings. The assumed than the lower number actually proposed to be remaining 6,000 dwellings may require additional infrastructure delivered. measures.

Viability testing The viability testing is naïve in that it assumes land None Paragraph 7.23 clearly states that the three different planning None values which equate to the release of exception obligations packages were modelled without any grant. sites at a time when these were in receipt of grants.

Comments WYG Planning & Planning Obligations must accord with Circular None Agreed, although the introduction of CIL means that contributions None Design on behalf of 05/2005. need not be directly related to the proposed development. Sainsbury’s There is also now a legal basis for the tests in the 2010 CIL Supermarkets Ltd. regulations. (IDP13) Comments Natural England The Council needs to ensure that contributions on a None It is intended that green infrastructure will form part of the None (IDP11) pooled basis are secured to support green measures to be funded through CIL. infrastructure.

Inclusion of Strategic Land Paragraph 3.6 should Specific transport measures must be delivered to ensure that None specific Partnerships (IDP14) delete specific reference sustainable communities are created in the urban extensions. It transport to transport schemes is not sufficient to leave transport provision to be determined schemes and instead include a through the development management process. This would also general policy that not provide a basis for allocating public funding towards specific

157

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) phased infrastructure projects. will be provided to meet the needs of new development.

Developer There is no justification at national or local level for None Paragraph 4.31 explains why it is not always possible simply to None contributions contributing towards the cost of primary care. rely on the annual budget. Contributions from developers towards cost of Paragraph 4.30 states that PCTs are expected to towards the cost of primary care can therefore be justified. This primary care manage within an annual budget from the will be kept under review as the new arrangements for primary Department of Health. care in Somerset are clarified. Inclusion of public art in the Public art should not be form part of the IDP as it is The Core Strategy either Public art is adequately dealt with in Policy DM4 and paragraph None IDP not considered in detail in the Core Strategy. needs a specific policy 6.31. Contributions towards public art are already a requirement on public art or it should of Policy ED2 of the Taunton Town Centre Area Action Plan, not be referred to in the which was adopted in 2008. IDP. Need for contributions In Table 4.8 many of the facilities can be provided None If sports and recreation facilities are provided by the private None towards sports by the private sector. sector there is no guarantee that they will be open to the general facilities public. Facilities where the private sector is expected to make the provision are already highlighted. There is also a need to allocate land within major developments for the facilities; otherwise there will be nowhere for them to be provided at a future date. Swimming pools There is no mention in the Core Strategy document None Paragraph 4.70 of the IDP explains that the Council has None of the need for 2 new swimming pools or where undertaken a PPG17-compliant ‘Sports Facilities Strategy’ which they should be located. provides the justification for requiring 2 new swimming pools.

No evidence is provided of the need for 8 new None Paragraph 4.75 of the IDP explains that the Council’s policy is None community and village halls. derived from its published document ‘Policy for the Provision of Community Halls in Taunton Deane’. This was adopted in August 2008 and forms part of the evidence base for the Core Strategy. Maintenance agreements The Council should make clear in the IDP that they None The Council already accepts this type of agreement. None would be willing to accept 20 year-plus maintenance agreements for country parks, other parks and amenity space. Number of dwellings Paragraph 7.17 is misleading as the Council have None This is not correct. There appears to be confusion about the None

158

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) required to assumed 17,000 dwellings, not 11,000. overall requirement in the Core Strategy and the number of make dwellings without planning permission (11,000). Paragraphs contributions 1.11 – 1.13 provide the explanation.

Table 7.1 does not deal adequately with those None The objector does not say what these are. None things which would be provided in the normal course of a development. Approach taken in the The IDP fails to show that it has properly None The infrastructure referred to in the IDP is typical of that for which None IDP considered the impact of the Core Strategy, Circular developer contributions are sought by local authorities around 05/2005 and the incremental nature of the urban the UK. It is not in conflict with Circular 05/2005, particularly as extensions and development. under CIL there does not need to be a direct link between the funding of infrastructure and individual development sites.

The incremental nature of development is addressed by the pooling of contributions to reduce the likelihood of infrastructure being incomplete where development pauses. Omission of Mike Rigby (IDP16) A cycle route between No scheme has been identified that could be included in the IDP. None cycle route Bishops Lydeard and Taunton should be included in the IDP.

Omission of British Waterways The importance of the Bridgwater & Taunton Canal None This is more appropriately an issue for the Core Strategy rather None the Bridgwater (IDP 4) as green infrastructure has not been taken into than the IDP. However, the Green Infrastructure Strategy does and Taunton account. This is contrary to Government advice. take account of the Bridgwater & Taunton Canal. Canal Table 2.1 does not include the canal under the None Include reference to the Bridgwater & Taunton Canal in Table Include reference to heading of green infrastructure. 2.1. the canal in Table 2.1.

Additional maintenance requirements and a None British Waterways did not initially identify these requirements None possible need for upgrading the canal towpath as when consulted about the IDP. The requirements can be part of the cycle network will arise from the Monkton incorporated when the IDP is reviewed, subject to detailed Heathfield development. The proposed multi-user discussions between the Council and BW. The Council will path between the Blackdowns and the Quantocks require clear and costed proposals rather than general ideas may require improvements to the towpath and to about future improvements. Bathpool swing bridge.

Any proposed new CIL policy should include None These requirements can be incorporated when the IDP is None waterways under the headings of: reviewed, subject to detailed discussions between the Council 1. Green infrastructure and open space and BW.

159

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) 2. Sustainable transport infrastructure It is a review of the IDP that would address this, not the CIL None 3. Part of the infrastructure supporting flood policy. The canal can be referred to under these headings when alleviation, drainage and water supply the IDP document is reviewed.

Development Barton Willmore LLP The IDP should be reviewed to include the None As the Comeytrowe development is not needed earlier in the None at Comeytrowe on behalf of the provision of infrastructure elements needed as part plan period, there is no need to review the IDP to include Comeytrowe of the Comeytrowe development earlier in the plan infrastructure elements at Comeytrowe. However these Consortium (IDP18) period. elements will need to be included in a review of the IDP before the development can be brought forward. Green burials D Bradley (IDP20) Green burials should be mentioned in 4.40. None There is currently no evidence on which to base a requirement None for green burials as part of the development process. If evidence emerge this can be incorporated in a review of the IDP.

Role of 4.52 should include a reference to the role of None A reference to churches could be added to 4.52. Add reference to churches churches in providing village and community halls. church halls to 4.52.

Concert space 4.54 should specify the need for concert space and None There is currently insufficient evidence of need and costs on None and art gallery an art gallery. which to base a requirement for concert space and an art gallery as part of the development process. However, if evidence emerges, this can be incorporated in a review of the IDP.

Inclusion of Add reference to churches in 4.68. None Places of worship could be included in the second sentence of Add reference to churches 4.68. places of worship in 4.68.

Churches as 4.75 should include reference to encouraging use of None The IDP is not the appropriate document to propose changes in None community churches as village halls/community buildings policy. buildings through a revised grants system.

Tree planting 5.2 should refer to tree planting and potential for None The IDP is not the appropriate document to propose new policy. None and collections tree collections.

Tree Town Table 5.1 should refer to Taunton having potential None There is no formal proposal to make Taunton Tree Town of the None to be Tree Town of the South West. South West, so this cannot be included in the IDP. Comments The Theatres Trust It is important to encourage cultural activities in None Noted None (IDP21) local village and community halls. These can come under pressure from higher value land uses and therefore need to be especially supported.

160

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets)

Pubs can be transformed as additional venues to None Noted None provide a range of performance spaces.

We note the intention to upgrade the Brewhouse None Noted None Theatre and Arts Centre and look forward to being included in pre-application discussions on this in due course. Comments GVA on behalf of St Support the principle of infrastructure improvements None Noted None Modwen which will facilitate the regeneration of the Firepool Developments plc site. (IDP22) Support the recognition in 7.20 that contributions to None Noted None infrastructure must be kept at a level that maintains development viability and does not adversely affect the pace of development across the Borough.

Initial observations are that the findings from the None Noted None viability testing undertaken to inform the IDP appear reasonable.

Requirement RPS Planning & Paragraph 4.48 needs to refer to the Constabulary’s Amend paragraph 4.48 The IDP can be revised to take account of the Constabulary’s Amend paragraph for Development Ltd. on intention to seek contributions from development, to refer to the ACPO intentions; however the Constabulary need to provide more 4.48 to refer to the contributions to behalf of Avon & following the nationally advised approach from the approach. information on the level of contribution they are seeking and its ACPO approach. policing Somerset Association of Chief Police Officers (ACPO). justification. Incorporation of Constabulary (IDP31) specific proposals will need to await a review of the IDP.

Comments The Constabulary would wish to be involved in the None The Constabulary will be consulted as part of the CIL process. None discussions surrounding production of the CIL.

Compliance Environment Agency Changes will need to be made to paragraph 3.44 of The EA and the Noted. Amend Tables 6.1 with PPS12 (IDP32) the IDP in advance of the Core Strategy Borough Council have and 6.2 to show the Examination to ensure that the requirements of subsequently agreed EA and TDBC as joint PPS12 are accorded with. Until the details of the that, provided the 1 in lead organisations. strategic flood attenuation scheme are confirmed, 100 year flood levels in the EA cannot commit to being the lead authority on Taunton are reduced by flood defences for new development, but would be 100mm, they can act as happy to be a partner should such a scheme have a partners in delivering a

161

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) demonstrable reduction in flood risk to existing strategic fllod properties. attenuation scheme.

Status of The Woodland Trust The IDP does not refer to native woodlands forming The IDP needs to make The Habitats Regulation Assessment does refer to native None native (IDP 3) part of green infrastructure. clear that natural green woodland and this can be specifically referred to in the IDP when woodlands space including native it is reviewed. woodland forms part of green infrastructure.

Woodland Woodland buffers and off-site planting associated The 20m wide woodland It is thought that this woodland is most likely to be delivered by None creation within with the major development sites do not currently buffer at Monkton the owners on whose land it will be situated, rather than the the IDP form part of the IDP. Heathfield and other developers. For this reason it would not be appropriate to habitat offset include it in the IDP; however, the Council would wish to involve requirements need to be the Trust in discussions regarding delivery and management of included in the IDP. the woodland.

Standards for Proximity and access to woodland is a key issue The Woodland Trust’s This is an issue for a future review of the Green Infrastructure None access to linking the environment with health and other social Woodland Access Strategy and Green Space Strategy. woodland and economic issues. Standard (WASt) should be used should be used as a tool for delivering green infrastructure.

Assumed level Hoddell Associates on The IDP demonstrates that it is not possible to fund The infrastructure In the majority of locations, industry is not generally an None of developer behalf of Messrs/Mrs the infrastructure required by the Council in middle requirements should be appropriate alternative use to residential development. The contributions, Sebastian & and lower value areas when compared with reduced or the costs alternative use to housing would normally be agriculture. Thus scale of Saunders/Smailes(IDP industrial land values. This is likely to result in land spread across a greater there would still be a large uplift in land value in the majority of infrastructure 5) not coming forward or not coming forward as number of dwellings. cases. The comment appears to imply that infrastructure in requirements quickly as required to meet the Council’s strategic lower-value areas has to be funded by CIL collected in those housing targets. areas; this is not however correct. The IDP assumes no public funding. In reality there is likely to be some public funding over the Plan period. In addition, the level of CIL will be set having regard to viability. There is thus no reason to reduce the infrastructure requirements. Additional Taunton Cultural Historic churches tend to lack the facilities such as Include reference to a Whilst a general comment could be added, without specific None requirements Consortium (IDP 6) dressing rooms and toilets, which limits their need for these facilities evidence of need it is difficult to justify including a requirement in for arts and usefulness. in 4.43. the IDP. Grants are awarded to halls and organisations which culture are open to everyone and were the vast majority of the buildings use is general community use. A church hall can apply for a grant if they become community halls through the RANK

162

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) Foundation or Albemarle Scheme’s which ensure fair and open access for all.

In 4.51, there are likely to be further infrastructure None As these were not sufficiently firm proposals at the time of None requirements for the County Museum Service preparing the IDP, such future requirements (if they emerge) beyond its current developments. For example, an would have to be incorporated in a review of the IDP. art gallery with permanent collections.

The TCC identified a need for a performance space None This was not a sufficiently firm proposal at the time of preparing None for large-scale music and similar events. the IDP. It would have to be incorporated in a review of the document, if confirmed as viable.

The Brewhouse Theatre should be included in None Table 6.1 only covers the period to 2016; redevelopment of the Add reference to the Table 6.1 with the Council as the lead organisation. Brewhouse will be beyond this timeframe. The Brewhouse does Brewhouse in Table however need to be referred to in Table 6.2 (2016-2021). 6.2. Comments NHS Somerset (IDP 8) The IDP directly utilises the information provided by None The Council intends to regularly review the IDP and will liaise None NHS Somerset. It is important to maintain regular with NHS Somerset as part of this process. contact between the Council and NHS Somerset to ensure that the IDP remains up to date, as the timing of some of the primary care schemes can change. Level of Terence O’Rourke plc The likely contributions per dwelling are too high None The level of contribution per dwelling will be determined through None contributions (IDP 10) and this will inhibit the delivery of the Core Strategy. the CIL process, which has to be based on striking an per unit of appropriate balance between the need for infrastructure and the residential viability of development in the area as a whole. development

Extending GP Gordon Ansell (IDP 2) Paragraph 4.23 may not be correct in that multiple None The IDP was prepared with advice from the Primary Care Trust. None practices branch GP practices are best suited to patients in It would not therefore be appropriate for the Council to adopt a terms of convenience and service received. position at variance with this.

Provision Regarding paragraphs 4.43- 4.45, there is no None The IDP does not take a view as to whether facilities for faith None designed for evidence that provisions for faith communities are communities are more or less beneficial; however people are faith more universally beneficial than spending money on entitled to practice their religion and it is reasonable for the IDP communities other services. to consider how the facilities they may need should be provided.

Gypsy and Paragraphs 4.83 – 4.84 implicitly refer to those Re-title as ‘Mobile Home There is significant legal documentation stemming from 1968 to None traveller allocated a gypsy status due to their race and/or Provisions’. the present recognising Gypsies, Travellers and Showmen as provision lifestyle choices, which is prejudicial and against distinct groups; in addition, Romany Gypsies and Irish Travellers government plans to make everyone equal under are a distinct ethnic minority group under the Race Relations Act

163

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) planning law. It is also contrary to the UN of 1976 and Amended Act of 2000 and 2003. Gypsies, Declaration of Human Rights and the Human Rights Travellers and Showmen are also defined under planning law Act. precedent from 1977 up to the present day; including the Draft Planning Policy for Traveller Sites published in April 2011. These state that Gypsy, Traveller and Showmen status is a material consideration in planning. Compliance Nash Partnership on No reference is made to the need for planning None The introduction of CIL means that developer contributions do None with Circular behalf of South obligations to comply with the five tests in Circular not necessarily have to meet the tests In Circular 05/2005. CIL 05/2005 Western Property Ltd.; 05/2005. by its very nature involves payment towards facilities not S.French,; Landowner associated with individual development sites. Reference should of Land known as be made to the CIL Regulations and CLG Guidance of Highlands, Cotford St November 2010, paragraphs 57 on. Luke; Haunch Lane Maintenance Developments and In 1.4 there is no indication as to what the ‘defined None Where maintenance contributions are required they are None contributions Rayglow Securities facilities’ are for which maintenance contributions indicated, for example in Tables 4.10 and 5.1. Ltd; owners of land will be sought. south of Harris’s Farm, Pooled Hillcommon (IDP23, Pooled contributions can only be sought through None Prior to the adoption of CIL there is the potential to use New None contributions IDP24, IDP25, IDP26, CIL and there is no indication of how infrastructure Homes Bonus to deliver certain items of infrastructure. Pooling IDP27) will be provided in the meantime. is permitted up to April 2014 and thereafter for contributions from 5 or fewer developments.

Interim Policy Reference is made in 1.4 to an Interim Policy but None It is proposed to adopt an Interim Policy during January 2012, None there is no information as to the status of this. subject to Member approval.

Completeness Paragraph 1.5 states that the IDP cannot identify all None It is not realistic to expect the IDP to identify at the outset, every None of IDP the infrastructure that is required. It cannot piece of infrastructure to 2028. The IDP will be reviewed therefore be robust evidence. periodically to take account of emerging requirements.

Role and There is no explanation anywhere of the role and None The role of the document is explained in 1.2 to 1.10. The None status of status of the document. Reference to CIL is Council will be considering CIL during 2011-12 with the aim of it document confusing as the Council will have to consider CIL being adopted by the end of 2012. CIL will provide a primary after April 2014 and the IDP cannot be an means of funding the IDP – it will be complementary. alternative.

Future Paragraph 1.12 refers to masterplanning of None If additional infrastructure is required this will be incorporated None masterplanning development. This has not been subject to when the IDP is reviewed. consultation and therefore there may be deficiencies in terms of what infrastructure is required.

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Infrastructure Paragraph 1.13 should identify all the infrastructure None As the sites are not required for development early in the Plan None for remaining required for the remaining 2,000 dwellings to be period, and have not yet been fully identified, there is no reason 2,000 brought forward later in the Plan period to do this. dwellings

Lack of public Paragraph 1.18 should also state that a lack of None This is unnecessary as Paragraph 1.16 already states that the None funding public funding will delay infrastructure provision. IDP assumes nil public funding.

Funding via Paragraph 1.19 should note that the LIP is county- None Paragraph 1.19 already notes that the LIP does not indicate any None LIP wide and funding may therefore go elsewhere in new public funding sources and cautions the availability of Somerset. existing funding streams.

Reference to Table 2.1 should include broadband under physical None Broadband is subsumed under ‘telecommunications’. Libraries None broadband infrastructure; libraries under social infrastructure are included under ‘art and culture’ and allotments under ‘green and allotments under green infrastructure. infrastructure’.

Consultation At what point were English Heritage, Town and None They weren’t as they have no responsibility for infrastructure None with other Parish Councils and the Wildllife Trust consulted. provision. However they have had the opportunity to identify any bodies requirements through the Core Strategy process.

West Somerset The West Somerset Railway could be mentioned in None At present there are no detailed infrastructure schemes for the None Railway 3.3 as it is understood there is an intention to link to WSR that could form part of the IDP; however future schemes Taunton. could be incorporated in the IDP.

Bus station In Paragraph 3.9 it should not be assumed that None If funding is not forthcoming from the operator then other None funding will be forthcoming from the bus operator to alternatives will be explored. A site outside the town centre upgrade the bus station. Bus operators may also would not be suitable for a bus station. choose to use other sites outside Taunton town centre.

Wellington bus In Paragraph 3.10, if further measures to improve None Costs have not been identified for bus service improvements in None service the bus service in Wellington have not been Wellington but are likely to be incorporated in future reviews. identified then how can cost be attributed to it?

Review of the Noted the assumptions included in paragraph 2.14 None Noted None IDP regarding review of the IDP over the Plan period to serve future development.

165

ISSUE ORGANISATION(S) SUMMARY OF REP SOUNDNESS TEST RECOMMENDED COUNCIL RESPONSE PROPOSED (insert comment id in CHANGE CHANGE brackets) Comments Wessex Water A major scheme is currently being undertaken at None The information is noted. None (IDP12) Taunton STW to improve the treatment capacity for future development within the catchment. Flood resilience works are also being considered for treatment works within the Wessex Water region.

Support from the local planning authority may be None The local authority would expect to do this through the planning Add reference to required to secure specific requirements for sites process. these projects in where new assets are required or to protect paragraphs 3.55 and existing plant and apparatus. 3.56.

Comments David Orr (IDP 9) The IDP does not appear to have been fully None The IDP assumes nil public funding. It is true that the economic None modelled for a recessionary and slow growth era. climate could affect the rate of delivery but this can be allowed for by regular reviews of the document. East-West Somerset County In 5.7 there is no reference to East-West Greenway East-West Greenway The County Council did not raise the issue of Greenways when None Greenway Council (IDP15) links which are already partly in existence along the links should be identified the IDP was being prepared, so they have not been included. River Tone and Bridgwater & Taunton Canal. and allocated some Also, projects cannot be included without information on likely resources. costs and timescales for delivery. Greenways would need to be incorporated in a future review of the IDP. Comments Fulfords Land and Regarding paragraph 3.49, Western Power None The Borough Council has met with Western Power Distribution None Planning Services on Distribution would normally expect developers to and their concerns have now been resolved. behalf of Western pay for diversion of less strategic circuits of 11kV or Power Distribution below. It would normally seek to retain the position (IDP 29) of 132kV, 66kV and in some cases, 33kV circuits particularly if their diversion placed a financial obligation on Western Power Distribution. Paragraphs referring to undergrounding or diverting power lines are strongly opposed.

166 Sustainability Appraisal

ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in SOUNDNESS TEST CHANGE brackets)

Validity of Natural England (5) • The SA forms a sound None Comments Noted. None Sustainability evidence base for the Core Appraisal Strategy and the economic, social and environmental sustainability of the Published Plan Core Strategy have been satisfactorily assessed following Government Practise guidance. However, the following comments have been provided: Natural England • Given that the Council has its None The SA scoping stage and the Core Strategy plan making process None Difficulties in (5) own ‘in house’ ecological included consultation with both statutory consultees and Council undertaking expertise within the Heritage ecological expertise which have helped to inform the SA on assessing assessment and Landscape team, it is the impact of Core Strategy policies on the environmental value of the surprising to note that the Borough. difficulties in undertaking the assessment included lack of ‘ know how’ in relation to scoring against environmental objectives and, in particular, biodiversity. Heavy reliance Natural England The heavy reliance upon inputs However, it seems clear All Core Strategy policies have been subject to HRA. It is a statutory None upon inputs from (5) from the HRA is of concern since from the SA that, in requirement by the Council to carry out a comprehensive assessment the HRA the biodiversity resources to be practise, the sustainability of the impact of Core Strategy policies on the sites of international maintained, enhanced and objectives employed did importance. SA objectives 1b, 1c and 7a and b however, address restored through the planning extend to biodiversity biodiversity and landscape considerations that go beyond the system extend from the considerations beyond designated sites of European importance. The scoping stage of SA designated sites of international designated sites of included consultation with English Heritage, Environment Agency and importance, through sites of international importance Natural England. The following sources have informed the production national and local importance to and there is no particular of the SA ; Biodiversity Action Plan, PPS9, Taunton Deane Green protected species and biodiversity evidence to form a view Infrastructure Strategy, Somerset Biodiversity Strategy which all give a within the wider environment. that they were not afforded more local understanding of the biodiversity issues affecting the appropriate degree of Borough. weight.

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ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in SOUNDNESS TEST CHANGE brackets)

Development 1. Natural England (5) There is a contrast between the A clearer explanation The SA does not include an assessment of alternative strategic sites None options information presented in respect of within the SA of the for Wellington because in planning policy terms the suitability of such the two main settlements. For appraisal process which sites is limited to the east side of Wellington. Development Taunton, the various alternative led to the selection of encroaching west, south and north of Wellington would not be strategic options for growth that Cades/Jurston as the most acceptable in planning policy terms. The west side is constrained by were considered as strategic appropriate location for an the green wedge separating Wellington from Rockwell green and the urban extensions but not taken urban extension would be south side lies at the foot of the Blackdown Hills AONB and is forward are set out and the results useful. bounded by the A38 and the M5 is within close proximity. of strategic sieving and detailed Development north of Wellington is constrained by the railway line. environmental appraisal that they The suitability of the two strategic sites in Wellington; Cades/Jurston were subject to are summarised. and Longforth have been assessed through both the regulation 25 and By contrast, the alternative options in more detail through the reg27 Sustainability Appraisal. that were considered for strategic urban extensions of Wellington and the results of the appraisal of those alternative options are not summarised.

2.DW Alder Town The SA acknowledges ecological For the Core Strategy to be See response above. None Planning Consultants issues at Cades/Jurston and considered sound, the (14) Longforth Farm but fails to assess evidence base to support it alternative sites that have a lower needs to show the options impact. It is not, therefore, clear that were considered and that alternatives have been the reasons for selection assessed and the most and rejection. appropriate site has been chosen. Rejected Sites WYG Planning & The SA fails to identify why the None The Ford Farm site has not been ruled out on sustainability grounds. None Design (13) Ford Farm site was rejected as a Whilst the suitability of Form Farm has not been reproduced in the development option. Regulation 27 Sustainability Appraisal, it was tested through the reg 25 Sustainability Appraisal and the sheets assigning values are included in the reg25 SA appendices. An explanation of why the Ford Farm site was not included in the Core Strategy is detailed in the Consultation Responses – Core Strategy and Small Sites Consultation Document which states that ‘ until the flood alleviation scheme is completed through the site channel improvement works and ground raising it would be inappropriate to allocate Form Farm for development. Subject to completion of the flood alleviation scheme Form Farm could be included in the Site Allocations DPD which will follow adaptation of the Core Strategy’ If allocated in the Site

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Allocations DPD Ford farm will be subject to further testing through Sustainability Appraisal. Rejected Sites WYG Planning & The SA fails to identify why the None The Killams site has not been ruled out on sustainability grounds. None Design (13) Killams site was rejected as a Whilst the suitability of Killams has not been reproduced in the development option. Regulation 27 Sustainability Appraisal, it was tested through the Reg 25 Sustainability Appraisal and the sheets assigning values are included in the Reg25 SA appendices. An explanation of why the Killams site was not included in the Core Strategy is detailed in the Consultation Responses – Core Strategy and Small Sites Consultation Document which states that ‘Killams attracted 1,222 individual responses, representing over half of the total consultation response….The scale of the response to Killams is a demonstration of localism and for this reason the Council does not propose to allocate Killams as a strategic site in the Core Strategy’. If allocated in the Site Allocations DPD Killams will be subject to further testing through Sustainability Appraisal. Consultation 1.Milverton Action It is not clear that in the None The regulation 25 Sustainability Appraisal page sets a series of None Process Group (9) consultation process the Council questions relating to the proposal for alternative sites which were regarding made allowance for the proposal subject to public consultation in January 2010. The Regulation 25 alternative sites for alternative sites. Sustainability Appraisal indicates the strategic sites considered for allocation in the Taunton Deane Core Strategy as well as their scores 2.DW Alder Town There were no opportunities for None against the Council’s site criteria. Whilst this information has not been Planning Consultants the public to compare options and reproduced in the Regulation 27 Sustainability Appraisal, it was tested (14) consider alternative strategies, through the reg 25 Sustainability Appraisal and the sheets assigning rather they were told what was values are included in the reg25 SA appendices. An explanation likely to happen. regarding sites which were not included in the Core Strategy are The SA fails to identify alternative detailed in the Consultation Responses – Core Strategy and Small sites if some sites did not come Sites Consultation Document. forward.

3.Pegasus Planning The Core Strategy is considered None Comments Noted. Group (11) sound as it is justified based on robust and credible evidence base and provides the most appropriate strategy when considered against reasonable alternatives as set out in the Sustainability Appraisal. Objective on English Heritage A fundamental omission from the None. Comments accepted. PPS5 has been left out from the evidence base. None. cultural heritage (7) evidence base within the SA is However, PPS5 guidance has informed the drafting of the Core

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ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in SOUNDNESS TEST CHANGE brackets)

reference to PPS5 which should Strategy Environment Topic Paper. This document forms an important be in place to then underscore part of the SA evidence base which has been used to underscore policies within the Core Strategy. policies within the SA. Objective 6 To preserve and enhance the The Core Strategy is not, Borough’s built environment, heritage and archaeology is used to therefore, founded on a robust and assess the impacts of Core Strategy policies relating to historic credible evidence base. environment. All statutory consultees were invited to comment on the content of the reg25 Sustainability Appraisal. Monitoring The Theatres Trust (6) The Sustainability Appraisal The monitoring indicators Core Strategy as a strategic plan does not deal with specific arts None indicators monitoring indicators fail to relate of objective 15 should be facilities but the spatial strategy aims to improve and enhance access to the improvement of leisure, revised to include cultural to services and facilities in general through the plans spatial strategy. culture and the arts. The Objective provision such as access Town and other centres will be promoted and enhanced as the 15 do not include cultural provision to arts facilities. primary location for main town centre uses including cultural such as access to arts facilities but development. We do not currently have means or resources to monitor only relate to culture as a sport arts provision in the Borough through the planning system which is the and recreation activity requiring reason access to arts facilities has not been included as one of the green space. monitoring indicators. Compatibility of Milverton Action The Sustainability Appraisal posits None There is likely to be a tenuous link between SA objectives 16 and 1 as The SA should be amended SA objectives Group (9) ‘no link’ between Objective 16 and some biodiversity and wildlife value may be lost as a result of to include a tenuous link Objective 1 and 2. Similarly, the employment growth. This impact is minimised by the fact that most of between SA objectives 1 and appraisal posits ‘compatible’ in the economic development has been proposed within the Taunton 16. relation to Objective 16 and town centre, helping to protect the environmental quality of the Objective 4. These measures do Borough. Other employment development will mostly lie within urban not appear to be robustly extensions where holistic solutions will be promoted, such as the supported in the evidence. creation of country parks. The SA posits no link between SA objective 16 and 2 due to the fact No change has been that employment growth is principally encouraged at Taunton and included. Wellington town centres which will lessen the prospect of developing on greenfield land. There is likely to be a tenuous link between SA objectives 4 and 16 The SA should be amended reflecting the fact that employment growth is likely to increase traffic to to include a tenuous link a degree. This is minimised by the fact that the plan approach between SA objectives 4 and supports self-containment through balancing homes and jobs, mostly 16. within mixed use urban extensions and town centre locations. Alternative DW Alder Town The SA fails to explain and justify None It is not for the SA to justify housing targets. Fordham Study justifies it None. Housing Target Planning Consultants the alternative housing target and as part of its evidence base. Although the housing numbers have (14) how the reduction in housing reduced from the RSS levels, the overall strategy has not numbers from the Draft RSS fundamentally changed. The Council originally objected to the RSS figures reflect local issues and housing figures as they didn’t seem deliverable at the time. The circumstances. The SA also fails evidence base which has underpinned the RSS and the two studies

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to assess how this reduction in which have informed the identification of Monkton Heathfield and target has impacted on the policies Comeytrowe as sustainable locations for urban extensions still remain within the plan. valid. The only difference relates to timing and phasing of development at Comeytrowe which is now proposed at the later stage in the plan period. It is not possible for the SA to assess time implications i.e. the likely impact of different phasing options on local issues and circumstances. Employment and DW Alder Town The SA fails to compare None It is not for the SA to justify the economic led approach. The Council None housing led Planning Consultants employment led and housing led made a decision to support pro-growth agenda. The state of the approaches (14) approaches. economy in 2011 points towards many of the assumptions about growth over the RSS period: 2006 – 2026 being overly optimistic. Taking the economic led approach, and with the aim of matching additional jobs with additional homes, this equates to Taunton Deane dwellings requirements far less than the levels of growth associated with the housing led approach. This proves the higher growth options to be a more unsustainable option. The economic growth agenda is thus more sustainable in terms of being commuter neutral. Framework for Somerset County The scoring of various None The scoring of various development options is summarised and the None scoring Council (8) development options is stated but matrix is explained on page 37. The sheets assigning values are not explained. Although the included in the appendix section of the SA. framework for scoring has been Originally through the Reg25 SA we had planned to adopt a scoring included; the sheets assigning framework to proposed allocations but decided on alternative values have not been included in approach. Although the main difficulty with including unweighted the report so it is difficult to scoring to sites is that this does not accurately bring out issues which comment on the outcomes. may prevent development altogether or at least be weighted more strongly against it. With this in mind, the framework applied to assess the sites does allow a more comprehensive assessment in terms of giving environmental, social and economic considerations an equal weighting. The scoring system fails to identify The scoring mechanism applied to the specific sites remains in the None features which should have more earlier draft SA and will still form the basis for more detailed weigh in decision making than consideration of non-strategic sites and those rejected since the others and where the ‘show Council considers that the appraisal of strategic options is sufficiently stoppers’ exist. Therefore, it is robust to ensure the identification of the most sustainable and considered that the assessment appropriate sites. could be unsound. Inappropriate Barton Willmore LLP Confusion caused by the different None All development options and Core Strategy policies have been None scoring applied to on behalf of levels of development being assessed on the basis of their status in the Core Strategy at the time sites Comeytrowe considered at different times of Core Strategy preparation. For example, in the case of Broad

171

ISSUE ORGANISATION(S) SUMMARY OF REP RECOMMENDED COUNCIL RESPONSE PROPOSED CHANGE (insert comment id in SOUNDNESS TEST CHANGE brackets)

Consortium (10) and/or options considered. locations such as Comeytrowe certain sustainability considerations The SA fails to support an early and scores assigning values may be subject to change when certain release of 2,000 dwellings but infrastructure improvements have been carried out. All broad locations which would not prejudice the including Comeytrowe willl be reviewed and may be included in the development of a further 6000 Core Strategy at the later stage. In this case, Comeytrowe would be dwellings (given the significant subject to further Sustainability Appraisal. capacity available in the area to accommodate a major mixed use development in the area).

Welcome many of the general The SA contains some The studies identified in the SA which have assessed the potential None findings of the SA and its evidence inconsistency which should constraints associated with the South West Sector are based on a base (Some studies identified in be addressed. robust evidence base and no new or further evidence has been the SA do not assess accurately provided to suggest otherwise. In the case of Comeytrowe, the the potential constraints conclusions of studies in 2004 and 2005 which recognise Comeytrowe associated with the South West as the second most sustainable location for a strategic urban Sector when compared to other extension remain sound in the recent economic and demographic sites. projections but the scale and complexity of transport, foul and surface water drainage and green infrastructure provision for a strategic mixed use urban extension necessitates a comprehensive pasterplanning approach and therefore a piecemeal approach to development will not be acceptable. Development at Mrs Wendy Sargent Support for the contents of the None Comments Noted. None. Oake (2,3) Sustainability Appraisal for not supporting development at Oake for the following reasons: Oake has limited services and there is no road infrastructure to be able to accommodate more cars. There are problems with traffic jams and parking availability. Affordable housing would not be suitable due to lack of facilities.

172 CORE STRATEGY SCHEDULE OF CHANGES

The schedule has been divided into Technical and Soundness Changes.

Technical Changes in the schedule below are minor amendments, generally matters of consistency, which officers have identified.

Soundness Changes are minor amendments which have been recommended by respondents asserting that the plan is unsound, but officers have made no judgment as to whether these are matters of soundness.

TCI (Technical Page/para Change Changes) Strategic Objective 5 13, para 2.23, “TDBC has a number of strategies that address provision and access to, inter alia, allotments, built sports (Inclusive insert following facilities, community halls, green space, playing pitches, young children’s and young peoples play space. We Communities) after first are also partners for a range of county-wide strategies that aim to identify issues and address findings for, inter sentence: alia, children & young people, child poverty, financial inclusion, homelessness, Priority Areas, strategic needs, older persons, housing and tenancy. In addition there are numerous stakeholder studies and reviews which provide in-depth studies and actions for addressing inequality, such as Strategic Review of Health Inequalities and Somerset Annual Public Health Report ” Strategic Objective 5 13, para 2.24, “…issues of rural isolation which that need to be addressed. A range of county-wide strategies identifies in (Inclusive amend second more detail individual issues for specific sections of the community. Whilst the…” Communities) sentence and add sentence as follows: Strategic Objective 5 13, replace para (Inclusive 2.25 with Table Indicator of Target Source Communities) 2.5 Measuring achievement Success Improving By 2015 a minimum of 6.85 ha per 1000 population of Open Internal Monitoring indicators, targets amount and Space provision and sources as quality of follows: Open Space By 2015 a minimum quality rating of 4 (good) for all Open Space provision provision Improving Reduce the mortality rate for cardio-vascular disease for people NHS Somerset

173 TCI (Technical Page/para Change Changes) Health under 75 years to 40.95 per 100,000 directly aged standardised population by 2013/14 Annual Monitoring, NHS Somerset Year on year reduction in the percentage of people with limiting long term illnesses Sport England

Year on year increased in life expectancy at birth

Year on year increase in percentage of adult sport and active recreation participation, at least three sessions a week, 30 minutes, moderate intensity on at least 12 days out of the last 4 weeks. Improving Year on year increase in the percentage of 16year olds achieving Annual Monitoring education and 5+ GCSE at grade A*-C Learning Department for Increase in the percentage of working age population with NVQ Education level 3+ qualification

Reducing Year on year reduction in the crime rate Annual Monitoring Crime Year on year increase in the percentage of residents who feel Home Office fairly safe & very safe a) after dark and b) during the day Indicators of Reduction in the number of SOA’s with the upper most deprived Indices of Multiple deprivation nationally depravation

Reduction in the number of SOA’s with the upper 10% IMD barriers to housing and services Increase in Year on year increase in the percentage of the population Annual Monitoring economic economically active activity Annual Population Year on year increase in the average gross weekly earnings of full Survey

174 TCI (Technical Page/para Change Changes) time residents Annual Survey of House and Earnings Workplace Analysis Maintaining or Maintain or increase the level of rural services in Taunton Deane Annual Monitoring increasing Services and Community Halls within a 1 mile radius of new developments Internal Monitoring facilities Increasing Year on year increase in the percentage of completions in Annual Monitoring amount of sustainable settlements Housing in Sustainable locations Policy SP1 50, Amend last “Outside of the established settlements identified above, proposals will be treated as being within Open Sustainable paragraph as Countryside.” Development follows: Locations Policy SP1 52, 4.7 amend “It is not the intention to accommodate further allocations in these villages, but to recognise that there should Sustainable last sentence of some scope for continued infilling within existing settlement limits.” Development paragraph as Locations follows: Policy SS1 70, amend first “Phased delivery of around 5,000 4,500 new homes at an overall average of 35-40 dwellings per hectare; bullet: Policy SS1 Monkton 70, amend third “sheltered housing provision;” with “care and residential accommodation for the elderly;” Heathfield bullet point by replacing: Policy SS1 Monkton 71, Insert new • “A well defined green edge to the urban area that protects views from Hestercombe House and the Heathfield final bullet point Quantock Hills.” (to accord with Policy SS2): Policy SS3 Wellington 81, Insert new • “25% of new homes to be affordable homes in line with Policy CP4: Housing;” Longforth second bullet point of policy:

175 TCI (Technical Page/para Change Changes) Policy SS4 Wellington 86, Insert new • “25% of new homes to be affordable homes in line with Policy CP4: Housing;” Cades/Jurston second bullet point: Proposals Map Proposals Map Amend ‘Key’ on Proposals Map and Inset Maps 1 and 3 to state “Water Source Protection Zone CP1, CP8: and Inset Maps 1 Climate Change and Environment” and 3 Proposals Map Taunton Town Amend lower box to read: Centre Map Core Strategy and (Saved Taunton Deane Local Plan Policies) Amend key to read: Area of High Archaeological Potential CP8 EN23 Remove duplicate notation showing County Archaeological Site Town Centre Boundary CP3 (M2) (M4) Proposals Map Inset Map Key Amend key to read: (accompanying Core Strategy and (Saved Taunton Deane Local Plan Policies) Maps 1 and 3) Area of High Archaeological Potential CP8 EN23 Remove duplicate notation showing County Archaeological Site Town Centre Boundary CP3 Central Area (M2) (M4)

SCI (Soundness Change) Page/para Change Vision for the Borough 5, Amend third paragraph “Employment led growth … It will help enable the Borough to consider, mitigate and adapt to the possible effects of climate change,” Strategic Objective 1 Climate 6, Amend Table 2.1 to Row 2, Target “… from 2006 baseline”. Change read: Row 3, Target “… from 2010 baseline”. Row 4, Target “ … planning permission from 2012 baseline”. Strategic Objective 1 Climate 6, Amend Table 2.1 to ‘Modal Share’ criterion b. to read 34.3% Change read, Strategic Objective 3 Town 9, Amend Objective 3 to “… appropriate scale for retail, leisure, cultural, sporting, office and other town centre activities and Other Centres read: …”

176 Strategic Objective 3 Town 9, Amend paragraph 2.20 “Regeneration of Taunton town centre (through the Area Action Plan) will retain and enhance and other Centres to read: its role and focus for employment growth, shopping, leisure, nationally significant cultural and sporting activity within the sub-region, which extends over western Somerset and into eastern Devon, and in the south-west generally. Wellington town centre will …” Strategic Objective 3 Town 10, Amend Table 2.3 row 2 “Completed cultural floorspace” and Other Centres to include

Amend Table 2.3 row 3 to include “Completed cultural floorspace” Strategic Objective 6: 15, Table 2.5 Add reference to walking and cycling target times to primary schools (further work is needed to Accessibility decide what these should be). Strategic Objective 6: 14, Paragraph 2.29 Add an “ It needs to be recognised, however, that the planning system can not address the policies of Accessibility additional sentence: service providers that have led to centralisation of facilities in larger centres and reduction in rural transport provision.” Strategic Objective 6: 14, Paragraph 2.27 Rewrite 2.27 to read: “Development in the Borough needs to planned in a way which minimises Accessibility use of the M5 for short-distance commuting and other journeys, particularly where this involves ‘junction hopping’. At the same time, there is also a need to encourage modal shift for longer- distance journeys, since these account for the majority of carbon emissions from transport.” Strategic Objective 6: 14, Paragraph 2.26 Amend ‘…in Taunton – which has looked at the impact of growth across the town as a whole - Accessibility final sentence of paragraph suggests that, to reflect best practice ‘eco standards’, at least 50% of all trips should be 2.26 to read: undertaken by modes other than the private car.’ Strategic Objective 7: 16, Amend objective SO7 “To ensure that development provides or contributes to the on- and off-site infrastructure…” Infrastructure to read: Strategic Objective 8: 17, Amend objective “To maintain and enhance biodiversity, the natural and man-made environment, heritage Environment minimising the need to travel, waste, pollution and the use of non-renewable resources and to promote good design and materials which respect and enhance local distinctiveness.” Strategic Objective 8: 18, Table 2.7, amend first “Increase in line with Somerset Woodland Strategy 2010 from current coverage of 7.62% to Environment indicator target 8.7%” Strategic Objective 8: 18, amend sixth indicator Indicator: “% of waterbodies river length of achieving Good Ecological Status (or above) Environment and target biological quality” Target: “Increase from 2009 2008 baseline data.” Policy CP1 19, Amend policy CP1 g. to “Their scale, form, design, materials and cumulative impacts can be satisfactorily assimilated Climate Change read: into the landscape or built environment and would not harm the appearance character of these areas and has no overriding impact on the amenity of the area in respect of noise, dust, odour and traffic generation”

177 Policy CP1 22, Amend Paragraph 3.16 “All renewable energy proposals including wind farm developments should be sensitively Climate Change to read located to avoid any significant harm to the landscape, including the qualities for which any national designated landscapes have been recognised, and equally to avoid harming the ecology of the Borough and to offset potential impact on wildlife. Any development …” Policy CP1 22, Amend paragraph 3.17 Replace “English Nature” with “Natural England.” Climate Change to read: Policy CP1 22, Amend paragraph 3.17 “Lead Delivery Body: Taunton Deane Borough Council as Local Planning Authority and Climate Change to read: Somerset County Council as Transport Authority and Waste Planning Authority in cooperation with partners including …” Policy CP2 Economy 26, Amend Table 3.1, “* Taunton town centre and other allocations in the TCAAP Retail, Broad location to * Wellington …” read: Policy CP3 Town and other 28, Amend policy SP2 “Focus shopping, leisure and other employment growth towards town centre and then other centres (second bullet) to read: identified regeneration opportunities outside of the town centre delivered through the adopted Town Centre Area Action Plan”. Policy CP3 Town and other 29, Amend paragraph 3.41 “… Taunton town centre is the major driver for economic growth within the Borough, providing centres to read: the retail, leisure, cultural, sporting and office focus for a catchment population of over 350,000” Policy CP3 Town and other 30, Amend paragraph 3.49 (commencing line 6) “…compounded by the fact that adequate land has been made available centres to read: within town centres as well as edge of centre sites in Taunton town centre as identified on the Inset Map to more than meet projected demand. The Plan has therefore …” Policy CP5 Inclusive 34, Amend first paragraph “Development proposals will promote sustainable development that creates social cohesion Communities to read: and inclusive communities; reduces inequalities, promotes personal well-being and addresses accessibility to health, inclusive housing, training, education, places of worship, leisure and other community facilities ensuring better quality of life for everyone both now and for future generations.” Policy CP5 Inclusive 34, Amend 7th bullet point “Services, Community and Social Facilities – providing a range of education, health, indoor Communities to read: sports, retail and meeting spaces as well as access to sustainable transport and high speed broadband.” Policy CP5 Inclusive 34, Amend 8th bullet point “Recreational Space – improving health and interaction through provision of formal and Communities to read: informal green space such as, play spaces, allotments, playing pitches, sports facilities as well as promoting walking and cycling.”

178 Policy CP5 Inclusive 35, Amend paragraph 3.71 “3.71 Many of the Boroughs rural communities are disadvantaged by barriers to housing, poor Communities to read: access to facilities and severely limited by public transport. New development in rural areas must therefore include a high proportion of affordable housing. There is therefore a need to bring forward affordable housing in rural areas and ensure all new development is well related to existing facilities and services. It is also vital that these communities have good access to utility infrastructure, such as gas, to reduce dependency on oil, energy efficient homes to reduce fuel poverty, and services such as high speed broadband to enable community diversification and support rural businesses, services and facilities. [new formatting] “3.72 A range of accommodation is vital throughout the Borough to promote integration and provide balanced communities. Sustainable (economically, socially and environmentally), mixed communities; which promote integration, for the benefit of all members of society are essential throughout the Borough. A range of transport modes; walking, cycling and excellent public transport is also essential for a balanced community by enabling good access to employment, services and facilities. 3.72 becomes 3.73 3.73 becomes 3.74 3.74 becomes 3.75 3.75 becomes 3.76 Policy CP5 Inclusive 35, Amend paragraph 3.74 “…which will require adaptability of homes, and a range of specialist housing as well as such Communities to read: as provision of Care and Residential Institutions, including, inter alia, Extra Care Housing Schemes, Close Care, Assisted Care housing and Continuing Care Retirement Communities. Increased demand….” Policy CP6 37, Policy CP6 reword first “…and mitigate and adapt to climate change.” Transport and Accessibility sentence to read:

Policy CP6 37, Policy CP6 “…and Taunton East, and from rural centres and villages to the main towns;” Transport and Accessibility add the following at the end of the second bullet point: Policy CP6 37, Policy CP6 “Requiring all developments which are likely to have significant transport implications to submit Transport and Accessibility Amend fourth bullet point: a robust evidence base and management plan in line with current policy and guidance on Transport Assessment, and Travel Planning and the County Council’s Travel Plan SPD” Policy CP6 37, amend sixth bullet “…in accordance with the Local Transport Strategy to reduce…” Transport and Accessibility point:

179 Policy CP6 37, Amend second “In particular, efforts are needed to encourage longer-distance journeys to be made by train, Transport and Accessibility sentence of paragraph 3.82 and the adopted Taunton Town Centre Area Action Plan…” to commence: Policy CP6 38, New paragraph after “There is a clear link between sustainable transport and accessibility, and public health Transport and Accessibility 3.84: policies. Health promotion strategies need to be embedded in future transport plans throughout Taunton Deane to promote primary prevention of poor health.” Policy CP7 40, amend paragraph 3.96 “…Somerset’s Local Investment Plan: Somerset’s Future Transport Strategy; New Homes Infrastructure to read: Bonus…” Policy CP8 Environment 41, amend policy CP8 third “A network of green infrastructure assets has been identified and should be retained and paragraph: enhanced, including through the development of green wedges and corridors as envisaged through the Taunton Deane Green Infrastructure Strategy.” Policy CP8 Environment 41, amend policy CP8 third “Developments will be expected to adopt Natural England’s Accessible Natural Green Space paragraph: Standards (ANGSt) and contribute to realising the opportunities identified within the Taunton Deane Green Infrastructure Strategy.” Policy CP8 Environment 41, amend policy CP8 “Development will need to mitigate or and where necessary, compensate for adverse impacts fourth paragraph: on landscape, protected or important species, important habitats and natural networks , river and ground water quality and quantity so that there are no residual effects.” Policy CP8 Environment 41, amend policy CP8 fifth “as set out in the Strategic Flood Risk Assessment Level2. Site specific measures within paragraph: development sites will not be sufficient mitigation to accord with PPS25. Development sites will need to ensure that flood risk is not exacerbated from increased surface water flows by ensuring that existing Greenfield rates and volumes are not increased off-site through the adoption of multi-functional SuDs. The Council will seek to improve flood risk and mitigate for the impacts of climate change within Taunton Deane (and in particular the Taunton urban area) through the provision of a strategic flood attenuation scheme to which development sites will need to contribute. A strategic flood attenuation scheme, funded by contributions from development, is proposed on the River Tone between Taunton and Wellington to reduce flood risks downstream. Policy CP8 Environment 42, amend bullet 5 to read: “not exacerbate, and where possible improve the quality, quantity and availability of the water resource, reduce flood risk (fluvial and surface water); and” Policy CP8 Environment 42, amend sixth bullet • “protect habitats and species, including those listed in UK and Local Biodiversity Action point: Plans, and conserve and enhance expand the biodiversity of the Plan Area.”

180 Policy CP8 Environment 43, add to para 3.103: “We have been working closely with the Environment Agency who support our long-term objective of reducing flood risk and the impacts of climate change in the Taunton urban area. An initial inception study has been completed which identifies a preferred option of long term storage on the River Tone between Taunton and Wellington to reduce flood risks downstream. The Council will also consider the use of green spaces to contribute to flood alleviation (as recommended by the Green Infrastructure Strategy and paragraph 3.12 of the Core Strategy) as well as the modification of existing infrastructure (for example, de-culverting of watercourses and improving existing flood risk infrastructure) to alleviate flooding.” Policy CP8 Environment 43, amend final sentence “Risk should be reduced by safeguarding land from development that is required for current of 3.103 to read: and future flood management, incorporating sustainable drainage systems (SUDS) and using opportunities offered by new development to reduce the causes and impacts of flooding, such as making the most of benefits of green infrastructure for natural flood attenuation through woodland and wetland creation, flood storage, conveyance and SUDS.” Policy SP1 Sustainable 49, amend first para as “In order to create and maintain sustainable, balanced communities, provision will be made for Development Locations follows: the delivery of new services, facilities and infrastructure including the creation of at least 11,900 jobs and about at least 17,000 new homes… Policy SP1 Sustainable 52, amend para 4.12 as “Site Allocations and Development Management Plan Document to be adopted in 2014; Urban Development Locations follows: Extensions SPD to be adopted in 2012 2013” Our Vision for Taunton 54 last para of Vision add: “AONB” after “Quantock Hills” Policy SP2 Realising the 55, Amend second bullet “Focus shopping, leisure, sport and cultural development and other employment growth vision for Taunton point to read: towards..” Policy SP2 Realising the 55, Insert in fifth bullet “places of worship,” after “community halls,” vision for Taunton point: Policy SP2 Realising the 58, add to end of 4.31: “, with the optimum solution identified and secured through a robust travel plan. “ vision for Taunton Wellington Spatial Portrait 60, Amend 4.33 to read: “4.33 Wellington is the second largest settlement in Taunton Deane Borough and the sixth biggest settlement in Somerset.” Policy SP3 Realising the 61, Amend first bullet point “The beautiful market town of Wellington is the second largest in the Borough and the 6th Vision for Wellington to read: biggest settlement in Somerset, supporting a wide rural hinterland extending into adjoining districts to the west and south…”

181 Policy SP3 Realising the 61, Amend third bullet point • “Deliver around at least 2,500 net additional dwellings Vision for Wellington to read: • Assuming tThe relocation of Relyon and Swallowfield to the eastern part of Longforth and the mixed use regeneration of their existing premises to the include a new local centre on Station Road has been completed, beyond 2028 the Vision indicated longer-term potential for growth to the north of the Town at Tonedale;”

Policy SP3 Realising the 62, Amend SP3 ninth “Provide a Northern Relief Road for Wellington as an integral part of the proposed Vision for Wellington bullet point: development at Longforth and an eastern relief link road as an integral part of the development at Cades/Jurston; and” Policy SP3 justification 62, Amend 4.44 to read: “Wellington in view of its sensitive location as a gateway to the Blackdowns Blackdown Hills as well as the rich array of wildlife and biodiversity at the fringe.”

Policy SP4 Realising the 66, amend bullet point 1 to “Provide small-scale local opportunities for employment growth including tourism and rural vision for the rural areas read: diversification” Policy SP4 Realising the 66, amend bullet point 3 to “Deliver around at least 1,000 1,500 net additional dwellings (including existing planning vision for the rural area. read: consents and allocations)” Policy SS1 Monkton 74, new paragraph, after “The concept plan for Monkton Heathfield shown on page 73 is evolving and further Heathfield para 5.16 engagement will take place as the Masterplan and SPD is progressed to guide the submission of any planning application. The plan must be viable and deliverable and result in a coordinated approach to development. The justification for the distribution of land uses will be supported by the evidence base for the development of Monkton Heathfield”. Policy SS2 76, Amend first bullet point • “Phased delivery of around 900 new homes at an overall average of 35-40 dwellings per Priorswood/Nerrols of policy: hectare:” Policy SS2 76, Amend fourth bullet “general industrial (B2)” Priorswood/Nerrols point of policy by deleting Policy SS2 77, 5.22 Add at end of “In June 2010 the Council agreed that Interim Sites of about 300 dwellings each be released to Priorswood/Nerrols para: contribute towards the shortfall in the 5 year supply of housing land in Taunton Deane.”

Policy SS2 78, 5.25 Delete: “general industrial (B2)” Priorswood/Nerrols Policy SS3 Wellington 81, Amend first bullet point • “Phased delivery of around 900 new homes at an overall average of 35-40 dwellings per Longforth of policy: hectare:”

182 Policy SS4 Wellington 87, 5.50 Add at end of “In June 2010 the Council agreed that Interim Sites of about 300 dwellings each be released to Cades/Jurston para: contribute towards the shortfall in the 5 year supply of housing land in Taunton Deane.”

Policy SS6 Staplegrove 92, Amend para 5.69 first “A structural landscaping belt 20 metres wide is proposed along the outer edges of the sentence development areas. and The existing 132kv overhead lines are a design constraint proposed to be diverted. “

Policy DM1 General 99, Amend criterion d. e. “Unacceptable” before the word “harm” or “harmed”. Requirements and f. to include: Policy DM2 Development in 102, Amend heading of 4. “Agriculture, forestry and related” the countryside policy DM2.4 to read:

Policy DM2 Amend policy DM2.4.a to “new storage non residential agricultural and forestry buildings commensurate with the role read: and function of the agricultural or forestry unit”.

Policy DM2 Development in 102, Additional category: “8. Development for essential utilities infrastructure.” the countryside Policy DM3 Gypsy and 106, Amend second “Where sites are not available consideration should be given to sites adjoining or adjacent to Traveller Site Selection sentence of Policy DM3 to existing settlements (and in particular land associated with strategic urban extensions).” Criteria read: Policy DM4 108, Amend fourth bullet “Village design statements and similar; and” Design point of DM4 to read:

Policy DM4 109, additional sentence at It is also important to ‘design out’ crime, and the principles set down in the UK police initiative, Design end of paragraph 6.26: ‘Secured by Design’, should be incorporated into development proposals.

Policy DM5 Use of resources 112, Amend paragraph “The carbon reduction targets se out in policy DM5 are based on current requirements and and sustainable design 6.40 to read: policy although it is acknowledged that these may be subject to change or superseded by changes to national policy. Although the Council is keen to encourage higher and faster …” Proposals and Inset Maps Amend ‘Key’ on Proposals “Water Source Protection Zone CP1, CP8: Climate Change and Environment” Map and Inset Maps 1 and 3 to state Appendix 3 Glossary 132, add definition of Concept Plans illustrate the principles of development, but not the precise alignment of roads Concept Plan or disposition of land uses.

183 132, add definition of Key Key Diagram is a strategic representation of development proposals. Diagram Infrastructure Delivery Page/para Change Plan Defining Infrastructure 5 Add reference to the Bridgwater & Taunton Canal in Table 2.1 Add libraries and allotments to Table 2.1 Physical Infrastructure 19 In 3.55 and 3.56, add reference to support from the local planning authority being potentially needed to secure specific requirements for sites where new assets are required or to protect existing plant and apparatus. Arts and Culture 30 Add reference to church halls to the second sentence of 4.52. Community and Voluntary 32 Add reference to places of worship to the second sentence of 4.68. Sectors Emergency Services 29 Amend paragraph 4.48 to refer to the intention of Avon & Somerset Police to seek contributions from development, following the nationally advised approach from the Association of Chief Police Officers (ACPO). Summary of Infrastructure 41 and 43 Amend Tables 6.1 and 6.2 to state that the Borough Council and Environment Agency are joint Requirements lead organisations on flood defences for new development. Add reference to the Brewhouse under Art and Culture in Table 6.2. Sustainability Appraisal Page/para 35 amend table Include a tenuous link between SA objectives 1 and 16 and 4 and 16.

184 CORE STRATEGY KEY ISSUES

Summary of Issue Council Response

1. Town centre boundary Over the Plan period Taunton town centre will need to expand to meet projected floorspace requirements for town centre uses. The PPS4 Good The boundary has been drawn too widely and therefore includes sites that Practice Guide recommends a proactive approach to defining boundaries to under national policy should be considered edge or out of centre. It should be accommodate future needs within defined centres. Proposals are phased in clarified that only High Street falls within the town centre for the purpose of the Taunton Town Centre AAP to prioritise and promote retail development PPS4 around High Street until 2016, consistent with guidance. The Proposals Map also defines the primary shopping area and PPS4 defines ‘edge of centre’ without the need for repetition in the Core Strategy. High Street for example is defined within the primary shopping area, Firepool is not. It would be wrong to define the Town Centre boundary for purely retail purposes. It also encompasses other town centre uses such as leisure and offices. The boundary is therefore correctly drawn. 2.The validity of strategic housing targets It is contended that the Proposed Changes rate of delivery would prove undeliverable for Taunton Deane given current economic climate and state of Housing figures are not justified on the basis that RSS evidence base should the housing market. The required residual rate of delivery would now exceed be taken into account in arriving at housing figures. The methodology 1,300 dwellings per year. applied by the Fordhams Locally Balanced Housing Projection is challenged. The Fordhams LBHP is based upon a locally derived approach drawing upon over 2,000 household surveys undertaken as part of the Council’s SHMA. It is contended that by running the latest ONS projections and replacing local employment migration elements with primary data derived from the SHMA before applying the Councils jobs-led scenario, the Council can rely upon a realistic but still challenging housing target which will meet housing need over the plan period and demand arising from the Plan’s aspirations for growth.

3. Appropriateness of phasing mechanism Figures are expressed as ‘at least’ and phasing should not be taken as a cap on development over a particular time period where this accords with the Phasing should not be used solely on the basis of employment creation, this principles and policies set out in national planning policy and the Core fails to take into account other factors which drive housing demand e.g. Strategy. population change, demographic changes, affordable housing need. It should also be noted that the Council’s approach to phasing its housing

185 Summary of Issue Council Response

requirements was recently supported at a Section 78 Planning Appeal. The Inspector noting that there was: “some logic in the approach given that economic activity affects to a degree migration into and out of an area so that a downturn would depress need as well as demand”. Appeal Ref: APP/D3315/A/10/2140103 - Land at Maidenbrook Farm, Taunton (para 27)

4. Lack of a five year deliverable supply of housing sites The Council is now in the process of reviewing its Strategic Housing Land Availability Assessment so as to ensure it can provide a forward looking In-light-of representations on the validity of housing targets, use of phasing assessment over the period April 2012 – March 2017. Since the Council and implications of draft NPPF, the Council is unable to demonstrate a five does not accept that either its housing numbers are too low, or that phasing year deliverable supply of housing land. is inappropriate, any assessment will be framed against the targets and phasing set out in the Published Plan Core Strategy. The NPPF remains a consultation document (and one that has attracted a significant volume of representation). Given that a good deal of this representation will relate to the ‘20% requirement’ very limited weight should be attached to this particular provision of the draft policy. Particularly, as there seems to be some uncertainty and confusion as to its application. The Council will continue to take practical steps to identify sites which can come forward and make a contribution towards its five year deliverable supply of housing land, irrespective of changes to national planning policy.

5. Clarification of Core Strategy, IDP, Interim Policy and CIL In drawing up its infrastructure proposals, the Council has produced an IDP in accordance with PPS12; has drawn on guidance from the Planning The relationship between the Core Strategy and the IDP and whether the IDP Advisory Service, and has engaged with a wide range of stakeholders. It has is sufficiently comprehensive; whether the Council’s proposals are compliant also taken account of the CIL regulations and relevant circular advice. The with the policy tests in Circular 05/2005 and the CIL regulations; the extent proposals in the Core Strategy and IDP are therefore underpinned by sound to which infrastructure costs can be covered by developer contributions and evidence, including the viability of development. The Council has also set how any shortfall will be addressed; whether the introduction of CIL is out how priorities for funding will be established given inevitable constraints appropriate and the extent to which the cost of infrastructure will be covered on resources. The Council proposes to adopt an interim policy for developer by it; and the status of the interim policy that the Council proposes to adopt in contributions in January 2012, covering the period prior to the introduction of the period before CIL is introduced. CIL in early 2013. Proposals for CIL will be brought forward in accordance with the regulations during 2012-13, and there will be full consultation with those affected.

186 Summary of Issue Council Response

6. Role and function of Cotford St Luke In terms of their size, range of services and employment the Major Rural Centres of Wiveliscombe and Bishops Lydeard are in a different league to In Policy SP1 Cotford St Luke is identified as a Minor Rural Centre, but other rural centres in Taunton Deane. In terms of its smaller size and more representations variously suggest it should it be upgraded to a Major Rural limited range of services and employment Cotford St Luke sits comfortably Centre and downgraded to a Village. alongside the other designated Minor Rural Centres. The Villages are much smaller and have a very limited range of services and little or no employment.

7. Allocation of Monkton Heathfield as a major urban extension The proposals for Monkton Heathfield have been in the public domain for around 10 years, stemming from the Taunton Vision Commission (2002) There has been no defined point in the process when Monkton Heathfield through the Urban Extension Study (2003/4), the Sub Area Study (2004/6) was clearly identified for additional growth. There has been no Plan B. and the RSS proposal (2007). All these studies included public engagement and assessment of alternative options. The Core Strategy does not focus all development to Monkton Heathfield. Comeytrowe, which is proposed to commence post 2016, will be ultimately larger than Monkton Heathfield,, other allocations are made through the Core Strategy, the adopted Taunton Town Centre AAP and the future Site Allocations DPD will also contribute.

8. Traffic implications of developing Monkton Heathfield A range of detailed studies and modelling work covering transport requirements arising from the strategic allocation has been undertaken and The provision of transport infrastructure to cope with the increase in tested. The County Council and Highways Agency have both confirmed that population at Monkton Heathfield is inadequate the approach undertaken is satisfactory.

9. Housing delivery at Monkton Heathfield As a result of recent masterplanning work and meetings with Persimmon and Redrow to agree the delivery assumptions, these have been revised and the The delivery of 5,000 homes at Monkton Heathfield over the Plan period is Council has reduced Monkton Heathfield to 4,500 dwellings. The UI unreasonable due to build rates and the current global recession. Residential commission includes work on economic viability and housing delivery growth should thus be better distributed. (Taunton Urban Extensions Strategic Sites Delivery Plan April 2011 – document included in the revised evidence base).

10. Masterplanning of Priorswood/Nerrols The Council has commissioned a team of consultants led by Urban Initiatives to prepare a masterplan and design codes for both Nerrols and Monkton The policy is not effective because it contains no requirement for a Heathfield urban extensions. This work is progressing and will be the subject comprehensive masterplan for the area. of further stakeholder and community engagement leading to its adoption as

187 Summary of Issue Council Response

a Supplementary Planning Document to the Core Strategy. It is therefore unnecessary for the policy to include a requirement for a comprehensive masterplan for the area. 11. Staplegrove should be recognised as a Strategic Site allocation The eastern part of Staplegrove is affected by Lesser Horseshoe bat rather than a Broad Location foraging. Compensatory woodland planting will take up to 10 years to become established. The quantum of development needs to be determined Whilst land at the western end of the area may not be available in the short through an overall masterplan. term, this need not prevent the area east of Mill Lease stream from being forward within the first five years of the Plan Period. The site should be included as a Strategic Site allocation with overall potential for approximately 1,800 dwellings. 12. Comeytrowe should be recognised as a Strategic Site allocation To release part of Comeytrowe in advance of agreeing a comprehensive rather than a Broad Location masterplan which has been subject to full public consultation would risk failure to make adequate developer contributions towards provision of the The Core Strategy should make a specific allocation for a “strategic site” on infrastructure required to serve an urban extension of up to 8,000 dwellings. the northern part of Comeytrowe for 2,000 dwellings. There is no good The proposal to allocate 2,000 dwellings now is based on utilising the limited reason to delay the start of development until 2016 – it should start as soon capacity in existing infrastructure systems. This could undermine the viability as possible. A masterplan should still be required to identify the potential for of major new infrastructure required to serve the urban extension of up to the southern part of the area, which should be identified as a broad location 8,000 dwellings, but also by using up all the existing capacity could prevent for development of up to 6,000 dwellings. The proposal for 2,000 dwellings small sites in the south western sector of Taunton from coming forward. A neither requires a commitment to further development to make it viable and piecemeal approach to development of Comeytrowe/Trull would represent deliverable, nor predetermines the outcome of the subsequent cherry picking and is therefore resisted. masterplanning of the wider area.

188