PROPOSED SUBMISSION LOCAL PLAN 2006-2028 - Aug 12

Comment ID 2062
Document Section Proposed Submission Local Plan 2006-2028 Environmental Quality Historic Environment Policy EQ3: Historic Environment View all on this section
Respondent East Coker Preservation Trust View all by this respondent
Agent Richard Burgess Associates (R…
Response Date 09 Aug 2012
Do you consider the DPD is Legally Compliant?
Do you consider the DPD is Sound? No
If you have responded that the DPD is unsound, Do you consider the DPD is unsound because it is:
  • Not Justified
Comment

The Trust supports the above policy strongly but considers the proposal for a south of Yeovil Major Urban Extension to be in fundamental conflict with Policy EQ3 (and in particular criteria (i.) for the reasons set out in its objections to Policy YV2 in terms of impact on Heritage Assets.

In the Trust’s submission South Somerset District Council have failed in its duty to consider properly and equitably the impact on Heritage Assets both in the comparative selection of the Urban Extension site and in absolute terms on the assets in the Keyford/East Coker area relative to current government Policy.

In summary to comply with the National Planning Policy Framework the Trust would submit that SSDC would have to substantially re revise the Plan and supporting documents to address the following:-

  • To comply with NPPF, the evidence base should take into account the setting of all designated heritage assets, within and around the proposed development area. This should also include identifying the significance of each, using the four values of historical; evidential; aesthetic and communal as enshrined in the English Heritage Conservation Principles, Polices and Guidance, PPS 5 guidance and NPPF.
  • The scheduled monument significance and setting, in relation to NPPF, has not been defined, with the level of detail appropriate to the asset’s level of importance. In a policy of ‘Informed conservation’ supported by EH, the significance of an asset should be defined to enable its conservation in the form of a heritage statement or similar.
  • The character, setting and local distinctiveness has not been adequately assessed and identified so that it can be safeguarded It is recommended that an Historic Environment Character Appraisal be provided and be NPPF compatible.
  • Group value of the heritage assets may be eroded if development corridors were created between the nationally important sites. An assessment of the erosion of group value of the assets can only be informed by a full assessment of significance and setting of each individual heritage asset and subsequent group value.
  • Insufficient consideration has been given to the non-designated heritage assets, such as the potential for below-ground archaeology. One of the reasons that there are less archaeological finds spots in the proposed development area is the areas has previously been undeveloped. Given the known sites and features of archaeological significance in the area, it is anticipated that potential for further archaeological remains would be high. Absence of evidence is not evidence of absence. The potential for archaeological features dating to the prehistoric and Roman period would be high
  • The significance of non designated heritage assets has not been clearly determined; there is no local list of heritage assets, contrary to advice by English Heritage (2012) Good practice guide for local heritage listing.
  • Community identity and sense of place are yet to be investigated and defined within the parameters of English Heritage guidance (2011) Knowing your place. Heritage and community-led planning in the countryside.

The significance, character and setting referred to in Policy EQ3, has not been adequately assessed in this case. The evidence base used as a foundation for these decisions is incomplete. Para 132 of the NPPF gives great weight to the conservation of designated heritage assets. However, this framework has not been considered in the ‘Historic Environment Assessment of Yeovil Periphery’,

At present there is no conservation area appraisal available for viewing on the SSDC website of East, North or West Coker. Access to a full and comprehensive conservation area appraisal for each of these areas would aid the definition of local distinctiveness that Policy EQ3 wishes to retain. These appraisals are considered to be essential for decision making, without which a decision cannot be adequately informed.

What changes do you suggest to make the DPD legally compliant or sound? The deletion of Policy YV2 from the Plan. This would remove the inherent conflict within the plan between Policy YV2 and Policy EQ3 . It would also correct the failing in the Plan that Policy YV2 is not soundly based or in compliance with National Policy as set out in the NPPF in that the Heritage and Landscape background information is unsound, unsystematically collected and not in accordance with current NPPF or English Heritage advice.

The Proposal for an Urban Extension on the south side of Yeovil is considered to pose a fundamental threat to the landscape, heritage and setting of this part of the rural environs of Yeovil; it is also considered to be unnecessary; to be based on incorrect calculations and assumptions both with regard to housing need, population growth and densities.

Furthermore the process whereby SSDC arrived at this area as their preferred location for urban growth is considered to be flawed and based on inadequate/incomplete evidence with regard to environmental, transportation, landscape and heritage impact both in itself and relative to other options. As such it is considered that the plan is fundamentally unsound and essential that the East Coker Preservation Trust’s professional representatives be allowed to participate fully in the Examination of the policies to which objection is made, including by means of cross examination of the Councils witnesses.
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: It is considered that the plan is fundamentally unsound and essential that the East Coker Preservation Trust’s professional representatives be allowed to participate fully in the Examination of the policies to which objection is made.
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