PROPOSED SUBMISSION SOUTH SOMERSET LOCAL PLAN 2006-2028 - EXAMINATION SUSPENSION: PROPOSED MAIN MODIFICATIONS NOVEMBER 2013

Comment ID 849
Document Section Consultation Document Sustainability Appraisal, Habitats Regulation Assessment and Equality Analysis Sustainability Appraisal SA View all on this section
Respondent Charles Bishop Ltd (JB) View all by this respondent
Response Date 10 Jan 2014
Do you consider the Proposed Main Modification is Legally Compliant? Yes
Do you consider the Proposed Main Modification is Sound? No
If you have responded that the Proposed Main Modification is unsound, do you consider the Proposed Main Modification is unsound because it is:
  • Not Justified
Comment

Introduction

I am writing on behalf of Charles Bishop Limited who have relevant land interests in the Keyford area, and also on my own personal behalf.

Summary

We consider the modification to Policy YV2 to be 'Not Justified', simply because inadequate justification appears to have been given for the change from one Sustainable Urban Extension (SUE) to two.

It also seems that very little specific justification been given for the choice of the two smaller Sustainable Urban Extensions.

We can also find no justification for the reduction in dwelling numbers from 2500 to the Plan Period figure of 1565 dwellings. Our understanding of the Inspector's preliminary findings that he was anticipating that the revised Sustainability Analysis (SA) would either confirm or provide an alternative location (or locations) for the 2500 dwelling figure, rather than a reduced figure of 1565 dwellings.

Essentially, while we fully support the proposal to site the 800 dwelling SUE at Keyford, we are concerned that the Council have not produced an SA specifically targeted at this reduced size scheme. We have therefore produced such an analysis, and have appended it to this representation.

Justification for the two individual Urban Extensions

While the Council 's consultants Enfusion have provided extensive SA data on the range of large site options, it appears that this work was not repeated for either of the smaller SUE options, either before or after the decision was taken to pursue the two SUE option.

With landholdings at Keyford, our interest is clearly centred on that area. The reduced scale scheme for 800 units now proposed for the area closely equates with that considered by the previous Inspector at the 2001 Inquiry, Mr David Fenton, and recommended for allocation by him in his 2003 Report.

The reduced scale Keyford scheme fits well within the bounds of the existing urban edge along East Coker Road and Lower East Coker Road, and also within a boundary formed by tree and hedge lined local roads, namely the A37 and Pavyotts Lane.

Although the Council did not accept the findings of the 2003 Inspector's Report owing to there being no need for more residential development land at the time, the conclusions set out in the Inspector 's 2003 Report effectively provide a number of independent and tested responses to many of the Sustainability Objective questions which would apply in respect of a dedicated SA carried out specifically in respect of the proposed 800 dwelling Keyford scheme.

What changes do you suggest to make the Proposed Main Modifications legally compliant or sound? As stated earlier, we maintain our support for the proposed SUE at Keyford to the south of Yeovil.

Our main concern is for the Council to justify the robustness of their procedures in:
- Deciding to have two smaller SUEs in lieu of one large one
- Reducing dwelling numbers in Yeovil in the Plan Period from 2500 to 1565
- Producing an Sustainability Analysis for the smaller proposed SUEs
If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? Yes
If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: As owners of part of the land in the Keyford scheme we feel it is important that we attend the Examination and present our case on the matters outlined above.
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