Comment ID 763
Document Section Consultation Document Sustainability Appraisal, Habitats Regulation Assessment and Equality Analysis Sustainability Appraisal SA View all on this section
Respondent P J Burrows View all by this respondent
Response Date 10 Jan 2014
Do you consider the Proposed Main Modification is Legally Compliant?
Do you consider the Proposed Main Modification is Sound?
If you have responded that the Proposed Main Modification is unsound, do you consider the Proposed Main Modification is unsound because it is:

The conclusion drawn and summarised within Paragraph 2.17 of  the consultation document (Ref. 1) is based to a significant degree on the Sustainability Appraisal Report (Ref. 2) with other factors such as deliverability and availability also taken into account. Four areas of the Sustainability Appraisal Report (SA) will be considered:

9. Protect and enhance the landscape and townscape 

Ref. 2 Appendix II pII-56 states: 

The cumulative effect of a number of smaller scale developments on the landscape is difficult to determine as each area that forms part of the Multi-site Option is within a different landscape setting. With this in mind, you could potentially assume that the impact of a number of smaller sites would be less than a larger site within an individual landscape setting. 

It then goes on to consider what may happen beyond the plan period as a result of  ‘piecemeal stages’ rather than ‘a single masterplanned form’. However, it is evident that a number of smaller developments would be less detrimental to the landscape and townscape. Also, there is no reason why a number of smaller developments should not be equally well planned, even to take account of future expansion. Integration and mitigation opportunities would be more evident in this case of smaller developments. 

SA objective 9 should then be rated as less negative for the Multi-site Option than the other options and given the uncertainty that exists could be ranked as “?”. 

10. Historic environment 

Ref. 2 Appendix II pII-13 states: 

The Historic Environment Assessment of Yeovil Periphery (July 2010) identified this area (study area 3 and 4) as having a moderate to high historic landscape sensitivity and moderate to high historic asset sensitivity. The study concluded that the capacity of this area to accommodate new development without loss or damage to key historic landscape sensitivities and historic assets is moderate to low.  

It then goes on to state that under this option most of the development will fall within an area which has moderate capacity to accommodate potential new development. However, a development of 1,565 dwellings as a single site within this area is hardly consistent with a “moderate” development capacity within a parish that is currently around 800 dwellings. Further, East Coker Parish contains more than 80 listed buildings and 2 conservation areas. Insufficient weight has been given to protect this historic environment. The impact is “major negative” and the ranking for Option B in this category should be rated as such. This would truly reflect the shortcomings of this option when measured against the objectives of NPPF Section 12. 

12. Minimise pollution 

A key parameter within this category is a consideration of the loss of the highest grades of agricultural land. Within the Multi-site Option the distribution of development should at least be such as to avoid the loss of Grade 1 agricultural land. The hierarchy of use should be consistent with NPPF paragraph 112 which states that lower grade land should be used in preference to higher grades. If the distribution of development is performed such as to comply with this objective, the ranking of the Multi-site option should be changed from “Major negative” to “Minor negative”. This would probably require that no or very little development takes place within the Option B part of the Multi-site Option. 

13 Flooding 

The SA states that there is an element of uncertainty in the Multi-site Option as the effect is dependent on the combination of sites selected. Given the reduced development in each area, it should be possible to comply with NPPF Paragraphs 99 to 101 and avoid the flood-prone parts of Option C included in the Multi-site option. This parameter would be then ranked the same as the options B and C, i.e. “0”. 

Revised Sustainability Appraisal: See attached


What changes do you suggest to make the Proposed Main Modifications legally compliant or sound?
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: