Proposed Submission South Somerset Local Plan (2006 - 2028): Main Modifications - August 2014

Comment ID 41
Document Section Main Modifications Policy SS5: Delivering New Housing Growth Content View all on this section
Respondent R Pratt View all by this respondent
Response Date 10 Oct 2014

I STRONGLY OBJECT to the Main Modification MM12 on the grounds that it is not compliant with national policy (NPPF) and that it fails to add sufficient clarity as requested by the Local Plan Inspector’s preliminary findings [Ref A] and highlighted in my consultation response to the original Main Modification [Ref B], and representations at the local Plan Examination and Resumed Hearings [Refs C, D & E] . 

This aspect remains unsound and contrary to NPPF Para 15 which states plans should have “clear policies that will guide how the presumption of [of sustainable development] should be applied locally”.

MM12 seeks to introduce a modification to help clarify the policy for Market Towns without Strategic Directions of Growth in the context of the presumption in favour of development for the period pending Site Allocations DPD availability.

However the proposed modification is ill-considered as it will have the effect of temporarily allowing proposals to come forward for (potentially large-scale) development in the countryside areas surrounding Crewkerne and Wincanton and conflicting with proposed specific policies for growth in these towns.

This modification introduces inconsistency with requirements of the NPPF in the following areas :-

Para10 – Plans and decisions need to take local circumstances into account.  The effect of this modification is to overrule the identified specific local circumstances  for Wincanton and Crewkerne and provide a “green light” for speculative developers to develop on the countryside surrounding these towns, pending the adoption of a Site Allocations DPD.

Para110 –In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.

The effect of this modification as currently worded is to allocate unbounded land (the majority of which will be greenfield) surrounding the Market Towns of Wincanton and Crewkerne which will include land of high environmental value.  This cannot be called positive planning and instead will provide the go ahead for speculative developers to develop on and pollute the countryside surrounding these towns, pending the adoption of a Site Allocations DPD.

In the case of the Primary Market Towns of Wincanton and Crewkerne, the failure to define (adequately or otherwise) a Strategic Direction for housing growth is at the heart of the issue. 

In the case of Wincanton, I refer to my original submissions to the Local Plan Examination [Refs B and D] which urges redefinition of the current Strategic Direction of growth for Employment as mixed-use, hence obviating the need to address Wincanton as an exception (ie. a Market Town without Strategic Direction of growth for housing).  Justification for this is provided in the original observations [Refs B and D] .  Although this would be a major modification and could be proposed at an early review, modifying the Direction of Growth to be mixed-use would sweep away soundness issues of flexibilty for housing growth in Wincanton now and remove the need for an early review of the Local Plan for Wincanton.  I still advocate this to be the best policy for flexibility in future growth for Wincanton and clarity in how the presumption in favour of development can be dealt with in Wincanton ahead of adoption of the Site Allocations DPD.

Notwithstanding the above, given nearly all of the planned housing for Wincanton has already been built with only a handful of houses to be built for the balance of the plan period, the housing need could clearly be met within the existing Development Area of Wincanton, and this should be reflected in MM12 for consistency with this policy.

In the case of Crewkerne,  the CLR Key Site (Policy HG1) is proposed to meet the housing need over the plan period, so promoting development that is outside of this area is inconsistent with the Local Plan policy for strategic growth proposed for this town.  Policy HG1 pre-empts the Site Allocations DPD and this should have been reflected in MM12 but hasn’t been.  Para 6.64 of the Local Plan clearly states “the location of the ‘growth’ [in Crewkerne] has been predetermined by the planning permission for CLR and this is recognised by Policy HG1.”  MM12 does not reflect this.

An additional lack of clarity occurs in the failure to identify the direction of growth being for housing.  It could be (mis-)interpreted that “direction of growth” could include Direction of Growth for employment.

Failing to adequately address how the presumption in favour of development will be managed for Wincanton and Crewkerne prior to adoption of the Site Allocations DPD has the potential to jeopardise the entire strategy for housing and employment in these locations by allowing unbounded development. A consequence of this may be to render the Site Allocations DPD irrelevant for these areas. 

Addressing the shortfalls of MM12

Alternative wording is proposed to take account of the specific local circumstances of Wincanton and Crewkerne and minimise the potential adverse effect on strategy for growth and on the local environment.

For Wincanton and Crewkerne this is by way of identifying that development should be within the Development Area for Wincanton and the Strategic Housing Site as defined in Policy HG1 for Crewkerne pending the adoption of the Site Allocations DPD.  This presumes in favour of development for both Market Towns but does not jeopardise the strategic plans for growth in Crewkerne and would be consistent with the very low number of houses to meet the remaining need of Wincanton (pending either the adoption of the Site Allocations DPD or the proposed review within two years of Local Plan adoption, whichever comes first).

A minor typographical modification is also proposed in the capitalisation of “development areas”. This is suggested for consistency with it’s use throughout the rest of the Local Plan, and to clarify this is a specific area as defined in the Inset Plans.

I submit that the Specific Wording Changes below will add the clarity sought by the Inspector and NPPF Para 15, seek to minimise adverse effects on the local and natural environment per NPPF Para 110 and importantly, offer compliance to NPPF Para 10 by taking into account the specific local circumstances of the towns of Wincanton and Crewkerne and thereby overcome soundness issues.

Specific Wording Changes to MM12 proposed (in bold text).


PSSSLP Page and Policy

Main Modification


Page 53; Policy SS5

Add the following in the third paragraph:


“Prior to the adoption of the Site Allocations Development Plan Document, a permissive approach will be taken when considering housing proposals in :-

  • Yeovil (via the SUEs);
  • ‘Directions of Growth’ for housing at the Primary Market Towns of Chard and Ilminster and Local Market Towns;
  • the Strategic Housing Site as defined in Policy HG1 for Crewkerne;
  • the Development Area at Wincanton.

The overall scale of growth (set out below) and the wider policy framework will be key considerations in taking this approach, with the emphasis upon maintaining the established settlement hierarchy and ensuring sustainable levels of growth for all settlements.  The same key considerations should also apply when considering housing proposals (wherever located) adjacent to the Ddevelopment Aarea at Crewkerne, Wincanton andthe Rural Centres.


Mr R S Pratt







Inspector’s Preliminary Findings following the Resumed Hearings, Letter 16/07/14


Mid Hearing Document – R Pratt H001 Issue 10 Wincanton


Comment ID 365 submitted on Main Modifications 10/1/14 – R.Pratt


Representation - Resumed Examination ISSUE 6 PMM5 – R Pratt (RSP/SSDC/14/003) [Issue 6 Pratt]


Representation - Resumed Examination ISSUE 7 PMM7 – R Pratt (RSP/SSDC/14/004) [Issue 7 Pratt]