Burnham-on-Sea & Highbridge Urban Extension District Council 2010

Contents

1 Introduction 2

2 Context 3

3 Proposed Change to the Core Strategy 5

4 How to make Representations on this Addendum 7

5 Supporting Information 9 2 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

1 Introduction

1.1 This document is published for formal consultation between 23rd November 2010 and 18th January 2011 as an addendum to the Council’s published Core Strategy. It sets out a ‘focused change’ specifically relating to Policy P3: Burnham-on-Sea & Highbridge.

1.2 The Council published its Proposed Submission Core Strategy for formal consultation in September 2010. This consultation ends on 22nd November and invites representations on the legal compliance and soundness of the proposals and policies contained within it. However, as part of this ongoing consultation period a number of informal comments have been made in respect of Policy P3 specifically relating to the non-identification of a broad location for the proposed urban extension to the town.

1.3 These comments have led to the Council reconsidering its approach away from deferring the identification of the urban extension to a later site allocations document and instead towards identifying a broad location within the Core Strategy. The Council considers this would be beneficial for a number of reasons including:

Clarification for the local community and key stakeholders as to the location of the urban extension; Consistency with PPS12: Local Spatial Planning which advocates the identification of broad locations and sites where it is of strategic importance; Increased certainty for landowners and developers and opportunities for a more expeditious planning process; Clearer demonstration that the proposal (and its objectives) are deliverable; and Greater efficiency in the use of Council resources

1.4 To ensure that this ‘focused change’ to the Core Strategy does not undermine its legal compliance and/or soundness, this addendum is subject to an eight week consultation period to enable the Council to consider the views of the key stakeholders and the local community on this proposed approach. No changes are being proposed to the overall spatial strategy or other proposals and policies of the Core Strategy.

1.5 The next section of the addendum outlines the original version of Policy P3 as it appears in the proposed Submission Core Strategy and its intention at that stage. Section 3 includes a proposed ‘tracked change’ version of Policy P3 and relevant supporting text. This sets out the proposed changes to the policy and supporting text, including the identification of the preferred broad location, being suggested by the Council and consulted upon under this addendum. Section 4 advises on how to make representations on this 'focused change' and Section 5 provides some supporting justification for the preferred location of the urban extension.

1.6 This addendum was approved for consultation by the Council's Executive on 17th November 2010. Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 3

Context 2

Policy P3 of the Proposed Submission Core Strategy

2.1 Policy P3: Burnham-on-Sea & Highbridge of the Proposed Submission Core Strategy sets out the place specific policy for the town against which proposals will be assessed. The policy and its supporting text identify the priorities for the town including improving self-containment, regeneration, infrastructure investment (including flood defences) and protection of the environmental sensitivities of the area.

2.2 For housing development, Policy P3 prioritises new housing on brownfield sites within the existing urban area and supports proposals that contribute to local housing priorities. Such priorities include the need to address affordability issues and to provide a wider range of housing types, including family housing, to create a better balance between local housing demand and supply as recommended in the Strategic Housing Market Assessment (SHMA).

2.3 The supporting text of the policy acknowledges that a brownfield only strategy is unlikely to be sufficient to deliver much needed investment in infrastructure, including flood defences, education and public realm improvements. To provide the opportunity to meet local objectives the policy also makes provision for a mixed-use greenfield urban extension during the Plan period to accommodate between 350 and 400 new homes. In addition to infrastructure delivery, these objectives include raising design and sustainability standards, improving the mix and type of housing available in the area, providing local employment opportunities and acting as a catalyst for the wider regeneration of the town and investment into services and facilities.

2.4 However, the policy and supporting text do not identify the broad location for the urban extension and instead state that this will be identified in a subsequent site allocations development plan document. The delivery section of the supporting text outlines that this site allocations document will include design principles for the sites and the phased delivery of infrastructure working with landowners and developers.

2.5 For information, an extract from Policy P3 dealing with the objectives and housing proposals is reproduced below as it currently appears in the Proposed Submission Core Strategy.

Extract from Policy P3: Burnham-on-Sea & Highbridge of the Proposed Submission Core Strategy

Proposals for development in Burnham-on-Sea & Highbridge will be supported if they meet all of the relevant following objectives :

Increasing self-containment by reducing the need to travel; Enhancing the service centre role of the towns and their relationship to the wider rural hinterland; Providing development opportunities that meet the needs of the local community including addressing known areas of deprivation and social exclusion; Promoting regeneration of the built environment and improvements to the public realm; Encouraging investment and complimentary development opportunities that support and strengthen the area’s role as a significant tourist destination; Consolidating and enhancing existing local services, facilities and infrastructure including education, open space and other social infrastructure; 4 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

2 Context

Delivering a strategic flood defence solution that is sensitive to its location adjacent to internationally important nature conservation sites; Protecting and enhancing the ecological sensitivities of the area including national and international nature conservation designations.

Housing proposals that maximise brownfield development within the existing urban area (as defined on the 'saved' Local Plan Proposals Map) through appropriate infill and redevelopment opportunities will be supported where they meet local housing priorities, particularly the provision of family and affordable housing. In addition, new housing development will be supported on an identified mixed-use urban extension (to be identified in a subsequent site allocations development plan document) where all the above objectives are demonstrably met. Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 5

Proposed Change to the Core Strategy 3

The Preferred Broad Location

3.1 The Council proposes to identify Land at Brue Farm, Highbridge as its preferred broad location for accommodating the urban extension for Burnham & Highbridge. This broad location is indicated in Map 1 below. The location offers advantages above other potential locations in terms of its overall accessibility and relationship with the centre of Highbridge and the services and facilities this offers, including local job opportunities and public transport. Of all the potential locations, it is considered that Land at Brue Farm offers the greatest opportunity to create a sustainable, mixed community and deliver key local priorities.

3.2 An assessment of the preferred location and the alternatives considered is included in Section 5.

Textual and Graphical Changes

3.3 The identification of Land at Brue Farm, Highbridge as a broad location to accommodate a mixed use urban extension results in a limited number of changes to the current Proposed Submission Core Strategy. To clearly identify these changes a ‘tracked change’ extract of Policy P3: Burnham-on-Sea & Highbridge and its supporting text is set out below. In addition the minor change required to the Burnham & Highbridge Spatial Plan is also shown below:

Policy Change 1

Proposed Changes to Policy Wording, Supporting text and Spatial Diagram

Changes to Policy Wording

Second Para of Policy P3

Housing proposals that maximise brownfield development within the existing urban area (as defined on the 'saved' Local Plan Proposals Map) through appropriate infill and redevelopment opportunities will be supported where they meet local housing priorities, particularly the provision of family and affordable housing. In addition, new housing development will be supported on an identified mixed-use urban extension on Land at Brue Farm, Highbridge(to be identified in a subsequent site allocations development plan document) where all the above objectives are demonstrably met.

Changes to Supporting Text

Approach - Para 6.52

A brownfield only strategy is unlikely to be sufficient to deliver much needed investment in infrastructure including flood defences, education and public realm improvements, therefore a mixed-use greenfield urban extension could be beneficial during the Plan period. Policy P3 identifies Land at Brue Farm, Highbridge as a broad location to accommodate this urban extension.This will be identified in a subsequent site allocations development plan document. In addition to infrastructure delivery, these objectives will include raising design and sustainability standards, improving the mix and type of housing available in the area, improving walking and cycling access through the provision of a new bridge across the River Brue,providing local employment opportunities and acting as a catalyst for the wider regeneration of the town and investment into services and facilities. 6 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

3 Proposed Change to the Core Strategy

Delivery - Para 6.70

A site allocations document, informed by tThe Supplementary Planning Document will also include a masterplan and design principles and identify the phased delivery of infrastructure including the new footbridge across the River Brue, for the urban extension broad location, working with landowners and developers.be prepared to ensure that a continued supply of housing land is available and deliverable from brownfield development opportunities and when required will identify the mixed-use urban extension following a site search. Any such searchThe masterplan and design principles will need to be mindful of the recommendations of the Habitat Regulations Assessment in terms of the potential impacts of residential development close to the southern bank of the River Brue and the need to avoid/mitigate manage the potential for recreational disturbance through the scale of development and green space provision. The site allocations document will include design principles for the sites and the phased delivery of infrastructure working with landowners and developers.

Changes to Spatial Diagram

Burnham-on-Sea & Highbridge Spatial Diagram Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 7

How to make Representations on this Addendum 4

4.1 An 8-week consultation period for representations to be made on the Addendum to the Proposed Submission Core Strategy commences on 23rd November 2010 at 9am and finishes on 18th January 2010 at 5pm. To assist you in making representations more easily, we are using an Online Consultation Portal(1). This allows you to access, read and comment on this addendum. Once on the portal, you can comment directly on the proposed changes to Policy P3.

4.2 Comments made at this stage should relate to the proposed changes set out in the Addendum only and not parts of the plan which are unaffected by the changes. Previous representations made on the Proposed Submission Core Strategy during its consultation period between September and November 2010 will still be taken into account at the examination so there is no need to make repeat representations.

4.3 As with the Proposed Submission Core Strategy, the consultation on the Addendum has the specific purpose of inviting formal representations to be made to the Inspector on whether the Core Strategy as amended by the Addendum is ‘legally compliant’, and is ‘sound’. To be legally compliant it is required to comply with the legal requirements of the Planning and Compulsory Purchase Act 2004 (as amended). To be considered ‘sound’ it needs to be justified, effective and consistent with national policy.

4.4 Before you make your representations, please read the guidance notes “How to comment on the Core Strategy Proposed Submission Document” that can be downloaded from the Council's Core Strategy(2) website.

4.5 If you are unable to use the online consultation portal, a Pdf version of the Addendum as well as a copy of the representation form are available from the Core Strategy(3) website. Hard copies are available free of charge on request. The Addendum is also available to be inspected (alongside the Proposed Submission Core Strategy, Proposals Map, Sustainability Appraisal Report, Consultation Statement and Habitats Regulations Assessment Report) at the places and times shown below:

Council Offices Reception, Sedgemoor District Council, House, King Square, Bridgwater, TA6 3AR (Monday to Friday 8:45am to 5:00pm) Public Libraries (during normal opening hours): Bridgwater Library, Binford Place Burnham-on-Sea Library, Princess Street Cheddar Library, Union Street Highbridge Library, Alpha House, Market Street Nether Library, Castle Street Library, 125 Fore Street

4.6 Please return completed representation forms to: LDF Team, Strategy and Business Service, Sedgemoor District Council, Bridgwater House, King Square, Bridgwater TA6 3AR. Or by email to [email protected].

4.7 Please note that copies of all representations will be made publically available.

All representations must be received by 5pm on Tuesday 18th January 2010

1 sedgemoor-consult.limehouse.co.uk/portal/planning/ 2 www.sedgemoor.gov.uk/corestrategy 3 www.sedgemoor.gov.uk/corestrategy 8 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

4 How to make Representations on this Addendum

4.8 Further guidance and information on this, and the Sedgemoor Local Development Framework in general, is available on the Council’s LDF(4) website or by contacting the LDF Team on 01278 436436.

4 www.sedgemoor.gov.uk/ldf Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 9

Supporting Information 5

Previous Versions of the Core Strategy

5.1 The Council consulted on an Issues and Options version of the Core Strategy between June and August 2007 and a subsequent Preferred Options version between September and December 2009. At the time of the Issues and Options consultation there were a number of unknowns in respect of levels of growth likely for Burnham & Highbridge, this included the early stage preparation of the then draft Regional Spatial Strategy (RSS) and the different spatial strategy options being consulted upon in the Issues and Options Paper.

5.2 As a result, although it was considered likely that at least in the medium term housing development in the town could be accommodated on brownfield sites; the following broad locations for accommodating a potential urban extension were included in the Issues and Options paper.

Land to the south of the River Brue Land at Alstone Land to the north of the Former Radio Station

5.3 Land to the north of Stoddens Road, Burnham and Land to the East of Love lane were promoted as further broad locations by consultation responses.

5.4 At Preferred Options stage the more limited levels of growth envisaged by the RSS outside of Bridgwater and other evidence including the strategic flood risk assessment suggested a brownfield only strategy for Burnham and Highbridge with no requirement for additional greenfield housing.

5.5 Consultation responses on the Preferred Options identified concern at the amount of growth being directed to Bridgwater at the expense of Burnham & Highbridge and the rural areas. For Burnham & Highbridge the proposed brownfield only strategy was seen as a ‘plan for stagnation’ which, given the viability issues associated with brownfield sites, would limit opportunities for infrastructure investment (including flood defences and education) and the delivery of a range of housing.

5.6 As a consequence a further change was made to the overall spatial strategy for the District which saw increased levels of growth outside of Bridgwater. This meant specifically for Burnham & Highbridge the inclusion of “a well-related mixed use urban extension, to be identified following adoption of the Core Strategy”. These changes were consulted upon as part of a special edition of the Council’s LDF newsletter in April 2010 and informed the preparation of the Proposed Submission Version of the Core Strategy published in September 2010.

Identifying the Potential Broad Locations

5.7 The Council's Strategic Housing Land Availability Assessment was published in July 2009. Its purpose is to ensure that a flexible and responsive supply of housing land in Sedgemoor can be maintained by demonstrating a 5 year supply of deliverable sites and setting out a supply of developable sites for the 5-10 year and 11-15 year periods. Its preparation included a ‘call for sites’ exercise where landowners and agents were encouraged to advise the Council of sites that could have the potential to accommodate housing.

5.8 As part of this ‘call for sites’ individual sites were promoted in the following broad locations adjacent to the existing urban area:

Land at Brue Farm, Highbridge (SHLAA sites H031 & H208 & H141) Land at Alstone, Highbridge (SHLAA sites H090 & H318) Land north of former Radio Station, Burnham (SHLAA sites H040 & H226) Land east of Love Lane, Burnham (SHLAA sites H130 & H131) 10 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

5 Supporting Information

5.9 Map 1 below is an extract from the Council’s SHLAA and identifies the individual sites that were promoted as part of the ‘call for sites’ exercise outside of the existing urban area for Burnham & Highbridge:

Map 1 SHLAA Sites identified as having Future Potential in Burnham-on-Sea & Highbridge Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 11

Supporting Information 5

5.10 However it should be stressed that the identification of a broad location does not imply that all SHLAA sites within that area are acceptable. It is not the intention to allocate sites within the Core Strategy, only to identify a broad location. Detailed site parameters will be developed as part of the development of a subsequent masterplan.

5.11 The broad locations identified in the SHLAA includes all three locations previously consulted upon at the Core Strategy Issues and Options stage, and one of the other options promoted as part of that consultation process (east of Love Lane). However all five locations (including north of Stoddens Road) have been individually assessed against a range of evidence and this has informed the selection of the preferred location.

Assessment of the Potential Broad Locations

5.12 The assessments of the preferred location and the alternatives considered are set out individually below.

Broad Location 1: Land at Brue Farm, Highbridge

5.13 This location was previously the subject of a proposed housing allocation in the then draft Local Plan but removed by the Council prior to the Local Plan Inquiry held in 2001/02. This was as a result of there being no requirement to make further greenfield housing allocations in addition to that at South Bridgwater to meet the strategic housing targets of the Plan.

5.14 However the Inspector at the Inquiry, whilst accepting there was no need at that time for the site, acknowledged the advantages of the location, concluding “In my view, no other similarly sized site at Burnham/Highbridge offers such a list of advantages; if an urban extension at Highbridge were 12 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

5 Supporting Information

needed during the Plan period, this would be the best site” (5). It is worth noting that the other greenfield sites promoted at the time, and so were also being considered by the Inspector, included all the alternative sites.

5.15 The specific advantages of Land at Brue Farm include:

Its central location in relation to the town centre and employment areas (compared with other greenfield sites); Accessibility given its location in close proximity to Highbridge Railway Station and public transport links; Relatively limited visual and landscape impact and with ample scope for further screening and the creation of landscape features etc; No impact on best and most versatile agricultural land; Relative ease of access from the A38 and opportunities for new footpath and cycle links to the town centre; No significant adverse impact upon nearby residents; and No significant infrastructure constraints.

5.16 The most significant change since the Inspector’s Report has been the publication of PPS25: Development and Flood Risk and the identification of the location as being within Floodzone 3a. Therefore flood risk is potentially a significant issue (as it is for all potential locations).

5.17 However promoters of sites in this location have undertaken independent flood modelling work that demonstrates that although floodzone 3a this would be considered ‘low hazard’. In accordance with the Council’s Strategic Flood Risk Assessment the site would therefore perform sequentially better than locations on the eastern side of Burnham (including land at the former Radio Station, Stoddens Road and Love Lane). In addition any required flood mitigation works would provide wider flood defence benefits to the area.

5.18 Initial discussions between Natural and the promoting developers have confirmed in principle that the Brue Farm site can be brought forward for development. Natural England will expect the site to provide adequate recreational opportunities to cater for the daily needs of new residents. These should be within the area between the A38 and the west coast railway, thus reducing the risk of increased pressure occurring along the Special Protection Area boundary to the west of the A38, especially from people exercising dogs.

5.19 Although all the broad locations assessed have the potential to help deliver local priorities and objectives including investment into flood defences, education and public realm improvements. Land at Brue Farm is considered to offer the most direct benefits as a result of its locational advantage in respect of its existing accessibility to facilities, services and public transport. In addition it offers the potential for additional improvements and therefore wider community benefit than the alternative locations which are more peripheral to the centres of Burnham & Highbridge.

5.20 Land at Brue farm is therefore the Council’s preferred broad Location for an urban extension at Burnham & Highbridge. In identifying this location the Council are mindful of the recommendations of the Habitats Regulations and the possible impacts of residential development close to the southern bank of the River Brue.

5 Sedgemoor District Local Plan 1991-2011: The Inspector’s Report, section 4.81: Land at Brue Farm Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 13

Supporting Information 5

Broad Location 2: Land at Alstone, Highbridge

5.21 Given the site’s proximity to land at Brue Farm it does share a number of advantages including accessibility to the centre of Highbridge and its services and facilities, limited visual and landscape impact and low quality agricultural land. However it is less centrally located than Brue Farm and therefore further from the railway station and the eastern employment areas. Furthermore the obvious means of access has from the A38 has now been developed for housing.

5.22 In terms of flood risk the site also falls within floodzone 3a and it is unknown as to whether any further detailed flood modelling has been undertaken to assess the level of ‘hazard’. However the site’s closer proximity to the Brue Estuary suggests the site would face tidal inundation before Land at Brue Farm.

5.23 As with Brue Farm the recommendations of the Habitats Regulations assessment on the Core Strategy regarding potential recreational disturbance from residential development close to the southern bank of the River Brue are equally applicable. However additionally given the site falls within a consulation zone of a SSSI/European sites (Bridgwater Bay/Severn Estuary) and may require separate Habitats Regulations Assessment.

5.24 The site is less centrally located than Brue Farm and therefore generally less accessible and currently has a number of unknowns in respect of managing flood risk, access and biodiversity impacts. Therefore the location is not preferred by the Council for the urban extension. In addition the amount available land at Alstone is smaller and unlikely to accommodate the scale of development suggested in the Core Strategy. 14 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

5 Supporting Information

Broad Location 3: Land North of former Radio Station, Burnham

5.25 Land to the north of the Former Radio Station site is in close proximity to existing education facilities, a medical centre and a sports centre and within reasonable distance from the eastern employment sites in Highbridge. The completion of the Frank Foley Parkway has improved the accessibility of the site generally; however it remains peripheral from the centres of Highbridge and Burnham and is unlikely to promote walking and cycling given its distance from key services. Furthermore the site is beyond reasonable walking distance from the railway station.

5.26 In terms of flood risk the location falls within flood zone 3a and the Council’s Strategic Flood Risk Assessment identifies the site as being at within both ‘medium and high hazard’ areas and therefore sequentially on flood terms performs worse than Brue Farm.

5.27 Like the other potential locations the land is of low quality agricultural value. However in terms landscape impact the site lies within the Burnham-on-Sea Green Edge defined in the adopted Local Plan (and saved within the Proposed Submission Core Strategy). This seeks to protect the eastern edge of the urban area to retain a significant piece of the Levels landscape as part of the setting of the town. It’s distance from designated European sites however does mean the site is likely to raise less biodiversity issues than those closer to the Brue Estuary.

5.28 Compared to Brue Farm, this location is more peripheral and limited in terms of accessibility. It would represent a less sustainable form of development and provide more limited direct benefits to the wider community than Brue Farm in terms of infrastructure investment and improvement. Furthermore the site is sequentially worse in terms of flood risk. Therefore the location is not preferred by the Council for the urban extension. Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 15

Supporting Information 5

Broad Location 4: Land east of Love Lane, Burnham

5.29 Land to the east of Love Lane is within close proximity to the local centre at Rosewood Farm but otherwise is peripheral to the centres of Burnham and Highbridge as well as the main employment areas at Isleport. It is unlikely to promote walking and cycling given its distance from key services and additionally the site is beyond reasonable walking distance from the railway station.

5.30 In terms of flood risk the location falls within flood zone 3a and the Council’s Strategic Flood Risk Assessment identifies the site as being at predominantly within ‘high hazard’ areas and therefore sequentially on flood terms performs worse than Brue Farm.

5.31 Like the other potential locations the land is of low quality agricultural value. However in terms landscape impact the site lies within the Burnham-on-Sea Green Edge defined in the adopted Local Plan (and saved within the Proposed Submission Core Strategy). This seeks to protect the eastern edge of the urban area to retain a significant piece of the Levels landscape as part of the setting of the town. Its distance from designated European sites however does mean the site is likely to raise less biodiversity issues than those closer to the Brue Estuary.

5.32 Compared to Brue Farm, this location is more peripheral and limited in terms of accessibility. It would represent a less sustainable form of development and provide more limited direct benefits to the wider community than Brue Farm in terms of infrastructure investment and improvement. Furthermore the site is sequentially worse in terms of flood risk. Therefore the location is not preferred by the Council for the urban extension. 16 Sedgemoor District Council 2010 Burnham-on-Sea & Highbridge Urban Extension

5 Supporting Information

Broad Location 5: Land north of Stoddens Road, Burnham

5.33 Land north of Stoddens Road is relatively poorly located in relation to existing services and facilities including shopping, employment, education and public transport. Of all the considered sites this is the most remote from the existing centres of Burnham and Highbridge. As a result the site is likely to promote unsustainable modes of travel and make limited contribution to the promotion of walking and cycling.

5.34 The site was previously promoted at the Local Plan Inquiry on the basis it could facilitate a northwards extension of the Burnham eastern distributor road to partially address congestion along the holiday route between Burnham, and Berrow. However given the scale of development currently required at Burnham & Highbridge there is no realistic prospect that even a first phase of this road could be delivered.

5.35 As with the other eastern sites it lies within the Green Edge and would have a significant landscape impact and on the setting of the town. Although it is predominantly of low quality agricultural value there is some higher value (grade 2). As with all the sites it lies within flood zone 3a, however the Council’s Strategic Flood Risk Assessment identifies this as generally ‘medium hazard’ but with some pockets of ‘high hazard’. This means sequentially in flood risk terms, although it performs better than the Radio Station site, the site represents higher risk than Brue Farm.

5.36 Although the site was promoted as an alternative option at the Issues Options stage of the Core Strategy, it was not promoted through the more recent SHLAA process. Furthermore there have been no discussions with interested parties for some time. This suggests that the site is no longer being actively promoted and therefore raises uncertainties in terms of its overall deliverability. Burnham-on-Sea & Highbridge Urban Extension Sedgemoor District Council 2010 17

Supporting Information 5

5.37 The peripheral nature of Stoddens Road and the sustainability concerns this raises, coupled with the flood risk and landscape impact issues means this location is not preferred by the Council for the urban extension.