Comment ID 1358
Document Section Proposed Submission Local Plan 2006-2028 Environmental Quality Environmental Quality View all on this section
Respondent Blackdown Hills AONB View all by this respondent
Response Date 10 Aug 2012
Do you consider the DPD is Legally Compliant?
Do you consider the DPD is Sound?
If you have responded that the DPD is unsound, Do you consider the DPD is unsound because it is:

We wish to object to the plan as we consider that the lack of a policy relating to AONBs and landscape/landscape character is a significant omission, and contrary to the requirements of the NPPF.

Furthermore, section 85 of the Countryside and Rights of Way Act places a duty on local authorities and other public bodies to have regard to the purpose of designation in exercising their functions and duties. We consider that the inclusion of a policy specifically dealing with conserving and enhancing AONBs (which would apply to all development within or affecting the AONB) would demonstrate the council’s compliance with that duty.

The start of chapter 12 environmental quality (paragraph 12.1) states that ‘maintaining and enhancing environmental quality in South Somerset will require the Council to address … protection and enhancement of the historic environment, landscape and biodiversity …’ however there is scant regard for landscape in the remainder of this section.


The varied landscape and natural environment of South Somerset gives the district its sense of place and contributes greatly to quality of life and the local economy. The three AONBs within and adjacent to the district exemplify the high quality, distinctive landscapes across the area. The plan should therefore provide suitable guidance so that proposals for development should be informed by, and be sympathetic to, the distinctive character areas and features that have been identified across the district.

The core planning principles set out in the NPPF include one that states that planning should take account of the character of different areas, recognising the intrinsic character and beauty of the countryside. A further point highlights that planning should contribute to conserving and enhancing the natural environment. In relation to plan-making the NPPF (paragraphs 156 and 157) states that local plans should include strategic policies to deliver conservation and enhancement of the natural and historic environment, including landscape and that they should contain a clear strategy for enhancing the natural, built and historic environment. We believe that the case for inclusion of landscape policy is therefore clear.

More specifically in respect of AONBs, paragraphs 113 and 115 of the NPPF set out that additional considerations should apply in AONBs, in particular that local planning authorities should set criteria based policies for judging development proposals affecting protected landscape areas.

In conclusion, we are pleased to note that many of the comments and suggestions that we submitted in response to the draft core strategy in 2010 appear to have been addressed in this document, however the lack of policies relating specifically to AONBs and landscape character remains a grave concern. We trust that you will find our comments and observations helpful. We would be very happy to discuss any points further in due course and welcome continued involvement in the local plan process.

What changes do you suggest to make the DPD legally compliant or sound? We appreciate that until recently core strategies/LDF documents were prepared on the basis that Regional Spatial Strategies (RSS) and national planning guidance would provide higher level policies and guidance, particularly in relation to AONBs for example, and should not be repeated in local planning documents. However, with no higher level plan and much streamlined national policy, it is now essential to address the policy ‘gap’ through locally defined policies.
If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination?
If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: