The Direction of Strategic Growth has not been adequately or appropriately identified. Please see text below and the attached in support of this statement, the supporting documentation:

• ‘Land at Newtown Road, Langport: Landscape and Visual Baseline Report’ April 2012 prepared by Floyd Matcham (Dorset) Ltd; and
• The Sustainability Comparison of the Options for Growth in Langport/Huish Episcopi.

Land to the North West of Langport/Huish Episcopi:

There is a strong case for extending the Proposed Direction for Growth to the northwest of Langport to take in land to the west of Newtown Road. This is due to the Site’s high level of sustainability being close to the town centre and ease of access to a full range of facilities; and as a result of understanding the landscape context, the ability, through a tailored landscape strategy, to bring forward a sympathetic development of minimal impact despite its proximity to the moors.

The attached Landscape and Visual Baseline Report, undertaken using the recognised guidance of the LI and IEMA adds an additional level of detail to the Council’s own Peripheral Landscape Study for Langport / Huish Episcopi, rather than contradicting it: The former was able to look more fully into the specific impacts of the site in question whereas the Peripheral Study covered the full extent of the combined settlements.

The Baseline Study looks at the landscape characteristics of the surrounding area including landform and built development that make up the particular landscape character of the Site. It considers the sensitivity of landscape receptors and the sensitivity of visual receptors.

The SSDC Peripheral Study included the Site within an area of highly sensitive area because it remains an intact field lying between the urban edge and the moor. While this position is accepted in general (albeit the site itself was not assessed as part of those areas – see Figure 2 of the Landscape Sensitivity for Langport, Peripheral Study) the more detailed Floyd Matcham assessment carried out for the site identifies an approach that responds to the sensitivity of location by recognising its constraints and designing accordingly.

Advised by the Landscape and Visual Baseline Report, we consider it is important to note the following aspects:

• The site forms part of a transitional zone between the open landscape of the moor and the built up edge;
• Fields to the north of the Site act as a break between Langport and the hamlet of Coombe;
• The Site is distinct from the rest of the ‘gap’ between Langport and Coombe due to:

i) presence of the woodland plantation and double hedgerow along most of the western boundary which provides a wide physical and visual buffer between the moor and grassland on the site;

ii) the Site is bounded on two sides by existing development so that it has a direct landscape and visual relationship with the urban edge;

• From the moor the Site is seen against the outline of the ribbon development on Newtown Road whilst the lower part of the Site is noticeably concealed by the woodland plantation and western field boundary;
• From the hill escarpment to the north, the upper part of the Site is perceived as nestling into the existing urban edge whilst the woodland plantation buffers the Site from the moor.

In designing a suitable landscape strategy for the Site the following points are recognised:

• The importance of retaining and conserving the woodland plantation and hedgerows;
• The opportunity to strengthen the natural vegetation in the area;
• Mitigation of the visual impact by a series of design measures including inter alia, setting back from the boundary, introducing new planting buffers to retain the visual separation of the Site from the fields;
• Retention of the frontage hedgerow and trees;
• Appropriate use of gradients and density in terms of securing a design sympathetic to the topography such as split level housing;
• Creation of new vistas within the layout to retain visual linkage with the moor.

In following a landscape strategy arising from these elements, it is possible to minimise impact on the landscape and present a suitable development within the landscape context.

With the above in mind, the Direction for Growth as currently proposed should be widened to bring land to the west of Newtown Road, into consideration.

Direction of Growth to the North of Langport/Huish Episcopi:

Conversely, the Peripheral Landscape Study (PLS) recognises the importance of the separation of Wearne from Langport, and the relatively high sensitivity of site (iv) development of which, it says ‘

is not advocated from a landscape standpoint’ (para 7.6). Analysis by Floyd Matcham concurs that sites (iii) and (iv) (identified at Figure 5 Landscape Capacity Langport, PLS do raise some landscape issues in relation to the separation between the town and Wearne hamlet and the impact of development on the open nature of this area to the north of Langport. Accordingly we assert that this proposed Direction for Growth requires reconsideration:

The Floyd Matcham analysis of these two sites is set out below:

• Site (iii) North of Old Kelways would bridge the existing gap between Kelways and the cottages in Wearne Lane that are read as part of the southern leg of the hamlet. The sense of separation between the town and the hamlet would be lost along the lane which is the main access and approach to Wearne from the A372. The development area would stretch westwards from Wearne Lane across the northern edge of Newtown to the rear of houses fronting the A372. At the planned 40dph the development would, in current thinking, be high density and visually this could result in a very urban northern edge to Newtown running parallel to the settlement form of Wearne. This would also diminish the space and sense of separation between the town and hamlet. As Wearne is at a higher level the views down the slope to the new development could be prominent.
• Site (iv) East of Old Kelways only comes into the frame if more employment and housing land is needed. The site is essentially one large field with no natural sub division and with a very open appearance viewed from the B3153 Somerton Road, Wearne Lane to the west and from the eastern elevated section of the hamlet. This would be an eastwards expansion of the town into open countryside and the same separation and visual issues with Wearne hamlet apply. Looking across site (iv) from the lane near Wearne Farm the new development area south of the B3153 is already a dense urban form but the current openness of the site lends Wearne a suitable ‘breathing space’ as a separate settlement. Development on site (iv) would diminish this and at densities quoted of 35-50 the prospect would be for another peripheral high density development. Also employment growth, while important for the local economy, can lead to large building structures which are difficult to assimilate into edge of town sites.

By comparison, development of the Newtown Road site would have no effect on the gap between Newtown and Combe or Wearne.

Sustainability Appraisal:

In addition to the landscape justification above, land to the west of Newtown Road also scores better than the Options appraised through the Sustainability Appraisal.

Option 1 appraised land to the north and east of Kelways. Option 2 appraised a combination of 3 areas including land to the south of Old Kelways / adjacent to the railway line / south of the Church. No clear distinction was identified between these two options with a difference of scoring between - and -/?.

However, not all the options were assessed. Paragraph 4.85 of the draft Local Plan states that the distribution of growth has been refined from the broad approach using a range of evidence including factors affecting each individual settlement such as land availability and market deliverability. Paragraph 4.88 states that the SHLAA has been used as a mechanism to establish potential housing sites. It should be noted that the SHLAA is not a comprehensive exercise and that in the meantime other sites have come forward which are equally suitable, available and achievable. Land to the west of Newtown Road has become available since the SHLAA was undertaken and should now be considered against the preferred options as it provides a more sustainable location than either Option 1 or Option 2.

Please see Sustainability Comparison attached.