2.5 Over the course of the preparation of the plan, the scale of development proposed for the greenfield sites in Yeovil (within the plan period) has progressively decreased in scale from 5,000 dwellings, the minimum size generally considered viable for an ‘Eco Town’ to 3,700 dwellings, to 2,500 dwellings to 1,565 dwellings.

2.6 The Sustainability Appraisal Review Addendum[1], conducted by independent consultants, derived reasonable alternatives for growth using previous landscape assessments[2] constraints analyses, further desk and site based work, and an updated Landscape Addendum[3]. It was concluded that assessment of reasonable alternatives using 2,500 dwellings as the base level for options assessment, which exceeded the housing need in the plan period, was not justified in that it would mean that there was only one area (the southern, Coker area) with the capacity to accommodate this scale of growth, and would therefore pre-determine the outcome of the process.

2.7 Both single-site and more than one site, (multi-site) alternatives to accommodate housing need were considered. As housing need has progressively reduced, there is no substantive evidence to suggest that a single one site of 1,565 dwellings (or 2,500 dwellings) would give the full range of community, social and employment facilities that would create a totally self-sustaining community of scale. Consideration through the SA Addendum process concluded access to services would inevitably require integration to a greater or lesser extent with the town of Yeovil. Being able to accommodate expansion beyond the plan period was a consideration[4].

2.8 An assessment based on the identified housing need for the plan period of 1,565 dwellings meant that reasonable alternatives could be considered. Four areas were considered to be reasonable alternatives; the North Eastern Area (Upper Mudford), the Southern Area (Coker) the Eastern Area (Middle Yeo Valley & Dorset Hillsides) and, as part of a multi-site option, all three sites plus the Western Area (Brympton D’Evercy).

2.9 The SA Addendum used the established SA objectives. It concluded that from the four areas that could be reasonably considered for directions of growth, there was no clear direction of growth for Yeovil that was more justified than another across the range of SA objectives, either on a single site, or on more than one site. Based on the SA Addendum a further sieve of the directions of growth areas was undertaken using a further Criteria Assessment[5] that looked at key factors and in particular deliverability, market capacity and mitigation potential.

2.10 Since the Issues and Options stage of the plan the Council has opted to introduce a Community Infrastructure Levy. This enables funds to be collected and used where most needed, giving greater flexibility to Education and Highway authorities and giving the ability to contribute to facilities both on site, through Section 106 contributions and off-site through Community Infrastructure Levy (CIL), where they are most efficiently provided for instance to adding capacity to existing facilities.

2.11 The Council have considered the changing context to growth and in particular the current lack of housing land supply in the District and requirement to provide sites with a realistic prospect of delivery within 5 years (National Planning Policy Framework, Para 47). There is evidence to suggest that the proposed Main Modification will lead to an increased land supply in the earlier years of the plan. Discussions with developers indicate preference for a reduced scale urban extension which they consider will aid deliverability. Viability evidence undertaken by the Valuer and consultants on the CIL draft-charging schedule, confirms this. There is evidence to suggest that the market will deliver a greater housing build rate if a choice of sites is offered.

2.12 The Council believes that a Modification that allows for more than one development area is consistent with the strategy of the plan and will maintain the aspirations of Policy YV2. It does not represent a departure from the Local Plan’s strategy which is to concentrate development in Yeovil, to seek sustainable development of the highest design standards, incorporating green infrastructure and localised energy generation infrastructure which minimises the need to for car travel and carbon emissions on every site. There will be 40 % open space on both areas and a master planning approach will ensure that these standards are maintained. This, together with the inevitable need for urban extensions to draw on the existing facilities of the town, suggest that an approach that integrates development into the town using existing social and transport infrastructure is a reasonable response to contextual changes and the findings of the SA addendum.

2.13 The reference to a secondary school has been deleted as although it is a requirement to meet the needs of the 7,441 dwellings to be delivered over the plan period, the education authority are unable to conclude the most appropriate location to satisfy Yeovil’s long term needs. The scale of growth in the Sustainable Urban Extensions alone does not generate sufficient educational place demand to require a fourth secondary school in Yeovil within the plan period, however, contributions will be sought for secondary provision through CIL or Section 106 obligations, and the need for new provision will be reviewed during the plan period.

2.14 The two directions of growth will be included as part of the Site Allocations Development Plan Document programmed as a part of the Council’s Local Development Scheme. Should developers come forward with planning applications in advance of this, the permissive approach (recommended in the amendment to policy SS5) will apply and the Council will work with the developer and the community to ensure the principles of sustainable development are employed.

2.15 The Inspector acknowledged the difficulty in assimilating development into the town and referred to the mitigation potential from reduced housing numbers not having been fully explored (Para 33). The Council believe that the concentration on provision in the plan period of 1,565 dwellings, and on more than one site provides opportunities for important mitigation of the landscape and heritage impact, as well as the loss of Grade 1 agricultural land. The potential for this mitigation, it believes, will be optimised through the next stage of site based master planning, guided by the development plan process and the development management system using the polices of the Local Plan and the NPPF.

2.16 The conclusions of the process, including the additional criterion assessment are that there are two preferred Directions of Growth, namely Coker and Upper Mudford – contiguous with the existing Lyde Road Key Site. The Upper Mudford option was considered as deliverable, able to help provide additional community facilities that could supplement deficiencies in the north east of Yeovil, and would lead to less loss of the highest grade agricultural land. The Coker option was considered as being deliverable, having the potential to provide more market capacity and housing choice within Yeovil, as well as offering opportunities for integrating with nearby informal recreational opportunities.

2.17 Overall these two areas represented the most sustainable areas that will deliver the housing needs of the town of Yeovil. The approximate dwelling numbers are indicated as 765 on the North- Eastern site (Upper Mudford) and 800 (Coker) on the Southern site. This is based upon analysis of landscape, natural constraints and land availability. The precise numbers will be dependent on work to be undertaken through masterplanning and the Site Allocations DPD.

2.18 The Inspector in his letter of the 3rd July considered the Council’s SA assessment upon which the selection of areas for growth was based to accommodate the Yeovil Sustainable Urban Extension. In his conclusion he said he was unable to conclude that the area chosen for the Sustainable Urban Extension was the most appropriate strategy, when considered against reasonable alternatives (Para 53). He raised four concerns:

• The lack of weight attached to the need to seek to use areas of poorer quality agricultural land in preference to that of higher quality (bearing in mind that, once lost, such high quality land cannot be retrieved);
• The lack of substantive evidence to demonstrate that there are significant differences in terms of landscape impact between several of the options that have been considered. Opportunities for mitigation, primarily through layout and design do not appear to have been significantly addressed;
• Lack of consistency regarding the consideration of protecting and enhancing the historic environment; and
• Lack of clarity regarding the scoring for objective 14, conserving and enhancing biodiversity and geodiversity (Para 51).

2.19 In response the Council has carefully and thoroughly reconsidered its approach that led to the current choice of Direction for Growth within the Proposed Submission South Somerset Local Plan and, in particular, whether there were reasonable alternative areas to accommodate development sustainably.

2.20 The Inspector suggested that substantial further work was required to demonstrate the Plan was justified in respect to Yeovil (Para 66). The Council is mindful of the comment in his letter of the 17th July 2013 that ‘genuine reassessment of the situation will need to be undertaken, rather than providing a more detailed justification for the decision already taken.’

2.21 The Council engaged independent expert consultants who have reappraised the SA process in the light of the Inspector’s comments.

2.22 Consultants reviewed the iterative process that the Council undertook to produce the SA, and concluded that, despite having undertaken appropriated analyses at each stage, it was not always clear why options were selected or rejected. They agreed with the Inspector that the scoring that was undertaken in the final SA was inconsistent. The ‘Compliance Review’ sought to more clearly explain the work that had gone into the process and also to give the Council recommendations to guide the new SA Addendum, which is now considered fully compliant against the relevant SEA European legislation.

2.23 Polices YV1 and YV2 are amended below to clearly indicate the removal of the housing requirement for Yeovil post plan period, and the introduction of 2 Sustainable Urban Extensions as opposed to one. The Proposals Map for Yeovil has been amended to show two Directions of Growth for Yeovil, namely Coker and Upper Mudford, within which the Sustainable Urban Extensions will be delivered.

2.24 Consequential changes to Policy SS5, YV6 and SS3 are also presented as part of PMM1 and PMM2 below.

2.25 The Proposed Main Modification is presented in the table below (any new text is underlined and deleted text is shown as crossed through). For completeness and to allow the reader better understanding, the modifications include minor modifications agreed following submission of the South Somerset Proposed Submission Local Plan (blue text reflects minor modifications arising from Full Council on the 17th January 2013, and red text reflects additional minor modifications arising from “the Council and Objector’s Statements and Inspector’s Requests for Clarity, June 2013”).