Sedgemoor District Local PlanInspectors Report
Chapter 3
3CHAPTER 3
STRATEGY
3.1Paragraph 3.02 – Introduction
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
2837 / Government Office for the South West / Y / - / R3.1
Main Issue(s)
3.1.1The RJ should refer to the Government’s aim of reducing the need to travel, not minimising it [2837].
Conclusions
3.1.2The RDLP adopts the small but significant change of wording suggested by GOSW [2837].
RECOMMENDATION
3.1.3R3.1 I recommend no modification to the Plan.
3.2Chapter 3 – Key Objectives
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
3080 / Environment Agency / NS / R3.2
3225 / Mendip Society / NS / R3.2
3226 / Mendip Society / NS / R3.2
3227 / Mendip Society / S / R3.2
Main Issue(s)
3.2.1The key objective should be amended to make more explicit reference to environmental protection. Additional wording is suggested [3080].
3.2.2The key objective should include reference to strict control of development in the countryside. Appropriate wording is suggested [3225].
3.2.3The key objective should seek the evolution of a balanced and integrated transport system. Appropriate wording is suggested [3226].
3.2.4The key objective should not refer to a strategy of concentrating development within larger rural settlements (such as Cheddar). Instead, it should refer only to the towns [3227].
Conclusions
3.2.5The key objective, as drafted, is concerned primarily with the Plan’s development strategy. There are many other references in the Plan to environmental protection. I do not support the amendments suggested by The Environment Agency [3080].
3.2.6The key objective, quite rightly, concentrates on stating where (in general terms) new development should go, not where it should not. There is no lack of policies and text in the Plan to indicate strict control of development in the countryside. This, of course, is wholly consistent with national, regional and SP policy. I do not support Obj 3225. Nor do I support Obj 3226; this raises matters more properly dealt with in chapter 7.
3.2.7The Mendip Society [3227] also raises the important question as to whether the objective should refer to concentrating new development within and adjacent to larger rural settlements (as well as at the 2 towns). The Society objects to this, as being contrary to the SP. I agree with this, and indeed I find it consistent with the Council’s own case throughout the LPI, as expressed for example in BP5 (Strategy and Location of Development). In short, and to anticipate subsequent objections in this chapter, I support the Plan’s sustainable development strategy of locating most new residential development on brownfield land within the towns (ie. in Bridgwater and Burnham/Highbridge), and to form an urban extension, as described in PPG 3, on greenfield sites at Bridgwater. I believe this can meet the SP housing requirement. This militates against additional housing allocations at the 4 Rural Centres (including Cheddar) and in the villages. I believe that this strategy is consistent both with RPG and with the SP (a matter I discuss further elsewhere).
3.2.8That said, the Plan does allow for additional housing within the existing DBs of the Rural Centres and villages, but this will mostly be small in scale. The Plan is not proposing development on any significant scale at rural settlements, whether inside their DBs or on greenfield sites. Therefore, on balance, I think that the first bullet point in the key objective should be modified to delete the reference to “larger rural settlements”. Thus I support Obj 3227. Furthermore, given the proposals for greenfield expansion at Bridgwater, (which, to reiterate, I support in principle) I think that the objective should refer simply to the towns, rather than to their centres. To be logical and consistent, it should use the preposition “at” (the towns) rather than “in” them. Later sections of the Plan’s strategy chapter describe in more detail the balance between brownfield and greenfield development, and refer to the sequential approach in PPG 3. I give my recommended wording below [3227].
RECOMMENDATION
3.2.9R3.3 I recommend that the first bullet point under the key objective be modified as follows: “concentrates new development at the towns”. (Subsequent bullet points 4 and 5 should refer to “those towns”, rather than “those centres”.)
3.3Paragraph 3.04 – Locating new development
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
1104 / Country Landowners Association / - / R3.3
1602 / SAGE / NS / R3.3
3190 / Royal Society for the Protection of Birds / NS / R3.3
Main Issue(s)
3.3.1Suggest delete the word “unduly” from the sixth bullet point in the key objective [1104].
3.3.2The key objective should express the overriding aim of sustainability. Various amended wordings are suggested [1602].
3.3.3The key objective should include a reference to impacts upon sites of nature conservation importance or protected species [3190].
Conclusions
3.3.4The RDLP deletes the word “unduly”, as suggested by the Country Landowners Association [1104].
3.3.5The Plan clearly promotes sustainability as an ideal and an objective. It is not necessary to refer to it at every possible opportunity. I am not particularly attracted to any of SAGE’s suggested modifications, and therefore I do not support Obj 1602.
3.3.6Plan chapter 8 includes policies aimed at protecting sites of nature conservation importance etc. It is not necessary to insert a reference to this matter in the key objective. I do not support Obj 3190.
RECOMMENDATION
3.3.7R3.3 I recommend no modification to the Plan.
3.4Policy STR1 – Designated Rural Centres and Villages
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
230 / Ms J Taussik / NS / R3.4
1478 / Fear & Hawkins / Anthony Anton / Y / NS / R3.4
1639 / Persimmons Homes / NS / R3.4
2753 / Mr P Small / Greenslade Taylor Hunt / NS / R3.4
3250 / N Coombes & Son / J H Palmer & Sons / NS / R3.4
3531 / Cannington College / NS / R3.4
4741 / George Wimpey Plc &
Ensign Group Ltd. / Barton Willmore PP / NS / R3.4
Main Issue(s)
3.4.1Axbridge should be defined in the Plan as a Rural Centre, not as a village [230].
3.4.2Cannington should be defined in the Plan as a Rural Centre, not as a village [1478, 3531].
3.4.3Bridgwater and Burnham/Highbridge should be categorised in policy STR1 as towns, in accordance with RJ paras. 3.5-3.10 [1639].
3.4.4Greinton should be defined in the Plan as a village, and have its own DB [2753].
3.4.5Sutton Mallet should be defined as a village, and included within the terms of policy STR1 [3250].
3.4.6Wembdon should not be included among the villages listed under policy STR1. It is not a village. Physically and functionally, it is a part of Bridgwater [4741].
Conclusions
3.4.7Neither the SP nor the Plan itself contains clear cut criteria (population figures, service/facility thresholds etc.) for distinguishing between the various levels in the settlement hierarchy. Even if they did, these would inevitably be subject to change over time. Instead, the Plan relies on a more subjective analysis, and its categorisation of settlements is a matter for judgement. In these circumstances, it is perhaps surprising that there aren’t more objections to the lists of Rural Centres and villages in policy STR1. While there may always be scope for argument about marginal cases, I think this indicates that the Council has got these lists about right in the RDLP.
3.4.8On the basis of its size and population, and its limited range of services and facilities, I do not think that Axbridge should be defined as a Rural Centre. Even on a cursory inspection (far less thorough than mine!) it clearly comes lower down any hierarchy of settlements in Sedgemoor than the 4 Rural Centres which are defined in the Plan - Cheddar (the largest), Nether Stowey, North Petherton and Wedmore. While I accept that Axbridge has a substantially greater range of facilities and services than most of the other named villages, nevertheless I do not support Obj 230.
3.4.9Nor, in my view, and for similar reasons, are there any other very credible candidates for the category of Rural Centre. Alongside Axbridge, Cannington probably comes closest, being boosted by its educational establishments, (including Cannington College). However, it seems to me that it does not function as a service centre for a rural hinterland as fully as, or in a way comparable with the other named places. Therefore I do not support Objs 1478 and 3250.As the Council points out in CD/PO6, Bridgwater and Burnham/Highbridge are defined as towns in the SP, which does not individually identify Rural Centres and villages. This is clear from the RJ. I agree with the Council that there is therefore no need to confirm such a definition in the Plan policy. I do not therefore support Obj 1639.
3.4.10In my view, Greinton is too small and lacking in facilities and services to be defined for planning purposes as a village. Therefore it is justifiably omitted from the list of villages in policy STR1. It is a small settlement which has no particular status in the Plan, and is not an appropriate location even for limited growth. Indeed, defining such small settlements as villages would tend to undermine the Plan strategy. It follows that there is no need to define a DB for Greinton, and from that it also follows that there is no need to consider any detailed boundaries, such as the one promoted in Obj 2753. I do not therefore support the objection.
3.4.11Much the same applies to the nearby small settlement of Sutton Mallet, which in my view, and for similar reasons should not be regarded for planning purposes as a village. It should not, therefore, have a defined DB. I do not support Obj 3250.
3.4.12The case of Wembdon is an interesting one. The debate about its status in the Plan has been polarised, because both main parties (ie. the Council, and Ensign Group, the objectors) see this status as critical to the prospects of large scale development there – and, specifically, at Cokerhurst Farm. In short, if it is regarded as a part of Bridgwater (as the objectors would have it), then the Cokerhurst Farm proposals can be seen as an urban extension a la PPG 3; whereas, if it is seen as a village (a case averred by the Council, supported by Wembdon Parish Council), that would normally preclude greenfield development as obviously contrary to the Plan strategy.
3.4.13 To the disinterested observer, it is simply both – a village which by reason of its close proximity to Bridgwater has become almost a suburb, and hence a part of the town. Whereas Wembdon clearly originated as a separate settlement somewhat removed from Bridgwater, much of it was built during the post war period, such that in the course of time it has all but merged with, or been consumed by, the growing town. This long term growth process has been perpetuated by the construction of the BNDR and its associated housing. Only the narrow (and ever diminishing) Strategic Gap prevents Wembdon and Bridgwater from physically coalescing.
3.4.14 In these circumstances, and using a little common sense, neither of the polarised views of the parties is really tenable. It seems to me that, even if Wembdon is described in the Plan as a village (ie. that no further modification to the list of villages in the RDLP is made) that should not preclude it from being seen, for planning purposes, as virtually a part of Bridgwater, and therefore as a possible candidate for an urban extension (such as at Cokerhurst Farm), along with other possible locations. Thus Wembdon is a special case. I have taken this approach when considering the claims of “housing omissions” sites around Wembdon, including Cokerhurst Farm, vis a vis other greenfield sites on the edge of Bridgwater. As far as Obj 4741 is concerned, however, I recommend no modification to the Plan.
RECOMMENDATION
3.4.15R3.4 I recommend no modification to the Plan.
3.5Paragraph 3.15 – Rural Centres
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
1131 / Mendip Society / PS / R3.5
Main Issue(s)
3.5.1Rural Centres are not suitable for anything more than limited local development. This should be clarified in the Plan, at RJ para. 3.15 [1131].
Conclusions
3.5.2I have already recommended that the key objective should not refer to concentrating new development at the larger rural settlements (ie. Rural Centres). The Plan is not now proposing any housing allocations at the Rural Centres, and I support that. However, I see no particular need to modify RJ para. 3.15.
RECOMMENDATION
3.5.3R3.5 I recommend no modification to the Plan.
3.6Paragraph 3.17 – Rural Centres and Villages
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
1134 / Mendip Society / PS / R3.6
1601 / SAGE / PS / R3.6
Main Issue(s)
3.6.1RJ para. 3.17 identifies Cheddar as being suitable for “larger scale development”. This would be contrary to the SP, and should be deleted [1134, 1601].
Conclusions
3.6.2I note that FPCs3, which, following the deletion of a large housing allocation at Cheddar, I support, would largely satisfy Objs. 1134 and 1601.
RECOMMENDATION
3.6.3R3.6 I recommend that the Plan be modified in accordance with FPCs3.
3.7Policy STR2 – Development in Rural Centres and Villages
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
2767 / Mr D Law / Douglas Smith Associates / NS / R3.7
Main Issue(s)
3.7.1Policy STR2 makes no allowance for development in villages [2767].
Conclusions
3.7.2The objector is incorrect to state that policy STR2 makes no allowance for development in the defined villages. It does allow for small scale development and redevelopment within the defined DBs. The objector is promoting a particular site for development which lies just outside the Axbridge DB, and I deal with the linked objection elsewhere. I do not support Obj 2767.
RECOMMENDATION
3.7.3R3.7 I recommend no modification to the Plan.
3.8Paragraph 3.19 – Outside Settlements
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
950 / Mr & Mrs M Scott & Son / Sisman Nichols / NS / R3.8
1214 / H Harris / Sisman Nichols / NS / R3.8
1600 / SAGE / NS / R3.8
3090 / Wedmore Parish Council / NS / R3.8
3400 / Mr & Mrs Bigwood / NS / R3.8
Main Issue(s)
3.8.1RJ para. 3.19 should include a reference to tourist development outside DBs at Brean and Berrow, indicating the potential for its expansion [950, 1214, 3400].
3.8.2RJ para. 3.19 should include references to all relevant and related national and regional policies which restrict development in the countryside [1600].
3.8.3The Plan should take a positive stance towards residential barn conversions. Other buildings outside DBs may be justified by local needs [3090].
Conclusions
3.8.4I see no reason to include the reference sought by Objs 950, 1214 and 3400. These objections are all linked with other objections which seek a generally more permissive stance in the Plan towards caravan site development in the Brean and Berrow area. I deal with those under the appropriate references (esp. chapter 11). In general, I do not support such a stance, and it follows that I do not support these objections.
3.8.5Government advice (in PPG 12 etc.) is that there is no need in general for local plans to include detailed references to national and regional policies, although some limited cross-references may be helpful in specific contexts. The relevant national and regional policies are readily available, including on websites, the Planning Portal, etc. I do not therefore support Obj 1600, which would only clutter the Plan.
3.8.6The matters referred to in Obj 3090 are all dealt with elsewhere in the Plan. There is no need for any modification to RJ para. 3.19.
RECOMMENDATION
3.8.7R3.8 I recommend no modification to the Plan.
3.9Policy STR3 - Development Outside Settlement Boundaries
The Objections
Objection Number / Objector / Agent / Conditional Withdrawal(Y/N) / Recommendation
S = Support
NS = Not Support
PS = Partly Support / Recommendation Number
133 / Mr R Adams / NS / R3.9
656 / Somerset County Council / Planning Policy and Control / Y / NS / R3.9
1265 / Somerset County Council / Property Services / PS / R3.9
1285 / Somerset County Council / Property Services / PS / R3.9
4645 / Somerset County Council / Property Services / PS / R3.9
829 / Council for the Protection of Rural England / S / R3.9
903 / Somerset Wildlife Trust / S / R3.9
4259 / Somerset Wildlife Trust / S / R3.9
949 / Mr & Mrs Scott & Son / Sisman Nichols / NS / R3.9
1267 / H G & J H Harris / Sisman Nichols / NS / R3.9
1213 / Mendip Society / NS / R3.9
4379 / Mendip Society / NS / R3.9
1599 / SAGE / S / R3.9
2805 / Government Office for the South West / Y / NS / R3.9
2936 / Goldfinch (Projects) Ltd. / Ludlam Associates / NS / R3.9
4348 / Goldfinch (Projects) Ltd. / Ludlam Associates / NS / R3.9
3191 / Royal Society for the Protection of Birds / S / R3.9
3401 / Mr and Mrs Bigwood / NS / R3.9
4277 / BAE Systems / Fuller Peiser / NS / R3.9
4288 / Lions Court Ltd. / Foot Anstey Sargent / NS / R3.9
4444 / Persimmon Strategic Land / NS / R3.9
Main Issue(s)
3.9.1The Plan should allow for more new housing in the villages, particularly for the young and the elderly [133].
3.9.2Policy STR3 does not add anything of significance to the related SP policy [656]. [Inspector’s note: this objection appears to have been withdrawn by supporting representation 4589].
3.9.3The policy should recognise that many SCC schools require land for expansion, but that potential expansion sites are outside DBs. The policy should either make specific policy exceptions for these school expansion sites, or DBs should be amended to include them. The settlements affected are: Bawdrip, Brent Knoll, Catcott, Cheddar, Enmore, Mark, Otterhampton, Pawlett, Spaxton, Weare, Wedmore, Westonzoyland and Woolavington. [1265, 1285, 4645].
3.9.4Any development in the countryside should meet all 3 of the IDLP criteria, ie. re economic benefits, enhancing the environment, and reducing the need to travel [829, 903, 4259, 1599, 3191].
3.9.5The policy should contain criteria for assessing the economic benefits of proposed development in the countryside [903].
3.9.6Policy STR3 should be modified to add a criterion to allow for tourist development which complies with relevant policies in chapter 11 [949, 1267, 3401].
3.9.7The policy should contain 8 criteria; drafts are suggested. There should be specific reference to the Mendip Hills AONB [1213]. Revised drafts of the policy criteria are suggested [4379]
3.9.8In the IDLP the 3rd criterion is vague. It should be replaced by a requirement for new development to be accessible by public transport [2805].
3.9.9A criterion should be added, re development which contributes to the housing stock [2936].
3.9.10The last sentence of the policy (RDLP version) should be deleted [4348, 4277, 4288]. The first sentence should also be deleted [4288].
3.9.11The RDLP policy is not clear [4444].
Conclusions
3.9.12Policy STR3 is a general policy to control development proposed in the countryside, ie. outside the DBs of defined settlements. As in almost any rural district, it is a particularly important policy which is likely to be relevant to many proposals, and to be cited in many planning decisions, especially refusals of planning permission. Needless to say, it must be generally consistent both with national policy (especially as stated in PPG 7), and with SP policy (STR6). But it should do more than merely repeat these. I note that the RDLP made some additions to the IDLP version and a deletion which, in effect, FPCs5 would reinstate. Some of these alterations were made in response to the above objections.