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ITEM 11 EXMOOR NATIONAL PARK AUTHORITY PLANNING COMMITTEE 3 September 2013 CONSULTATION RESPONSE TO THE DRAFT WEST SOMERSET LOCAL PLAN – REVISED PREFERRED STRATEGY Report of the Head of Planning and Sustainable Development

Authority Priority: Securing more resources and influencing national and regional policy for Exmoor.

Legal and Equality Implications: Section 62, 11(A) of the Environment Act 1995 confers a duty on certain bodies and persons to have regard to the purposes for which National Parks are designated. These include that:

(1) The National Park Authority, in pursuing National Park purposes, shall seek to foster the economic and social well-being of local communities within the National Park, should co-operate with local authorities and public bodies whose functions include the promotion of economic or social development within the area of the National Park.

(2) In exercising or performing any functions in relation to, or affecting land in a National Park, relevant authorities should have regard to National Park purposes. Under the Act a ‘relevant authority’ includes any public body and this includes any local authority.

The Draft West Somerset Local Plan will form the development plan for the area of West Somerset outside the National Park boundary. The development plan guides and is the first consideration in determining planning applications for land use and development. Section 38 of the Planning and Compulsory Purchase Act 2004, states that planning applications should be determined in accordance with the development plan unless material considerations indicate otherwise.

The Localism Act 2011 (Section 110) introduces the ‘duty to cooperate’ in relation to planning of sustainable development. This includes engaging constructively with neighbouring planning authorities in relation to strategic matters in the preparation of development plan documents.

The equality impact of the recommendations of this report has been assessed as follows: It is considered that there are no equality issues in relation to this report.

Consideration has been given to the provisions of the Human Rights Act 1998 and an assessment of the implications of the recommendations of this report is as follows:

It is considered that there are no human rights issues in relation to this report.

Financial and Risk Implications: The financial and risk implications of the recommendations of this report have been assessed as follows: None on the basis of this report.

Purpose of the report: To seek approval of a consultation response to the Draft West Somerset Local Plan (Revised Preferred Strategy) and to comply with the Duty to Cooperate.

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RECOMMENDATION(S): The Committee is recommended to:

1. APPROVE the recommendations in the report as the basis of the National Park Authority’s response to the consultation on the Draft West Somerset Local Plan

2. DELEGATE to the National Park Officer authority to make minor revisions and elaborations to the consultation response before submission, as required.

1. INTRODUCTION

1.1. DUTY TO COOPERATE: National Park Authority officers have met with District Council officers to discuss strategic matters in relation to the preparation of both Exmoor National Park and West Somerset Local Plans. These initial meetings have been effective in highlighting particular issues and approaches prior to the commencement of the consultation.

1.2. The duty to cooperate will be furthered through the submission of the Authority’s consultation response set out in this report, together with future arrangements to demonstrate that there has been constructive engagement in the development of strategic policies during the formative stages of the plan process.

1.3. Joint commissioning of evidence to inform individual plans on key issues is one of the ways that can also be used to demonstrate the duty to cooperate. The Authority has worked in partnership with North Devon, Torridge, West Somerset and (formerly) North Cornwall Council on commissioning the Strategic Housing Market Area Assessment (SHMAA) and development of the Strategic Housing Land Availability Assessment (SHLAA) methodology. Further joint working across both local planning authority areas has included the Strategic Flood Risk Assessment (Level 1) and a Quantitative Needs Assessment (Retail Study).

1.4. CONSULTATION ARRANGEMENTS: This report sets out the context and specific comments on the Draft West Somerset Local Plan (Revised Preferred Strategy) which has been published for consultation for eight weeks from 29 July to 23 September 2013. The Authority has previously submitted responses to the West Somerset Core Strategy consultation on the development of strategy and policy options in 2010, and the Draft Local Plan Preferred Strategy consultation in 2012.

1.5. The Localism Act and publication of the National Planning Policy Framework has led to significant changes in the planning system and therefore West Somerset Council has revised its ‘Local Plan’ that sets out policies to guide development and land use across the local planning authority area of West Somerset until 2032. The requirements of the NPPF and the proposed changes to the Local Plan include:

Meeting the full, objectively assessment needs for market and affordable housing in the housing market area has meant a review of the Strategic Housing Market Assessment and resulting housing requirement for the Local Plan.

Identifying key sites to deliver the housing strategy over the plan period has meant that specific development sites have been identified.

A requirement to add a design policy to the Local Plan.

A settlement hierarchy has been proposed to make the housing strategy consistent.

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1.6. The consultation document has been prepared to highlight the key changes made to the Local Plan through the inclusion of the matters above. Other supporting consultation documents that are available include an appendix of maps/figures supporting the Local Plan strategy. However there is no accompanying Proposals Map (including inset maps for the settlements), Sustainability Appraisal, or Habitats Regulations Assessment Screening Report to support the revisions made to the plan.

2. COMMENTARY ON THE DRAFT WEST SOMERSET LOCAL PLAN (REVISED PREFERRED STRATEGY)

2.1. This section sets out those particular issues which are of most relevance to the National Park Authority. The full version of the Draft West Somerset Local Plan and associated documents can be found at:

http://www.westsomersetonline.gov.uk/Planning---Building/Planning-Policy/Current-Consultations

2.2. West Somerset Council (WSC) is inviting responses to the following questions:

Question 1: Do you consider that the proposed changes to the 2012 Preferred Strategy document highlighted in the Revised Preferred Strategy document, properly address the changes in the National Planning Policy Framework? If not how should the plan be changed?

Question 2: Do you have any specific comments about the appropriateness of any of the proposed Key Strategic Development Site allocations or any of the new policies / changes to existing policies listed in the table above [refers to a list of new and amended policies in the revised plan]?

2.3. The National Park Authority responded to the West Somerset Local Plan Preferred Strategy in 2012 and those comments relating to policies unaffected by the revision are therefore regarded by the Authority as representations for consideration by WSC, and will not be repeated in this response. WSC Officers have advised that representations made to the previous Local Plan Preferred Strategy will be taken into account at the publication stage of the Local Plan; therefore the revisions are solely in relation to the requirements of the NPPF.

2.4. The Council has stated that “it is essential that any comments on the revisions now proposed to the Preferred Strategy are supported with relevant evidence. It is not sufficient to object because you disagree with what is proposed, you must demonstrate why your proposed change is soundly based”.

2.5. The National Park Authority will provide an evidence-based response to the consultation in relation to the revised changes to the Local Plan Preferred Strategy based on policy changes considered to be relevant to the National Park. As some responses may be split between Question 1 and Question 2, it is regarded to be more appropriate to respond under the policy headings.

2.6. Amended policy SD1 – Presumption in Favour of Sustainable Development: The Authority recognises that the District Councils’ approach to the consideration of development proposals reflecting the presumption set out in the National Planning Policy Framework. The Authority has no specific comments on this policy.

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2.7. Amended policy SC1 – Hierarchy of Settlements: The addition of two further tiers within the settlement hierarchy, to include primary and secondary villages, is welcomed as it provides more certainty in relation to the development strategy. This was an issue highlighted by the Authority during the previous consultation in 2012.

As previously stated new development will be concentrated in the district’s main centre, Minehead / Alcombe, and in the rural service centres of Watchet and Williton.

Limited development in the primary villages: Bicknoller, Carhampton, Crowcombe, Kilve, Stogumber, Stogursey, West Quantoxhead and Washford.

At the secondary villages: Holford, Dunster Marsh, Old Cleeve, Blue Anchor, Brompton Ralph and Brushford, small scale development to meet clearly identified local needs may be permitted.

2.8. However, the Authority notes that the settlements listed in the hierarchy have been reduced (with the exception of the addition of Blue Anchor) in comparison with the current settlement hierarchy in the adopted West Somerset Local Plan. Settlements such as Huish Champflower, Monksilver, Sampford Brett, Skilgate, Upton and Withycombe are no longer identified and therefore would be prevented from future new-build development to meet any local housing and/or employment needs that may arise to support their viability.

2.9. Of particular consequence are two settlements split by the National Park boundary, Monksilver and Withycombe, which given the findings and recommendations of the Taylor Review1 are both proposed to be identified within the Exmoor National Park Draft Local Plan as settlements, albeit within different tiers of the proposed settlement hierarchy. The Authority considers that a consistent approach in West Somerset and to the part of the district within the National Park is sought in locations where settlements are split by the boundary. This would help to ensure that in taking into account local housing needs and site availability etc, there will be an opportunity to take a holistic approach across the entire settlement in order that the most suitable sites may be considered – whether they are within the National Park or West Somerset local planning authority area.

2.10. The Taylor Review is explicit in the issues it raises for smaller rural communities, and by no longer identifying these settlements for development (i.e. considering them to be unsustainable) they are even more at risk of becoming exclusive communities with existing services in danger of being lost. The provision of small numbers of affordable homes for local people could make a significant difference for these communities2. The NPPF also advocates supporting thriving rural communities within the countryside3.

2.11. Poor access from the county highway network should not constrain low levels of development built solely to meet local needs within these smaller settlements. Development to meet local needs is unlikely to exacerbate traffic levels to exceed the capacity of the local road network; it may help retain employment, social and family connections that may help reduce the need to travel. By not allowing any new-build development to take place this could easily cause local people unable to afford to live there to move away and travel back for work/family reasons4.

1 A Living Working Countryside The Taylor Review of Rural Economy and Affordable Housing (2008) 2 A Living Working Countryside The Taylor Review of Rural Economy and Affordable Housing (2008) Chapter 1 – paragraphs 7, 31 and 32. Chapter 3 – paragraph 1. 3 NPPF (2012) – paragraph 17. 4 A Living Working Countryside The Taylor Review of Rural Economy and Affordable Housing (2008) 

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2.12. Furthermore the limited settlement hierarchy proposed in policy SC1 prevents those communities whose settlements are not identified in the hierarchy from being able to shape their community over the longer term through local decision making processes such as neighbourhood planning. Development would only be permitted in the settlements identified in strategic policies as Neighbourhood Plans should be in general conformity with strategic policies in the Local Plan5.

2.13. The Authority recommends that the Council reconsiders the settlement hierarchy by either reassessing the proposed settlements within the ‘secondary villages’ category of the hierarchy to include Monksilver and Withycombe and other smaller settlements or generate a further category for smaller rural communities6 where only local affordable housing would be permitted based on a rural exception sites7 approach for local affordable housing to ensure that the delivery of affordable housing is maximised in such locations. Either approach would enable development to meet the local needs of these communities over the long term, should such a need arise, and help ensure greater consistency in relation to the policy approach for those settlements split by the National Park boundary.

2.14. It is not clear from the plan if a rural exception site approach to housing in smaller settlements (not identified in the settlement hierarchy) would be considered acceptable.

2.15. It is noted that small scale development for the secondary villages means up to 5 dwellings over the plan period to 2032. The Authority considers such a figure to be arbitrary, even though it is recognised that such a figure is intended to keep the level of overall development to an acceptable level in smaller rural communities, this figure is not based on any indication of overall local affordable need that may arise in the parish or surrounding areas, or whether the settlement has capacity for additional development in terms of landscape and/or other constraints including flood risk and ecological factors. It is suggested that a criteria based approach reflecting local affordable need and the capacity of the settlement to accommodate development in terms of scale and overall character (e.g. as set out in clause 5c of policy SC1), could be utilised to ensure that small scale development of an acceptable level is achieved.

2.16. Policy SC2 Housing Provision – The Authority notes the amended housing target of 2,900 dwellings following the revised Strategic Housing Market Assessment (SHMA) of which half (1450) will be provided on allocated key strategic sites at Minehead/Alcombe, Watchet and Williton.

2.17. Policy SC2A Strategic Development Distribution – Previously the Core Strategy (now Local Plan) was based upon 2,500 dwellings required by the draft Regional Spatial Strategy that presented an average of 125 dwellings per year. The target of 2,900 dwellings presents an average of 145 dwellings per year to 2032 and is intended to take account of cyclical fluctuations within the housing market. In relation to the average of 30 dwellings per year in the primary and secondary villages the Authority would uphold comments made in the 2012 consultation, in that the housing relates to local need with

Chapter 3 – paragraphs 71‐72 and 85‐91. 5 NPPF (2012) – paragraphs 184‐5 6 Huish Champflower, Monksilver, Sampford Brett, Skilgate, Upton and Withycombe 7 NPPF (2012) – paragraph 54: In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. 

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enabling (market) development, a proportion of this total is therefore unlikely to address housing needed locally.

2.18. Policy SC4 Affordable Housing – As there are no longer any development limits for the settlements, the Authority suggests changing ‘around’ in clause 4 to ‘adjoining’ so the sentence reads: “Local needs affordable housing will be considered on sites in and adjoining settlements” or a cross reference to policy SC1 clause 5.

2.19. It is not clear from clause 4 what the term ‘settlements’ refers to – whether it is all the settlements identified in policy SC1, just the primary and secondary villages, or any settlement in the West Somerset local planning authority area. The same applies to the term ‘settlement cluster’ – no further elaboration or examples are given in the supporting text to clarify this terminology. The Authority suggests that it would be helpful if the terminology was clarified within the policy or the supporting text.

2.20. The minimum proportion of affordable housing to market housing has changed from 1:3 to 35%:65% (approximately 1:2) – including within the smaller identified settlements. The Authority recognises that this ratio improves the proportion of affordable housing delivered within a scheme. However, this approach could still exacerbate the issue of delivering affordable housing to meet local needs given the restriction of 5 dwellings in secondary villages over the plan term.

2.21. Furthermore the threshold applied to the provision of smaller settlements outside Minehead/Alcombe, Watchet and Williton has been revised with the option selected for 3 or more dwellings rather than the option for 1 or more dwellings. The policy approach could therefore mean that more market homes are delivered than local need which would contradict the aim of policy SC1 clause 3 where small scale development should meet “clearly identified local needs”. Within these smaller settlements the delivery of affordable homes could be maximised on an exception site basis8 as previously stated. The Council may wish to consider an approach which ensures that the number of affordable homes should exceed the number of market homes would be more suitable in these locations to help meet the aims of policy SC1 clause 3.

2.22. Policy MD1 Minehead Development – the Authority supports the changes to the policy to ensure that criteria are inclusive rather than potentially exclusive. It is suggested for the purposes of clarification to include reference to the National Park within the written justification within the following sentence: “...and the high quality landscape of Exmoor National Park which surrounds the town to the north, west and south.”

2.23. Polices MD2 and LT1 – key strategic sites at Minehead/Alcombe: The key strategic development site allocations at Minehead, LT1 and MD2 lie adjacent to one another south of Periton Road (A39), and in close proximity to the National Park boundary, with the western boundary of LT1 directly adjoining the boundary (See Fig 2: Minehead/Alcombe key strategic sites in Appendix 1). These sites are expected to accommodate 760 dwellings over the plan period (38 dwellings per year over 20 years) of which 750 and 3 hectares of employment land is allocated for site MD2. No specific allocation of housing or employment has been identified for site LT2 as it is for longer term strategic development (post 2026).

2.24. Whilst recognising the significance of Minehead/Alcombe as a strategic service centre for West Somerset, and the constraints Minehead/Alcombe faces in terms of suitable sites

8 NPPF (2012) paragraph 54

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for new development, the Authority is concerned that the allocation of these strategic sites may have adverse impacts on the National Park designation and its purposes.

2.25. The Authority considers that the Sustainability Appraisal (SA) and Proposed Amendments to the Draft Preferred Strategy in Response to the Habitat Regulations Assessment of the Plan9 should have been made publicly available during this consultation as these documents provide further detail regarding the allocation of the key strategic sites MD2 and LT1 in terms of their environmental, economic and social sustainability and whether they meet the SEA Directive and the Habitats Directive.

2.26. Figure 8 of the appendix shows the bat consultation area for the local authority planning area and the revised section of the written justification for Policy MD2 refers to ‘Plan 1’ for biodiversity offsetting within areas of search, however this plan appears to be only available in a document from last year’s consultation. The areas of search A4, A5 and A6 are broader locations between the A39 (Periton Road) and the National Park boundary that include sites MD2 and LT1 up to the development limit highlighted (see Appendix 2 to this report).

2.27. The HRA for the previous Local Plan Preferred Strategy consultation in 2012 stated that “Overall it is considered that a significant effect cannot be ruled out on loss or degradation of commuting and / or feeding habitat used by barbastelle bats as a result of policies in the Local Plan prior to counter-acting measures being applied”10. The written justification states that the biodiversity issues identified in the HRA can be addressed through detailed design schemes.

2.28. For avoidance of doubt, the Authority suggests that the policy should include a specific test in relation to avoiding likely significant effects on the Exmoor & Quantock Oak Woodlands SAC through detailed design schemes and appropriate offsetting measures.

2.29. The NPPF states that “great weight should be given to conserving the landscape and scenic beauty in National Parks...which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas, and should be given great weight in National Parks and the Broads”11. Additionally the Environment Act 1995 Section 62 11A confers a duty on certain bodies and persons to have regard to the purposes for which National Parks are designated12. The written justification for policy MD2 cites that the allocated area is unconstrained by landscape designations, and does not make any specific reference to the close proximity of the National Park and potential impacts any development on this site may have on its setting.

2.30. The guidance note relating to the section 62 duty published by Defra13 clearly states their expectations of relevant authorities to include that “it may sometimes be the case that the

9 http://www.westsomersetonline.gov.uk/getattachment/Planning---Building/Planning-Policy/Closed-Consultations/Local-Plan-to-2032-Preferred-Strategy-Consultation/HRA-mitigating-policy-amendments-Jan-2012.pdf.aspx 10 Paragraph 5.20 of the HRA in relation to policy MD2 (strategic sites at Minehead) in the 2012 West Somerset Local Plan Preferred Strategy 11 NPPF (2012) – paragraph 115 12 In exercising or performing any functions in relation to, or affecting land in a National Park, relevant authorities should have regard to National Park purposes. Under the Act a ‘relevant authority’ includes any public body and this includes any local authority. 13 Duties on relevant authorities to have regard to the purposes of National Parks, Areas of Outstanding Natural Beauty (AONBs) and the Norfolk and Suffolk Broads Guidance note (DEFRA 2005)

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activities of certain authorities operating outside the boundaries of these areas may have an impact within them. In such cases, relevant authorities will also be expected to have regard to the purposes of these areas”. In such cases it is expected that the relevant authority are able to demonstrate how they have considered the purposes of the National Park in decision making, or in this case plan making. A number of ways are suggested including undertaking and making publicly available an assessment of the impact on the National Park and showing how decisions affecting these areas have been properly considered and recorded in high level policy documents and public statements.

2.31. The HRA analysis for strategic housing sites at Minehead in the last consultation highlighted specific likely significant effects on the SAC. It is assumed that the location of the strategic sites has had regard to the HRA findings as set out in the Proposed Amendments to the Draft Preferred Strategy in Response to the Habitat Regulations Assessment of the Plan (made available during the previous consultation). However, it is considered that addressing the HRA findings alone would not be sufficient to demonstrate that there will not be an adverse impact on the National Park particularly in terms of landscape harm – i.e. the development limit imposed by the HRA with regard to reducing the likely significant effect on barbastelle bats (see Appendix 2) does not necessarily also minimise other potential adverse impacts on the National Park.

2.32. The SA Non-Technical Summary14 (made available during the previous consultation) noted that:

“For development in the strategic development areas and employment sites several mitigation measures will be needed before development goes ahead including measures to reduce noise, provide ecological assessments, measures to improve drainage and reduce the risk of flooding, the provision of adequate community services, improvement of public transport and landscape appraisals (especially for development in areas of Minehead that may bring development closer to Exmoor National Park)[our emphasis].”

2.33. The Authority considers that the SA findings to the previous consultation have only been partially addressed through the insertion of a design policy. The assessment of the site allocations would have been more robust if the impact of sites MD2 and LT1 on the National Park was assessed prior to the allocation and mitigation measures introduced in the Local Plan (Revised Preferred Strategy).

2.34. In terms of the Authority’s consultation response and in relation to the duty to co-operate15 the Authority would suggest that the impact of the key strategic housing sites LT1 and MD2 on the National Park is objectively assessed in relation to the points raised in paragraph 2.30 above and that any decision is properly considered and recorded in the publication version of the West Somerset Local Plan; including any relevant policy amendments. This is a precautionary approach as it considered that there is not enough evidence publicly available, to be able to demonstrate that there will not be an adverse impact on the National Park.

2.35. Policy SV1 Development at Primary and Secondary Villages – the Authority notes the specific reference to primary and secondary villages in the amended policy and supports the addition of the first clause in relation to design – it is suggested that this clause

14 http://www.westsomersetonline.gov.uk/getattachment/Planning---Building/Planning-Policy/Closed-Consultations/Local-Plan-to-2032-Preferred-Strategy-Consultation/Sustainability-Appraisal-non-technical-summary-Feb-2012.pdf.aspx 15 Localism Act 2011 and NPPF

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directly cross refers to the design policy. The written justification does not reflect the approach set out in policy SC2 in relation to small scale development for the secondary villages and the Authority reiterates the comments made in relation to this point (see para 2.21 above).

2.36. Policy TR1 Access to and From West Somerset – the Authority supports the insertion of the requirement of a green transport plan for larger development proposals, but would suggest that this term is qualified in the text with regard to paragraph 32 of the NPPF “all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment” [our emphasis].

2.37. Policy NH1 Historic Environment – the Authority supports the insertion of the designated heritage assets Registered Parks and Gardens and Scheduled Ancient Monuments in the written justification including undesignated heritage assets of high importance; however we would reiterate that listed buildings (designated heritage assets) should also be included in the list. The Council may also wish to consider whether a description of the Historic Environment Record in the written justification could be a helpful source of information for future applicants.

2.38. Policy NH10 Securing High Standards of Design – the Authority supports the addition of a design policy in the Local Plan given the Government’s continued focus on the importance of high quality design in the NPPF. Specifically the Authority welcomes the positive aims of sustainable design which responds to the local context and potential links to neighbourhood planning and the establishment of local design standards.

2.39. Whilst ‘By Design’ is an important reference for urban design principles, the Authority suggests that for larger developments/redevelopments, including on the allocated sites, the principles of Building for Life 12 could be endorsed by the Council in the Local Plan to ensure that developers of new housing developments, local communities and West Somerset Council consider 12 questions to help achieve well-designed homes and neighbourhoods.

2.40. Furthermore, the Authority notes that the policy requires all new development should include a landscape framework to enhance both the natural and built environment. This aspect of the policy is supported, however there is no explanation in the written justification regarding what the landscape framework should encompass or consider. The Authority recommends that ‘landscape framework’ should be clarified in the written justification to include terms which are more recognisable to planning agents such as landscape and visual impact appraisals / assessments, landscape design, landscape management and master-planning.

2.41. Within this context the Authority would also recommend that reference to the Exmoor National Park Dark Sky Reserve16 is made and for the policy to encourage effective and efficient lighting design/management to reduce light pollution/spillage and therefore contribute towards the conservation and enhancement of Exmoor’s dark night sky.

3. CONCLUSION

3.1. In summary the National Park Authority welcomes the opportunity to comment on the revised changes to the West Somerset Local Plan Preferred Strategy in light of changes required by the NPPF. The Authority is particularly supportive of the insertion of the design policy which was a matter raised in the previous consultation response.

16 http://www.exmoor‐nationalpark.gov.uk/environment/landscape/dark‐skies  

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3.2. The key issues raised through the response are:

The contraction of the settlement hierarchy that no longer identifies the villages of Monksilver and Withycombe as settlements where new development would be acceptable. This presents an inconsistent policy approach across the boundary for these settlements (both of which are proposed to be included within the Draft Local Plan for Exmoor National Park) and fails to provide an opportunity for these settlements to be considered as a whole for the provision of development to meet local needs.

The impact of the allocated sites MD2 and LT1 at Minehead on the National Park should be objectively assessed and recorded as evidence to inform the Local Plan Publication version.

3.3. The Authority would welcome further discussion with West Somerset Council on these issues, including under the duty to cooperate.

Tessa Saunders Planning Policy Officer 3 September 2013

Background papers on which this report, or an important part of it are based, constitute the list of background papers required by Section 100 D (1) of the Local Government Act 1972 to be open to members of the public comprise:

The West Somerset Local Plan to 2032 – Revised Draft Preferred Strategy National Planning Policy Framework 2012 EXMOOR NATIONAL PARK AUTHORITY PLANNING COMMITTEE 1 May 2012: ITEM 8 – WEST SOMERSET LOCAL PLAN 2012 TO 2032 – DRAFT PREFERREDSTRATEGY CONSULTATION http://www.exmoor-nationalpark.gov.uk/about-us/meetings-agendas-reports/enpa-planning-committee/01-may-2012/ar-epc-01.05.12-Item-8.pdf West Somerset Local Plan (adopted 2006) A Living Working Countryside (The Taylor Report 2008)

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Appendix 1: Minehead/Alcombe key strategic sites

Appendix 2: Areas of Search A4, A5 and A6 showing development limit (dashed green line)

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