Proposed Submission South Somerset Local
Plan 2006-2028
Ref:
(For official use only)
Comments Form
Please return this form to South Somerset District Council, Spatial Policy Team,
Brympton Way, Yeovil BA20 2HT by 4.45pm Friday 10th August 2012
This form has 2 parts:
Part A – Personal details
Part B – Your representation(s).
PART A
1.Personal Details*
Both private and as a business owner.
Please acknowledge receipt of this document
Title
Mr
First Name
Peter
Last Name
Cameron
Job Title
Director
Organisation
(where
relevant)
ComVerge Ltd
Address Line 1 East Cottage
Line 2
East Coker
Line 3
Line 4
Post Code
BA22 9JY
Telephone
Number
01935 863249
Email Address
(where
relevant)
both@cameron-house.com
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I consider the DPD is unsound because it is:
Not Justified
Not Effective
Not Consistent with national policy
I consider the DPD is not legally compliant or is unsound because
The Plan has not been objective – the evidence tables show subjective valuations.
The planners and/or council have been unfairly swayed by one major landowner and
developer – the Red House roundabout was built many years ago for no reason – is
this the payback? The planners and/or council have not considered all the options
for future development around Yeovil – Abbey Manor Group are already protesting at
the proposal.
The Plan has paid no regard for comments during the previous consultation and has
disregarded the results of some of the council’s own reports.
The Plan has disregarded the Rural nature of South Somerset and the major role
agriculture plays within the community. It also pays total disregard to the increasing
requirement for self-sufficiency and sustainability in local food production. We need
to respect nature and not destroy its best assets by concreting over the best
agricultural land in the country.
No ‘Garden City’ is consistent with the housing density of 2500 houses on the Grade
1 Agricultural land proposed. The Councils own sustainability policy states Avoid
developing on Best and Most Versatile agricultural land, unless this is unavoidable
considering other sustainability issues, and that land in lower grades has been fully
considered (addressed in considering locations for development).
The assertion that the proposal will follow best practice with regards to ‘Green
Transport’ is unsupported. There have been no details of improvements of the
A37/A30/A3088 to prevent major traffic issues on these through routes Nor have
there been any suggestions as to how Hendford Hill could be improved. No obvious
means of improving cycleways and footpath connections to Yeovil Town Centre or to
the Station have been put forward and no idea of how “people” will actually be
encouraged to use them.
Change(s) necessary to make the DPD legally compliant or sound, having
regard to the test identified above
1.
Revise all Policies SS1-5 to delete Policy YV1-3 Yeovil Sustainable
Urban Extension.
2.
Deletion of Policy YV 6 Delivering Sustainable Travel in Urban
Extension.
3.
Rethink some previously considered options
a. E.G. from South Somerset’s settlement hierarchy workshop discussion
paper March 2011 …………. In the past Sparkford has been considered a
suitable location for further housing and employment opportunities especially
given its proximity to the main road network and availability of land close to it.
Railway passes through and consideration could be given to re-opening the
station. The Parish Council want to promote employment opportunities therefore there is a need for more housing to in the area.
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What an opportunity to provide rural housing to a community that apparently
wants to grow, that is near business parks, near the A303, but within a 10 minute
eco friendly train journey to the local shopping town of Yeovil.
4. Pay attention to your own Functional Economic Market Areas: Somerset
Analysis Prepared By SWO August 2010 which states that “There are two main
areas where the population is stable or decreasing that appear to affect Somerset: 1)
In the west and south. This covers West Somerset, Taunton Deane and South
Somerset.”
There is no need for any urban extension
In addition I have other objections
GENERAL
I object to the way the SSDC has gone about this plan in many different ways. For
example the online form is designed to put people off responding as it implies legal
knowledge, understanding of planning policies and laws, and understanding of all the
various acronyms such as DPD, etc.
There is simply no justification that 2500 houses are required.
There has been no justification that the chosen site for the proposed urban extension
is better than any other apart from the planners appearing to have been in close talks
with the owner/developer.
Costings were produced to show that the road infrastructure would be more
expensive to create if the development was to the north of Yeovil. These were then
revised to show it would not make any difference in cost. No plans are forthcoming
about any changes to the road infrastructure around the urban extension and so
Yeovil can expect gridlock within the time period of the plan.
There has been no justification to use Grade 1 agricultural land to build the proposed
urban extension. It was simply dismissed as unimportant.
There has been no response to see how flooding will be prevented if the proposed
urban extension is built. After this summer surely this needs some consideration as
the future cost of flood defences and the additional cost this will mean to the council.
The impact of the proposed urban extension will be to impose a decline on the
sustainability of East Coker and the other villages surrounding south Yeovil. Do we
really think that a local village shop will be able to survive?
If there is a competing
centre for shopping it will have a major impact on Yeovil town centre, which is
already in decline, and therefore reduce the sustainability of Yeovil and the whole
South Somerset plan.
If the council was really interested in the sustainability of the district as a whole it
would allow small scale development within each town, village or hamlet according to
the need of that community. Transport is only one factor in “sustainability”.
It
would also take a different stance on farming and agriculture as that has been totally
ignored in the plan and appears not to hold any importance to the council.
Foreword. Mr Pallister states in his foreword to the Proposed Plan: “The National
Planning Policy Framework states that Sustainable means “ensuring that better lives
for ourselves does not mean worse lives for future generations”. This Plan seeks to
endorse that statement for South Somerset.”
Today, we live with worldwide
uncertainty of weather, environment and security. The public is now waking up to
the fact that natural foods and natural growth is important and therefore, to consider
the wilful destruction of the best agricultural land in the area is foolish at the least and
criminal at the worst. The lives of future generations will be seriously affected for the
worse when they find that their predecessors have destroyed the means to live.
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I have to object that the plan is founded on unsound understanding of the public’s
requirements.
Agricultural employment The working population of rural Somerset is ~40%
of all employment and I expect that figure is much higher in South Somerset as a
district, and the SSDC should be finding ways to encourage local farming and food
production for which Somerset is famous around the world and not focussing on the
one urban area within its district. Whilst people in the UK may know Garador, the
whole world knows Cheddar.
Under the heading of Purpose of the Local Plan
reference is made to the South Somerset Sustainable Community Strategy
(SCS). Having briefly read this document I can see that its writers were trying to
prepare a sensible vision for the future, but I would object to it being relied on as it is
based on data from 6 years ago when the economy was very different and by its own
admission. The sample data for the consultation cannot be representative if it is only
64 respondents. (Summer 2007: Consultation of the Trends and Issues document
included mailing stakeholders and an online questionnaire. Collating the consultation results
from 64 respondents, of which 4% were from town councils, 35% from parish councils, 11%
from Somerset County Council, 24% from South Somerset District Council, 14% from
voluntary and community sector organisations and 12% from other statutory organisations.)
Under paragraph 1.9
it is stated that the Council has reviewed the 950 responses with 2850 specific
issues. It would seem that the council’s defence of the issues raised has simply
been to dismiss them without any justification. (I for one posted many objections
and comments on the Core Strategy but I can not see my name mentioned in the
list.) When the growth figures and housing projections have been questioned, by
their own admission, they have always been over inflated. It would appear that the
planners’ justification is that if a developer has land to build on then we had better
find enough housing to put there. Once again I must object to the use of over
inflated figures to suit the needs of developers and not the public. One has to
assume that the council has something to gain in terms of the CIL or other levies or
funding of projects.
We all understand that housing is required for population growth and other changes,
but when the planners built high density housing to provide “community living” in the
50’s/60’s, we all had to pay for the social unease it caused. In a rural environment
and a rural county we need to rural housing and infrastructure. Houses should be
built when and where people need them. If a philanthropist company needs to
employ an additional 3000 workers let them build a Bourneville. If a farm worker
wants to live in walking distance of his farm lets find a place for him to live. But to
build a new town on the outskirts of an existing town makes no sense especially
when there is not enough employment, when the town centre is in need of
refreshment and the shops are not occupied. I object to the proposed 2500 houses
to be built on England’s green and pleasant land. I object to a plan that states that
it needs 1565 homes but proposes an additional 1000 after the time period of a plan.
The 2006-2028 plan should not be allowed to include years outside that date
range. It can only encourage more developers buy up land in speculation of what
might be.
Para 1.32
The Local Plan is based on an Employment-led approach – however, there have
been no proposals as to how any new employment is to be introduced or what
incentive there is for employers to locate in Yeovil. If the area is seen to be vibrant
then employers and their employees will be only too happy to relocate. But why
does the council not want to encourage farming and agricultural use of the district?
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Much better to build on your strengths (agriculture) rather than fight for the scraps of
industry that could be located in any region of the country. I therefore object to the
statement that the approach is employment led.
Para 2.11-2.13 Rural Employment
Once again no mention of Agriculture and farming
Why does the council not want to encourage farming and agricultural use of the
district? Tourism may account for 5% of the rural economy but the south west
provides more than 25% of the farming industry units of the whole country. I
therefore object to the plan and the people who do not understand the local
economy as it really is. Devon is encouraging farmers by providing council owned
farms to rent. Somerset is throwing tenants off the land.
The Vision for 2028
Under this heading it is stated that: “There will be continued protection of distinctive
urban and rural environments”. Yet the rural settlement of East Coker will have been
overrun by traffic, overlooked by a new town and flooded by lamplight throughout the
darkness hours if not by the rainwater pouring down from the tarmac and concrete.
The Yeovil Sustainable Urban Extension will be established and act as an exemplar of the
benefits of more sustainable living with local job and service self sufficiency, high quality
design of buildings, a high level of attractive open space, leisure facilities and parkland.
These aspirations are in accordance with the aims of Paragraph 52 of the NPPF which refers
to large-scale extensions to settlements following the principles of 'Garden Cities’. We
have not been shown that the sustainable living aspiration is feasible or that the
developer will buy into the extra expense of providing the high quality design of
buildings or the attractive open spaces.
“South Somerset will have retained a viable agricultural base with high quality local food
production reducing the need for imports and food miles”. If the plan is to continue to
build on the best Agricultural land in the district this aspiration will not be achievable.
Aspirations and visions are wonderful window dressing to the reality of the
destruction of the local communities and settlements. I object.
4.32
Policy SS2 seeks to ensure the development needs of Rural Settlements can be met,
whilst restricting the scale of such growth to be consistent with the spatial strategy of
focussing most development at Yeovil, the Market Towns, and the Rural Centres.”
But I object because East Coker, which as a Rural Settlement, will not have a
life of its own but will be coerced into becoming a suburb of Yeovil. I point out
that in your own words: “Given that Policy SS2 is starting from the premise of no
development unless certain conditions are met, the evidence for development being of a
strong sustainable nature is particularly important to provide. Furthermore the local
community are best placed to determine local need and what will make their settlement
more sustainable and there will be an expectation that development proposals have
either come from the local community, or been tested and checked through local consultation
and engagement.”
We should indeed respect the locality and nature of the rural communities and we
should allow them to build what is right for that community. It does not need long
term plan to achieve this. If the council encouraged local agriculture it might require
additional rural development and housing and that might reduce the requirement to
turn Yeovil into the expected larger and larger town.
Sustainability:
I object to the interpretation that Sustainability is linked, inextricably, with
concentration of population in one location. Sustainability could mean self
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sufficiency within the rural settlements which would in turn make the district, county
and country more sustainable.
East Coker Parish Plan
I object that the council has taken no consideration of the local community and its occupants
as expressed in the East Coker Parish Plan.
The following is extracted from the East Coker Parish Plan of 2005 and indicates the fears
that are now coming to pass.
43% of households think there are threats to certain aspects of the parish, many of which
focussed on developments on farmland, and its implications. People want East Coker to
maintain its independence from Yeovil. Housing development creating an urban sprawl and
encroaching on current open land is seen as a potential threat. This is closely related to
loss of peace, tranquillity, open countryside and grade 1 agricultural land.
Building development
The rural nature of the parish is much valued, potential development is seen as causing
noise and light pollution, and a loss of wildlife.
Light pollution
This is of concern. Somerset County Council has a rolling programme to replace its street
lights.
It is understood that the new lights will reduce light pollution. Some people asked if South
Somerset District Council could be asked to instigate a rolling replacement of Yeovil's lights
to avoid upward spillage. The Rugby Club lights are still found to be obtrusive, as is the
church light which it was suggested could be angled down, or turned off completely.
Individual house security lights are often too bright and badly set. …. Some households
specifically objected to the idea of street lighting and some wanted what exists removed.
If your representation is seeking a change, do you consider it
necessary to participate at the oral part of the examination?
No, I do not wish to participate at the oral examination
Yes, I wish to participate at the oral examination*
Yes
If you wish to participate at the oral part of the examination, please
outline why you consider this to be necessary:
Because I do not believe the council understands the serious mistake it is making in
treating agriculture as “not required” in one of the most famous parts of Great Britain for
its agricultural heritage.
Please note the Inspector will determine the most appropriate procedure to adopt to hear
those who have indicated that they wish to take part in the oral part of the examination.
Signature:
Date:
3 August 2012
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