17 Lower Wraxhill Road, East Coker, Yeovil, Somerset. 1". August 2012.

Dear Sir, This is a representation about the South Somerset Local Plan. I am objecting to it on three major points. 1. Housing numbers and their distribution. 2. The need for a single block of urban extension to Yeovil. 3. The proposed location at East Coker Keyford for an urban extension.

Under points 2 and 3 I am also objecting to parts of the Sustainability Appraisal which I consider biased and flawed, and I also object to some of the documents on which the conclusions leading to the Local Plan were based., again because I consider them to he flawed. I refer in particular to the Peripheral Landscape study, the Historic Environment Assessment and parts of the various highways reports. For the reasons outlined in the following pages I consider the parts relating to the above area to be unsound. I would like an acknowledgment of this representation, which contains 3 pages including maps, diagrams and photographs.

Yours faithfully, A RESPONSE BY EAST COKERPARISH COUNCIL TO SOUTH SOMERSET DISTRICT COUNCiL -DRAFT SUSTAMABILmY APPRIASAL FEEDBACK mETINGOF 10 MARCH 2010

Nominated members of East Coker Parish Council attended cluster meetings in Novemberand December 2009 and the feedback meeting in March 2010. At these clnster meetings were representatives of councils that might be impacted by the urban extension.

It had been stated that the purpose of the cluster meetings was to consider various location options for the establishment of a 5,000 dwelling Urban Extension to ~eovildirected by Govemment. SSDC presented to the 1" cluster meeting six search area options after having disconnted options that failed to meet its Government sustainability criteria.

Attendees at the cluster meetings were randomly divided into three groups, each group with the aid of facilitators were asked to consider 14 SSDC objectives and advise (based on these objectives) which areas were preferred, with supporting justification (no areas were ruled out by SSDC).

Following two cluster meetings all three groups had unanimo~lslyagreed that development options to the northem edges of Yeovil were shongly preferred as these presented best solutions for highway links, benefits to existing deprived areas, close proximity existing and new employment opportunities, recreational, educational and medical facilities as well as several accessible routes to the urban centre of Yeovil.

All groups independently had come to a common view. Late in the process, without previous agreement or explanation the lead member facilitator asked groups to provide alternative options, but without allowiug due consideration orjustification. The general view of the forum was that this was not good practice or an acceptable procedure. Staff facilitators in each group actively pushed group members reluctantly towards hitte~topreviously discounted options. Some facilitators pushed for 3'd and 4"' options.

East Coker Parish Council representatives expressed grave concerns regardmg the process as it unfolded and raised these during the 2"cluster meeting but were advised fuflher cluster meetings would be convene with firrther oppomnity to clarify and justify. No fnrther meeting took place before SSDC presentation at the feed back meeting (l0 March 2010) had re~ixwedall fxst options (noAerly development) and detailed that only options to the south would be considered. Group were then asked to express preferences and work through a flawed objective scoring matrix, the process was unacceptable and was stopped by one group as it bad been severely compromised. It is following this that a meeting is being convened on 25" March 2010 between Mr Andrew Foyne and representatives of East Coker Parish Council.

East Coker Parish Council wrote to Mr Andrew Foyne in November 2009 prior to the cluster meetings to detail its views on rationale of an urban extension per se but more specifically the impact on the environmental, historic, highway and population of East Coker. No response detailing SSDC view on East Coker Parish Councils representations were received, either discounting the concerns (as not relevant) or recognising the concerns and using them to influence the Sustainability Appraisal and Core Strategy.

Fuither to the concerns raised the East Colcer Parish Council submit the following substantial evidence that it requires to be included in the evidence base used by SSDC to establisli the essential criteria for sustainable development not only for a 5,000 dwelling urban extension but for the whole community of Yeovil and its surrounding hinterland.

Transportation Issues -

Modes oFTransport: While it is an aspiration to get people to move by public transport, cycle or walk in preference to car it is recognised by Govemment and experts in Eco Town Planning that may not be practical in niral areas. In fact SSDC had completed studies that recognise that therr is low potenHnl to increase cycling due to topography also recognising that an urban extension should focus on sustainable iinla with the rest ofYeovi1 promoting east west mutes i.e uorth Yeovil escarpment but not south to north.

Public Transport: Good services already serve a wide area of urban Yeovil which for the most part is to the north, West and East ofthe centre. Public Trausport serving the south is poor. Given the planning criteria the urban extension will have at least 30% affordable housingfor young families and a requirement to cater for an aging population, neither ofthese social groups will walk or cycle to the town centre but they may within the fabric of the new urban extension. Public transport will play a significaut pavt in reducing carbon emissions and therefore proximity to the town centre is not the essential criteria but good pblic transport is.

Cycling: It is recognised that whilst currently cycle routes are predominately to the south of Yeovil the District Councils long term plan is to promote and maximise opportunities by providing walkiug and cycling routes in new developments (Transport TA2) the predominant new developments for the Yeovil urban area is North East and North West, linking to the existiug cycle routes must be a priority. In fact this document recognises the low poie~ltialfor walking and cyclingaronnd Yeovil due to topography. It clearly points to due Easmest routes rather than NorthiSouth. Currently there is no EastIWest cycle route along the nortbern escarpment but this will be taken forward in accordance with requirements of new development. This contradicts the requirement for a south only area of search.

Highways: - Yeovil Centre is served by several access points from the North and West A3088, Tintinhull Road, A37 from Ilchester and Mudford Road all these are linked to the Strategic Highway A303 and to the East A30 iiom Sherbome, the economically linked town to Yeovil in the RSS. From the South and West only the A37 and A30 semes Yeovil Centre via a serious choke point at Hendford Hill, equally neither ofthese routes is linked to the Strategic Highway.

Accessibility: Accessibility to facilities is basically threefold:

a. Access to major "one off facilities" mainly hospitals and colleges and leisure. b. Providing good day to day facilities, basic shopping, banks, health centre, community centre, scl100l. C. Accessibility to employment opportunities by either by walking, cycling, public transport or car.

Any new major development housing 12,000 people must have a local centre at its heart providing the daily basic need of the community, therefore overemphasis that the development needs to be close to the l'om Centre of Yeovil is a misnomer. It only needs to be accessible (once you have to get on a bus travelling I mile, 1.5 miles or 2 miles is not significant). Accessibility is as pertinent for the existing communities in Yeovil as any extension. With 30% of dwellings requiring being atfordable (young families) and an increasingly aging population cycling and walking to the town centre for shopping or leisure will oot be an option even for those living within a mile of the centre. Cycling and walking wilt basically be in pursuit of pleasure.

Rail Link: Significant emphasis is placed on locating an urban extension close to the Yeovil rail links. To understand the relative importance of tlnis you need to understand the relationship between Yeovil and urbau enviromnents on the rail routes. In the large urban areas London, Newcastle, Manchester, Birmingbam etc commuting by rail is significant however there is little commuting or other rail travel done from either Yeovil Junction or Pen Mill. In fact statistics show approximately 0.5% of the population (Yeovil and surrounding rural communities) travel by train. Future rail planning also shows that while number may increase the single track in6astructure will not be improved and this imposes significant limits on further growth. Developing close to rail links is not an essential witeria or a sustainability issue.

Envi~~onmentnlIssues -

Eco Dwellings: The main thmst is to develop carbon neutral homes by developing well insulated and designed properties. This may mean utilizing solar heating, possibly wind power and heating fiom the earth. SSDC Plauiug Team stated a prlme disadvantage of developing anywhere to the nod1 was presumably due to the solar beneh south. This is misleading and inacctwate as it is important to put solar panels on south facing roofs only ifa property rarely gets sunlight is it a disadvantage. In fact in the north there are south and west facing slopes and in the south there are north and west and east facing slopes.

Countn Park The Yeovil Countw Park is currently. only. to the south however most of the existinx- urban population along with the current planned new developments are in the nosh. Most of the urban deprived areas are also to the nor& and east of the town. By improving the cycle route system around the nortb there is an ideal opportunity to further develop the country park north of Yeovil with walks tree planting and exercise areas between the elements of an urban extension. To offer up the existing counhy park as a significant part of the 40% open space requirement is in fact disingennous as the planning team has not considered the wider health and well being issues of the wholeYeovi1 community. In fad the Yeovil Country Park would effectively beeome md urban park as it would be constrained within an encompassing urban setting. It is importnnt that a country park transitions into the unspoiled conntry. This could and should be done in the northern area of Yeovil, a Connt~yPark on the edge of the northern urban extension transiting into the conntry providing this FaciliQ for those living and working in the north ofthe town.

AgriculturalLand: By restricting the area of search to the East, South and South West the planning team have decided that development over large swc&of grade lagricultural land is acceptable and essential as all other wstainability issues for lower grade land out&& the protection of grade 1 land. Guidance shows that this should only he considered ifother lower graae land cannot be used due to sustainahility. This has not been proved in fact there is clear evidence that in sustainahility terms there is mnch to favour the northern options. Grade1 land is important for two main reasons:

a. Food security - the need to grow more of our national reqairement food to become less reliant on food imports. b. The carbon cost of shipping and importing food we can grow onrselves.

Rights ofway: A high number of extremely important rights of way cross the landscape immediately south of Yeovil. Historic RUPS bridleways and footpath including the hidden hollows within the sand based landscape exist here. These are of significant benefit to the health and well being of the population as access is from the urban edge all the way through to theHardington area and Colcer Ridge without need to access roadways.

Historic Build and Ancient Monuments: Land to the immediate north and west of Yeovil does not have the range and quantity of hsted buildings, conservation areas and ancient monuments as the land to the south This makes the north a most acceptable option on this objective.

Visual amenity: There is no doubt that development on the scale of an urban extension will be detrimental to visual amenity. It is the depth of impact that cm be assessed. Build on the northern escarpment would be visible from the levels and hills north of nchester however this is mainly from a low level looking upwards. Tree planting and screening can nullify this to a great extent. Although from Ham Hill looking towards Lufton cannot be protected in the same way the visual impact has already been compromised with the tiading estate. In the south detrimental impact m11 he significant from the Dorset Bills above Sherborne in the East to Rampisham in the West as well as Cokeer.Ridge.

Light Pollution: While it is true to that light pollution is unwelcome in most areas again it is about the greater im~act.To the north with Yeovilton and Ilchester on the horizon and the Mid Somerset Towns beyond there is already a significant light impact. To the east Over Compton and Trent are ~mpactedby Yeovil itself However to the South dark sky prevails as there are no significant towns for twenty miles.

Comm~miQIssues:

Impact on Villages: One main thrust that came out of the cluster meetings was the need to minimise the impact on the surrounding mral hinterland and communities. Villages are distinctive units with strong identity. Nowhere within the SSDC Sustainability Appraisal does it seek to identify the impact of an urban extension and any one or more ofthe village communities. Planning Policy Statement 7 clearly understands the need to separate towns and villages and is high& rest&ive of new build development in "open countryside" and limited to that which justifies a ~.uraIlocation.

Proximity to Villages: Building in locations that compromises the policy and impact on mral communities is unacceptable. This is highly evident if development is targeted south and east of Yeovil where there is such minimal open wunt'yside between the town and four villages (Over Compton, Batwick, East Coker and West Colcer) In the north two villages need to be considered (Chilthome Domer and Mudford). Mudford is about 1 mile fiom the urban edge and as such a buffer of 0.5 mile is still feasible. Careful plannine should allow a similar buffer with Chilthorne Donier. No similar buffer can effectively be applied in the south and east, barn portion of land at Newton Summewale.

Education:

Primary: Education needs to be seen in the round. Schools need to be built were there is a population requirement rather than establish a population where you wish to place school. To state that it would be good to develop south of Yeovil because there are few urhan schools is missing the point. The village schools within the south and east search areas including, Trent, Bradford Abhas, Balwick, East Coker and West Colcer would all in part he seriously compromised. The development of new scbools south of Yeovil wonld effectively rip the remaining heart out of these commuuities. In the North only one school would potentially be susceptible this would be Cbilthome Domer. In fact a new school on the urban edge towards Mudford would have the benefit of Mudford children attending school on the periphery of Yeovil rather than in the urban fabric ofthe tom.

Secondary: A secondary school location shouldnot he the driver to site a 5,000 home urban extension. Again it needs to be located within a reasonable commute of the main population a]-eas both current and future.

College and Adult Education: Yeovil College is Located to the north of the tom centre and well placed for developmeot to the north. The "Yeovil University Centre" on Preston Road is similarly well place, At Lufton there is the Innovation Centre and the Slulls Centre all these facilities suggest a northern option to be most sound.

Recw~tionalPacilities:

The importance of recreational facilities cannot be overemphasised. However an urban extension camlot be taken in isolation. It is important for the whole population of Yeovil and its surrounding rural hinterland. Facilities need to be close to areas of population that have most need, the urgent requirement forthis based on cunent population and hreplanned developments is in the nohem areas of Yeovil.

Sports Zone: The sports zone location was initially considered to meet this need in the north of Yeovil and may yet come to fruition. Work in 2007 looked at several areas and concluded that it was best location was to the north although the work did not look in depth at proximity to urhan population. Any sports zone be shoul~withinclose proximity to existing housing developments and developments of the future should reflect this proximity. The logical place for a sports zone is to the north, placing a sports zone to ihe south will not meet the needs of existine-. population . primarily the denrived and sociallv excluded who are less likely to commute to a facility. The establishment of the sports zone and a new "country park" in the north would satisfy this essential criteria. Developing to the south wonfd not.

Health and Wellbeing: One ofthe main pillan of sustainability is that an urhan extension should have significant impact on health and wellbeing not just of those benefiting from the living in a well built and well designed new development but this development should provide value to the existing urban settlement particularly those less fortunately areas that can benefit from being adjacent to the facilities provided by an new urban extension. There is tmdisputable evidence that the six most deprived wards in Yeovil would best benefit from a development within lmile in the north of Yeovil, rather than a development 2-3 miles away on the southern edge.

Urban Village Linlmlge:

The potential to link an urhan village to an urban extension detailed in the growth bid document appears to have been prepared to bring fonvard funding for the urban village rather than for the long term benefits of an expanding Yenvit. The document does not reflect impact on rural communities although the foreward by SCC does clearly aspire to SUSTAZNABILTY WITHOUT DAWGING EXISTING SETTLEBmNTS an urban extension to the south will damage existing setilements. The urban villa~econcept is as equally important to development at Market Street, Lyde and Brimsmore so linkage in geographic terms is, n&&e<-

rational nor logical but soley geared to strengthening a business case for the (foundaryl stars lane) urban - - village funding.