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ITEM 6 EXMOOR NATIONAL PARK AUTHORITY PLANNING COMMITTEE 7 October 2008 THE DRAFT REGIONAL SPATIAL STRATEGY FOR THE SOUTH WEST INCORPORATING THE SECRETARY OF STATE’S PROPOSED CHANGES - CONSULTATION RESPONSE Report of the Head of Planning & Community Purpose of Report: To seek approval of a response to consultation on the Proposed Changes to the Regional Spatial Strategy. Business Plan Reference: National Park Purposes: The Regional Spatial Strategy, as part of the development plan and because all local development documents must be in general conformity with it, will be a key policy tool in guiding land use and development to ensure it is appropriate in the context of National Park purposes. Legal and Equality Implications: Section 65(4) Environment Act 1995 – provides powers to the National Park Authority to “do anything which in the opinion of the Authority, is calculated to facilitate, or is conducive or incidental to- (a) the accomplishment of the purposes mentioned in s. 65 (1) [National Park purposes] (b) the carrying out of any functions conferred on it by virtue of any other enactment.” The Regional Spatial Strategy will, once adopted, become part of the development plan for Exmoor National Park under the Town & Country Planning Act 1990 and the Planning and Compulsory Purchase Act 2004. The Authority has no obligation to respond to this consultation, but as an ‘all purpose planning authority’ (formerly with structure planning powers) it does have a special status in providing advice to the Regional Planning Body (in this case the South West Regional Assembly) under Section 4/4 of the 2004 Act. Local development documents in the Exmoor National Park Local Development Framework are required by the 2004 Act to be in general conformity with the adopted Regional Spatial Strategy. Financial and Risk Implications: The cost of involvement in the Regional Spatial Strategy is provided for as part of the normal budgeting process.

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RECOMMENDATION: The Committee is recommended to: 1. AGREE the recommended responses to consultation on the Draft Revised Regional Spatial Strategy Incorporating the Secretary of State’s Proposed Changes; 2. DELEGATE to the National Park Officer authority to make minor revisions and elaborations to the consultation response before submission.

____________________________________________________ 1. INTRODUCTION

1.1. The Regional Spatial Strategy (RSS) will replace the majority of policies within Somerset and Exmoor National Park Joint Structure Plan Review 1991-2011 (and all other structure plans in the region), and also RPG10: Regional Planning Guidance for the South West (which has temporary RSS status under transitional arrangements).

1.2. The RSS will form part of the Development Plan, and therefore will guide the determination of planning applications. In addition, local development documents such as the Core Strategy of the Exmoor National Park Local Development Framework must be in general conformity with the policies set out in the RSS.

1.3. The South West Regional Assembly (SWRA) submitted the draft Regional Spatial Strategy (RSS) for the South West 2006-2026 to the Government during June 2006.

1.4. Comments on the draft RSS were considered by an independent Panel conducting an ‘Examination in Public’ (EiP) of the RSS from April to July 2007. Following the completion of the EiP, the Panel considered all of the evidence on the various matters tabled for discussion. The report of the Panel was submitted to the Secretary of State for Communities and Local Government in December 2007 and published, for information only, in January 2008.

1.5. The Secretary of State, having considered the recommendations of the EiP Panel Report, published the Proposed Changes to the draft RSS for comment on 22nd July 2008. The consultation period for the Proposed Changes ends on the 24th October. The Proposed Changes are accompanied by a schedule of reasons for all Changes and their relationship to the Panel recommendations.

2. BACKGROUND

The National Park Authority (NPA) has been involved with the development of the RSS to its present point. The housing figures for Exmoor in the RSS, for instance, directly reflect the formal advice (known as ‘First Detailed Proposals’) of the Authority and Members have been involved in meetings, workshops and correspondence with the SWRA to ensure that the Exmoor National Park’s interests are protected as far as possible.

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2.1. In these endeavours the Authority has often worked in concert with Dartmoor National Park, and with the South West Protected Landscapes Forum (representing the SW National Parks and AONBs).

2.2. At the end of August 2006, a formal response to the submission version of the draft RSS was submitted by the NPA and further endorsed the response of the South West Protected Landscapes Forum. Officers also attended three matters at the EiP in order to give evidence, regarding the Taunton Housing Market Area, Polycentric Devon and Cornwall Housing Market Area, and Energy and Renewable Targets.

2.3. The Authority is now invited to respond to the Secretary of State Proposed Changes to the draft RSS. Any comments must be made to the Proposed Changes only. It is not normally appropriate to revisit issues which have already been dealt with by the Panel following open debate at the EiP and have subsequently been accepted in the Proposed Changes. The associated documents are available to view online at : http://www.gos.gov.uk/gosw/planninghome/691545/713860/

3. EXMOOR NATIONAL PARK AUTHORITY RESPONSE TO THE

CONSULTATION ON THE DRAFT REGIONAL SPATIAL STRATEGY FOR THE SOUTH WEST INCORPORATING THE SECRETARY OF STATE’S PROPOSED CHANGES 3.1. SECTION 1 – A SUSTIANABLE FUTURE FOR THE SOUTH

WEST: This first section of the draft RSS Proposed Changes promotes sustainable development at the forefront of the strategy and growth for the region. This section includes four policies to guide sustainable development within the region; the Panel Report previously recommended that no change was made to policies SD1 – SD4. 3.1.1. The Proposed Changes have significantly modified policies

SD1 and SD2 which has weakened the policy framework for achieving sustainable development and reflects further changes made to subsequent policies and supporting text.

3.1.2. SD1 The Ecological Footprint: The Authority suggests that the proposed changes to this policy in bullet points 1 and 4, have weakened the aims of the policy which previously would have ensured greater effort to stabilise and eventually reduce the regions ecological footprint through more detailed plans and policies at a local level. It suggests that ‘requiring’ sustainable construction should be reinstated rather than ‘encouraging’

3.1.3. The Authority however supports the changes made to bullet point 5 of the policy where the shift to more sustainable modes of travel are applied to the Strategically Significant Cities and Towns (SSCTs) as the focus of the greatest proportion of housing growth. It was a previous concern of

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the Authority that linking new development to public transport could result in a blanket ban on development particularly that to meet local needs without access to public transport - many rural areas do not have access to good quality public transport facilities and are dependent on the need to travel by private car.

3.1.4. SD2 Climate Change: The Authority suggests that the Panel Report recommendation of ‘no change’ to this policy was the correct approach. It is suggested that it is helpful to refer to longer term reductions but note that the proposed changes to this policy have deleted the requirement for Local Authorities to demonstrate in their policies and plans how they will contribute towards a 60% reduction in CO2 emissions by 2050. The Secretary of State considers it to be unreasonable to expect LDDs to demonstrate how they would directly contribute to meeting a target beyond their timescale. We suggest that given the threat that climate change presents that the policy should require LDDs to look to how longer term reductions of 60% by 2050 are best achieved to enable actions towards those targets to be set in train in the RSS period to 2026.

3.1.5. One of the main challenges of the National Park Management Plan 2007-12 (NPMP) is responding to climate change through becoming a carbon neutral National Park. The National Park has a key role in demonstrating approaches to help mitigate climate change by reducing dependence on fossil fuels and minimising the local ‘carbon footprint’ in ways that do not irreparably damage the Exmoor National Park landscape and the experience of tranquillity. (NPMP)

3.1.6. It is important that other authorities also demonstrate how they will reduce CO2 emissions by 60% by 2050 not only as a global challenge but also a locally important challenge as climate change threatens the vulnerable habitats that represent some of the South West’s most characteristic landscapes.

3.1.7. Policy SD3 – The Environment and Natural Resources: The Authority supports Policy SD3 as unchanged.

3.2. SECTION 2 – CONTEXT FOR THE SPATIAL STRATEGY: This section has been entirely deleted within the Proposed Changes; this was not a Panel Recommendation. The Panel Report stated that although this section did not contain policies it “…contributes significantly to setting the scene and developing the big picture for the policy approach, policies and their implementation” (para .21). 3.2.1. The deletion of this section therefore removes a significant

area representing regional identity and an understanding of regional issues such as: the quality of environmental assets;

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expected population and economic change and the implications of this change; and the role and function of places.

3.2.2. The Authority suggests that section 2 should be reinstated to accord with the Panel Report recommendation.

3.3. SECTION 3 - THE SPATIAL STRATEGY AND POLICIES FOR THE SCALE AND LOCATION OF DEVELOPMENT: The Proposed Changes have made some significant alterations to this section which sets out the main policies which guide development in the South West. 3.3.1. Policy CSS – The Core Spatial Strategy: The Authority

suggests that the inclusion of this policy in the RSS should incorporate the Panel Report recommendations for this policy which refers to the spatial disparities of the east and west of the region.

3.3.2. The policy as set out in the Proposed Changes does appear to seek a sustainable approach in order to respond to and manage the development needs of the region, including the requirement to enhance economic prosperity ‘within environmental limits’ and the accommodation and management of growth ‘in the most sustainable way’. However, it is not clear whether the level or indeed any increase in growth can be accommodated sustainably and how the level of growth required will impact on the environment of the region. The policy is considered to be generic and lacking any regional specificity or identity.

3.3.3. The Authority considers that the Panel’s recommendation that the emphasis of ’creating a better local environment’ with balanced communities within smaller settlements should be included in the policy’. This approach is consistent with the objectives and vision for Exmoor’s economy and communities within the National Park Management Plan.

3.3.4. The Authority therefore supports the Panel Report recommendation for this policy and the replacement of the spatial strategy diagram 3.1 which clearly illustrates the policy.

3.3.5. Development Policy C – Development at Small Towns and Villages: This development policy is directly relevant to the settlements within Exmoor National Park. The Authority does not support the modifications to the policy as set out in the Proposed Changes. The policy has been extensively edited which significantly reduces the sustainability requirements of the policy; this has been highlighted in the accompanying Sustainability Appraisal. For example, the Authority particularly supports the aim of greater self-containment and stronger local communities as set out in

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the original working of the policy (and carried through to the Proposed Changes). It should retain the additional aim of supporting key services. The Authority supports the aim of extending the range of services available ‘to better meet the needs of the settlement and its surrounding area’. We object to the loss of ‘making use of existing premises’ and would suggest the addition of ‘where these make a positive contribution to the area’

3.3.6. The Authority supports the original wording of the policy as set out in the Submission Draft RSS; promoting sustainable outcomes that complement the vision and objectives set out in the National Park Management Plan for Exmoor’s economy and communities.

3.3.7. DEVELOPMENT POLICY G – SUSTAINABLE CONSTRUCTION: The Proposed Changes have removed the region-wide sustainable construction requirement from the policy in order to allow Local Planning Authorities (LPAs) to promote best practice in achieving sustainable construction and help achieve the national timetable for reducing carbon emissions from new or refurbished buildings. The revised policy has flexibility in allowing some LPAs to adopt higher sustainability standards (where local circumstances which warrant and allow this are clearly demonstrated) in advance of the Government commitment to achieve zero-carbon development by 2016.

3.3.8. The Authority does not support the revision to Policy G within the Proposed Changes and agrees with the Sustainability Appraisal findings that it merely repeats national policy. The Authority supports the principle of sustainable construction and suggests that the Panel Recommendation for Policy G (see Appendix 1) to ensure a consistent region-wide approach to sustainable construction is instated.

3.3.9. It is already a requirement of Housing Corporation funding that housing built by Registered Social Landlords (RSLs) meets the sustainable construction standard of Level 3 in the Code for Sustainable Homes. Therefore local affordable dwellings provided by RSLs and requiring Housing Corporation funding will meet this level of sustainable construction.

3.3.10. With regard to the Habitats Regulations Assessment the Authority supports the suggestion that the supporting text should include reference to the sensitivity of water resource zones (such as the Roadford Zone). There is some uncertainty as to whether the increased housing requirement with the associated increased water supply and abstraction within the Polycentric Devon and Cornwall HMA and Barnstaple SSCT, and the Taunton HMA and SSCT, will adversely impact the SACs within the Exmoor National

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Park (Exmoor Heaths SAC and Exmoor & Quantock Oakwoods SAC). The precautionary principle should be applied in these water sensitive zones to ensure water efficiency measures are applied to the significant housing numbers within these HMAs.

3.4. SECTION 4 – SUB-REGIONAL POLICIES AND HOUSING DISTRIBUTION: This section within the Proposed Changes completely replaces chapter 4 of the draft RSS; this follows the Panel Recommendation that section 4 should be restructured on the basis of the Housing Market Areas within the region. 3.4.1. It should be noted that there is a marked increase in

housing numbers from the Submission Draft RSS to the Panel Report due to implications of the 2003 Based DCLG Sub National Household Projections for the region and an assumption of economic growth at 2.8 % per annum.

3.4.2. However the Proposed Changes are based upon additional household growth predicted in the revised 2004 household projections (plus assumed economic growth of 3.2% p.a.); this additional growth has been mainly directed to the West of England HMA, Exeter HMA and Plymouth HMA.

3.4.3. The housing figures for the total period 2006-2026 for those HMAs and districts which may have implications for the National Park, are outlined in the Table 1 below:

Table 1: Overall net dwelling requirement: RSS PERIOD 2006-2026

Difference between draft RSS and

Proposed Changes

Difference between Panel Report and

Proposed Changes AREA Draft

RSS EIP

Panel Report

Proposed Changes

No. % No. % South West 461,200 569,450 592,460 131,260 28.5 23,010 4.0 Taunton HMA 27,900 34,500 34,500 6,600 23.7 0 0.0 Taunton Deane 17,300 21,800 21,800 4,500 26.0 0 0.0 Sedgemoor 8,400 10,200 10,200 1,800 21.4 0 0.0 West Somerset 2,200 2,500 2,500 300 13.6 0 0.0 Polycentric Devon & Cornwall HMA 20,500 35,000 35,000 14,500 70.7 0 0.0

North Cornwall 7,600 13,400 13,400 5,800 76.3 0 0.0 Torridge 4,800 10,700 10,700 5,900 122.9 0 0.0 North Devon 8,100 10,900 10,900 10,900 34.6 0 0.0 Exmoor National Park 400 400 400 0 0.0 0 0.0

Mid Devon 6,400 7,400 7,400 1000 15.6 0 0.0 (adapted from South West Regional Assembly Regional Planning Forum Paper B appendix 1 – 11th September 2008)

3.4.4. POLICY HMA6 – TAUNTON HMA: The Authority supports the principle of this policy to concentrate housing and employment growth at the two main SSCTs (Strategically Significant Cities and Towns) of Taunton and Bridgwater. Taunton in particular is a main service centre for retail,

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leisure and employment for some communities within the National Park.

3.4.5. However we should guard against the potential impacts of this proposed growth upon the National Park.

♦ Possible out-migration to Taunton and increased unsustainable travel out of the National Park.

♦ Increasing environmental impacts upon the special qualities of the National Park with a rising local population utilising the National Park as a recreation/leisure base.

♦ Potential impacts upon the Special Areas of Conservation (SACs) as highlighted in the Habitats Regulations Assessment. o Water supply to new homes in the Taunton HMA may

have adverse effects upon the Exmoor Heaths SAC and Exmoor & Quantock Oakwoods SAC and would therefore warrant more stringent water efficiency standards (HRA para 3.12)

o Increased tourism such as day trips into the National Park could cause increased levels of local air pollution which may have an adverse effect by increasing acid deposition levels on the Exmoor Heaths SAC (HRA Appendix 2).

3.4.6. We are very concerned about the housing requirement for West Somerset. Although this figure is relatively low compared to the other districts within the Taunton HMA; 2,500 dwellings is a significant number to be concentrated in the area of West Somerset outside the National Park.

3.4.7. Any concentration of the housing requirement on greenfield sites at Minehead could have negative impacts upon the setting of the National Park. This is because development land is severely constrained in Minehead with the National Park boundary on two sides and the sea on another. There could be pressure to develop towards the National Park boundary which would adversely affect the landscape of the National Park and impact upon tranquility and sense of remoteness that are noted as special qualities in the National Park Management Plan.

3.4.8. Emerging work on the HMA shows the level of need for affordable housing to be extremely high in West Somerset. It appears that the shortage of land around Minehead means that to find sites to meet the need for affordable housing, using the cross subsidy route where sites will also be taken up by open market housing, is likely to lead to conflicts in ensuring the National Park’s special qualities are not adversely affected.

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3.4.9. POLICY HMA10 - POLYCENTRIC DEVON & CORNWALL HMA (Northern Peninsula HMA): The level of housing requirement increase in this HMA is considerable at 35,000 over 20 years (70.7% above that recommended in the draft RSS): the majority of which will be dispersed amongst Policy B (Coastal & Market Towns) and Policy C (Small Towns & Villages) settlements within the HMA. Within and around Barnstaple SSCT (the only SSCT within this HMA) there will be 7,200 dwellings from 2006-2026.

3.4.10. The ratio of employment provision to housing is lower than that already experienced; this is due evidence of this area being attractive to in-migration by non-economic migrants, such as retirees to the area and second home owners. This is a particular concern in its own right in planning for adequate infrastructure for an ageing population demographic.

3.4.11. The rise in the North Devon housing requirement is not as severe as that for both Torridge and North Cornwall. However, there are concerns with this level of growth and should guard against potential social, economic and environmental impacts within the National Park. It is not clear how sustainable such levels of growth are e.g. in terms of transport routes where areas proposed for large increases in housing numbers are not always close to railway links.

♦ Possible out-migration for employment opportunities within Barnstaple and increased unsustainable commuting out of the National Park.

♦ Increasing environmental impacts upon the special qualities of the National Park with a rising local population utilising the National Park as a recreation/leisure base.

♦ Potential impacts upon the Special Areas of Conservation (SACs) should also be considered and planned for as highlighted in the Habitats Regulations Assessment. o Water supply to new homes in the Northern

Peninsula HMA are considered likely to have adverse effects upon the Exmoor Heaths SAC and Exmoor & Quantock Oakwoods SAC and would therefore warrant more stringent water efficiency standards (HRA para 3.12).

o Increased tourism such as day trips into the National Park could cause increased levels of local air pollution which may have an adverse effect by increasing acid deposition levels on the Exmoor Heaths SAC which are already

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vulnerable to acid deposition recorded at 6 times the critical load (HRA Appendix 2).

3.4.12. POLICY HD1 – SUB-REGIONAL DISTRIBUTION OF HOUSING 2006-2026: MANAGING AND SHAPING UP SUPPLY: The Authority is concerned with the wording and approach of this policy, namely “the flexible approach to delivery by not treating housing figures as ceilings…”. This approach is considered unsustainable to deep rural areas such as National Parks and AONBs where the challenges lie in creating balanced, sustainable communities with local employment opportunities.

3.4.13. The Authority welcomes continued identification of housing provision for Exmoor National Park as ‘estimates of provision against strictly local needs only’ (Proposed Changes para 4.1.88). However, the Authority do have some concerns; see comments below:

3.4.14. The Authority supports the identification of an estimated housing figure for Exmoor National Park within Table 4.1 set out as 400 during the RSS period 2006-2026 or 20 dwellings per annum. It is noted however that a footnote denoting those housing figures based on ‘estimated strictly local needs provision only’ is not included in Table 4.1. The Authority strongly requests that, in addition to para 4.1.88, a footnote is reinstated for those housing figures representing National Parks and the Isles of Scilly as previously set out in Table 4.1 of the draft RSS and Panel Recommendations. This should state “Estimated strictly local needs provision only”. The West Somerset and North Devon housing provision figures need to have their footnote reinstated as per that set out in the draft RSS to state “excludes part in Exmoor National Park”.

3.4.15. It is important that the use of ‘estimated’ housing figure is stated in the supporting text of Policy HD1 and in Table 4.1, as this is the likely scale of development envisaged for the National Park, as delivery will be against a more local and time specific identification of local affordable housing need. This identification is made through a National Park wide survey of housing need and supplemented by a rolling programme of parish based housing need surveys to ensure figures are updated. Policy HD1 should include a clause in recognition of the National Parks requirement to provide for “an estimate of strictly local needs”. This needs to state that the National Park Authority’s requirements for the management and release of land should be undertaken in a manner appropriate to the level of need and the means of delivery. This is in recognition of the fact that RSLs do not tend to purchase rural exception sites until permission is granted. More appropriate means of bringing forward land

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for development of local needs housing can be achieved through e.g. the work of Rural Housing Enablers.

3.4.16. Following the Authority response to the Examination in Public (EiP) of the Gypsy and Traveller policy; the Authority supports the provision of zero residential pitch requirements and zero transit pitch requirements as set out in Table 4.3.

3.4.17. Key Diagram Inset 10 Polycentric Devon & Cornwall HMA: The inset map for Polycentric Devon & Cornwall HMA does not show Exmoor National Park. The Authority suggests that key diagram inset map 10 is amended to show the entire area of Exmoor National Park within the HMA area since all of the area has been included, together with West Somerset in its scope. It is significant that the Dartmoor National Park area is clearly shown in key diagram inset map 4 for Exeter HMA.

3.4.18. The inset maps would benefit from some reworking as they presently lack very little spatial detail apart from main settlements and the primary route network, and the text is far too small to be clearly legible.

3.5. SECTION 5 – REGIONAL APPROACH TO TRANSPORT: The Authority generally accepts the revision of this section of the RSS Proposed Changes following Panel recommendations that it should be rewritten as an identifiable Regional Transport Strategy as set out in PPS111. There are some concerns however, which are set out below. 3.5.1. RTS4 – FREIGHT AND THE PRIMARY ROUTE

NETWORK: The Authority suggests that the Regional Freight Map 5.1 is reinserted into the RSS to ensure that those HGV routes illustrated on the map such as the B3223/B3224 route across Exmoor National Park are incorporated into the RSS. The Regional Freight Map 5.1 has been deleted in the Proposed Changes with a focus on the Primary Route Network as the main routes promoted for freight.

3.5.2. The B3223/3224 east-west route across Exmoor National Park is an important freight route in this area of the region due to the inaccessibility of other routes within the National Park; providing an essential freight link for settlements between Taunton and North Devon.

3.5.3. RTS6 – AIRPORTS AND HELIPORTS: The Authority particularly welcomes the proposed changes to regional policy regarding development at existing airports; taking into account the wider environmental implications of airport development. The supporting text has particular reference to vulnerable Natura 2000 sites (N2K) and further states

1 Planning Policy Statement 11: Regional Spatial Strategies

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that: “consideration to minimising any impacts resulting from construction and operation including air quality, loss or harm to biodiversity (e.g. flight paths of birds and bats), landscape and visual impact, atmospheric emissions, noise, odour, water pollution, flood risk, and the disposal of waste” (para 5.1.36).

3.6. SECTION 6 – HARNESSING THE BENEFITS OF POPULATION GROWTH AND MANAGING THE IMPLICATIONS OF POPULATION CHANGE: this section broadly relates to the RSS policies on affordable housing, housing density and associated infrastructure provision. The Authority broadly accepts the approach of the policies in this section: the comments below reflect some concerns within the supporting text and policies. 3.6.1. Para 6.2.4: The Authority suggests that the Proposed

Changes should note that National Park Authorities do not directly prepare Sustainable Community Strategies (although they have regard to and input into the SCS of district authorities within the National Park). The relevance of National Park Management Plans should be included as also playing a vital role at the local level in seeking to ensure sustainable development.

3.6.2. POLICY CS1 – PROVISION OF SERVICES AND COMMUNITY INFRASTRUCTURE: The Authority recommends that the sentence deleted sentence “Service providers need to ensure that all provision meets uniformly high standards to minimise the number of users who would wish to choose any other than the closest provider” should be replaced with “in rural areas LPAs should seek to protect existing community services and facilities including those for education and healthcare, to ensure that communities retain access to a range of services and facilities enabling them to retain balanced communities and to reduce the need to travel”

3.6.3. The Authority supports the insertion of new supporting text regarding the Habitats Regulations Assessment on page 162. The Authority suggest that additional text is inserted within the second paragraph:

“If following investigation of mitigation options, it is not certain that the impacts of the development, including of recreational pressure, will not have an adverse impact on the international nature conservation site then restrictions will may need to be put in place on the type, scale and/or location of development (e.g. through ‘no development buffer zones)…”

Furthermore the list of sites vulnerable to recreation pressure is not exhaustive and additional work may mean other sites are also at risk. There is a risk of uncertainty

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over development proceeding given the high numbers of housing proposed for areas with international sites close by.

3.6.4. POLICY GI1 – GREEN INFRASTRUCTURE: The Authority supports the proposed changes to Policy GI1 particularly:

♦ the identification, development and management of new areas not just intensification of existing areas.

♦ ensuring that a key aim is the maintenance and improvement of biodiversity; and

♦ protecting the integrity of international sites and providing new areas where development would otherwise cause unacceptable recreational pressure.

3.7. SECTION 7: ENHANCING DISTINCTIVE ENVIRONMENTS AND CULTURAL LIFE: This section is particularly relevant to the National Park statutory purposes and the aims and objectives within the National Park Management Plan and the Authority is broadly supportive of the proposed changes. Comments on this section are outlined below. 3.7.1. New supporting text - pages 170-171: The Authority

supports the insertion of text regarding Natura 2000 sites (SACs [Special Areas of Conservation] and SPAs [Special Protection Areas]) prior to policy ENV1. The Authority proposes that the Exmoor & Quantock Oakwoods SAC should be added to the list to reflect the important bat roosts in Horner and Hawkcombe Woods and wider foraging areas.

3.7.2. ENV1 – PROTECTING AND ENHANCING THE REGION’S NATURAL AND HISTORIC ENVIRONMENT: The new wording included at the end of this policy needs to clarify that any sites for proposed development which could have an adverse effect on site integrity should not be proposed in a LDD: it would not be certain that such sites could be delivered.

3.7.3. Policies ENV2 – ENV5 were not considered at the Examination in Public and therefore no recommendations were made for any subsequent modifications to these policies – this has been upheld by the Proposed Changes. The Authority therefore supports and welcomes this decision particularly regarding ENV3 Protected Landscapes which incorporate the statutory purposes of the National Parks and ensures that the purposes have status in the Development Plan.

♦ ENV2 – Landscape Character Areas

♦ ENV3 – Protected Landscapes

♦ ENV4 – Nature Conservation

♦ ENV5 – The Historic Environment

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3.7.4. RE1 – RENEWABLE ENERGY TARGETS: 2010 AND 2020: The Authority suggests that the policy or supporting text should include reference regarding the need to seek technologies at an appropriate scale to ensure that renewable energy development outside National Parks does not adversely affect their special qualities – e.g. micro-renewable technology may provide for renewable electricity more appropriately than large scale highly visible technologies including wind farms visible from National Parks.

3.7.5. Policy RE4 does retain its reference to cumulative negative impacts of renewable energy schemes and proposals within protected areas should be of an appropriate scale so as not to compromise the objectives of the designation.

3.7.6. The Authority supports the proposed change to paragraph 7.3.9 which inserts reference to loss of biodiversity (e.g. flight paths of birds and bats) when considering minimising impacts resulting from construction and operation of renewable technology. The Authority proposes that “and avoiding” should be inserted after ‘minimising’ in this paragraph.

3.7.7. RE5 – DECENTRALISED ENERGY TO SUPPLY NEW DEVELOPMENT: The Authority has particular concerns regarding the changes to this policy which imply greater onus upon Local Planning Authorities to gather further evidence in order to set targets within local development documents. The regional standard recommended in the Panel Report for larger developments ensures consistency across the region. Additionally the words ‘unless…this is not feasible or viable’ should not be included in the policy as this would undermine the policy aims.

3.7.8. The Authority therefore in supports the Panel Recommendation, to ensure that larger developments across the region are consistent in reducing carbon emissions from energy use by 20%. Although these larger developments of 10 dwellings or more, or 1000m2 of non-residential floorspace are not common in the National Park, there may be implications for proposals for large agricultural buildings over 1000m2.

3.7.9. RE6 – WATER RESOURCES and New supporting text pp191-192: The Authority welcomes the insertion of new supporting text in response to the Habitats Regulations Assessment identification of N2K sites which are sensitive to increased water abstraction to serve new homes. Both SACs within the National Park (Exmoor Heaths SAC and the Exmoor & Quantock Oakwoods SAC) are stated regarding Taunton HMA and Polycentric Devon & Cornwall HMA.

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3.7.10. The Authority is concerned in relation to the increased likelihood of adverse effects occurring upon N2K sites, where the abstraction sources for new development are hydrologically linked. It is already acknowledged by the Proposed Changes that water deficits are likely to occur in the Roadford Zone even if water efficient homes are built (para 7.3.12).

3.7.11. The new supporting text and policy RE6 Water Resources do require LPAs to ensure that planned development does not exceed the capacity of existing water supply, and the locations of development do not affect the integrity of N2K sites through increased levels of water abstraction. The Environment Agency is seeking to address this problem through reductions in water abstraction licences to serve new homes.

3.7.12. RE8 – WOODLANDS AND FORESTS: The Authority supports the proposed changes to this policy to include the protection of ancient or veteran trees against loss. The aims of this policy are consistent with the objectives and targets for Exmoor’s wildlife set out in the National Park Management Plan.

3.7.13. The Authority further welcomes the insertion of new text into paragraph 7.3.20 (supporting text for policy RE8) which states: “The removal and management of trees and woodland may be necessary where this is needed to meet conservation objectives for open habitats, such as heathland and grassland”. This insertion was a recommendation of the Habitats Regulations Assessment and ensures that the integrity of the Exmoor Heaths SAC is not compromised. This text also meets the objectives for Exmoor’s landscape in the NPMP.

3.7.14. W1 – PROVISION OF WASTE SITES: The Authority does not support the Proposed Changes to this policy, in particular the change in Table 1 from ‘maximum’ landfill (000’s t/annum) to ‘minimum’ landfill. This change (with no alterations to the figures) suggests that more waste can be landfilled rather than less, and is therefore not consistent with the regional approach to waste as set out in para 7.4.1 “to minimise the amount of waste produced in the region, and then to make a major shift away from current reliance on landfill of untreated waste…”. The Authority therefore supports the original wording of the policy as set out in the Submission Draft RSS.

3.8. SECTION 8 – ENHANCING ECONOMIC PROSPERITY AND QUALITY OF EMPLOYMENT OPPORTUNITY: This section sets out the region’s approach to sustainable economic prosperity and achieving sustainable communities.

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3.8.1. ES1 – SUSTAINABLE ECONOMIC PROSPERITY: The Authority supports the insertion of this policy into the Secretary of State’s Proposed Changes, following the Panel recommendation. The Authority particularly welcomes recognition of the rural economy in “the need to support and diversify the rural economy and promote sustainable communities”.

3.8.2. The Authority supports the insertion of new supporting text (pp 217-218) to policy ES1 particularly regarding the growth of business in rural areas which should be focused on the most sustainable and accessible locations, and includes reference to home-working and re-use of redundant farm buildings. The scale of employment is also considered where it should be appropriate to the place and help support its role and function. This is commensurate with the objectives for Exmoor’s economy and communities in the NPMP.

3.8.3. TO1 – SUSTAINABLE TOURISM: This policy has been extensively modified following the Panel Report recommendations and subsequent Proposed Changes. The Authority supports the policy as set out in the Proposed Changes which embeds sustainability and recognises the potential of the region’s environmental assets for tourism where it is consistent with their conservation. This complements the NPMP objectives and vision for understanding and enjoyment of Exmoor’s special qualities.

Supporting Documents: Exmoor National Park Management Plan 2007-2012 The Draft Regional Spatial Strategy for the South West 2006-2026 Exmoor National Park Authority Representation on the Draft Regional Spatial Strategy for the South West 2006-2026 to the Examination in Public The Panel Report on the Regional Spatial Strategy for the South West 2006-2026 (December 2007) The Draft Revised Regional Spatial Strategy for the South West Incorporating the Secretary of State’s Proposed Changes (July 2008) The Revised Regional Spatial Strategy for the South West: Schedule of the Secretary of State’s Proposed Changes (July 2008) South West Regional Spatial Strategy Proposed Changes – Habitats Regulations Assessment Final Report South West Regional Spatial Strategy Proposed Changes – Sustainability Appraisal Final Report

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Appendix 1: Schedule of Changes Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS SD1 The Ecological Footprint The region’s Ecological Footprint will be stabilised and then reduced by: - Ensuring that development respects

environmental limits - Requiring the wise use of natural resources

and reducing the consumption of key resources such as energy, water and minerals

- Building a sustainable, low carbon and low resource consuming economy which can be secured within environmental limits to bring prosperity and well-being to all parts of the region

- Requiring sustainable construction and design as the norm in all future development and when opportunities arise, improving the region’s existing building stock in line with current best practice

- Minimising the need to travel by better alignment of jobs, homes and services, reducing the reliance on the private car by improved public transport and

- effective planning of future development, and a strong demand management regime applied in the region’s main centres in particular

- Requiring a shift towards the more sustainable modes of transport

- Meeting national and regional targets relating to renewable energy, resource consumption/extraction and waste production/recycling

Local authorities, regional agencies and others will

No Change SD1 The Ecological Footprint The region’s Ecological Footprint will be stabilised and then reduced by: - ensuring that achieving development that

respects environmental limits - requiring the wise use of natural resources

and reducing the consumption of key resources such as energy, water and minerals

- building a sustainable, low carbon and low resource consuming economy which can be secured within environmental limits to bring prosperity and well-being to all parts of the region

- requiring encouraging sustainable construction and design as the norm in all future development and when opportunities arise, improving the region’s existing building stock in line with current best practice

- minimising the need to travel and securing a shift to use of more sustainable modes of travel by effective planning of future development, better alignment of jobs, homes and services, reducing the reliance on the private car by improved public transport and effective planning of future development, and a strong demand management regime applied in the region’s Strategically Significant Cities and Towns main centres in particular

- requiring a shift towards the more sustainable modes of transport

- meeting national and regional targets relating to renewable energy, resource

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS include policies and proposals in their strategies, plans and programmes to assess how all new developments, regeneration areas and major refurbishments contribute to stabilising and reducing the region’s ecological footprint

consumption/extraction and waste production/recycling.

Local Authorities, regional agencies and others will include policies and proposals in their strategies, plans and programmes to assess how all new developments, regeneration areas and major refurbishments contribute to stabilising and reducing the region’s ecological footprint.

SD2 Climate Change The region’s contribution to climate change will be reduced by: - Reducing greenhouse gas emissions at least

in line with current national targets, ie by 30% by 2026 (compared to 1990 levels)

- Following the principles outlined in SD1 The region will adapt to the anticipated changes in climate by - Managing the impact of future climate change

on the environment, economy and society - Identifying the most vulnerable communities

and ecosystems given current understanding of future climate change and provide measures to mitigate against these effects

- Avoiding the need for development in flood risk areas and incorporating measures in design and construction to reduce the effects of flooding

- Recognising and putting in place policies and measures to develop and exploit those opportunities that climate change will bring

- Requiring ‘future proofing’ of development activity for its susceptibility to climate change

- Improving the resilience and reliability of existing infrastructure to cope with changes in

No Change SD2 Climate Change The region’s contribution to climate change will be reduced by: - Reducing greenhouse gas emissions at least

in line with the current national targets, ie by of 30% by 2026 (compared to 1990 levels), as part of a longer term reduction of 60% by 2050

- Following the principles outlined in SD1. The region will adapt to the anticipated changes in climate by - Managing the impact of future climate change

on the environment, economy and society - Identifying the most vulnerable communities

and ecosystems given current understanding of future climate change and provide measures to mitigate against these effects

- Avoiding the need for development in flood risk areas and incorporating measures in design and construction to reduce the effects of flooding

- Recognising and putting in place policies and measures to develop and exploit those opportunities that climate change will bring

- Requiring ‘future proofing’ of development activity for its susceptibility to climate change

- Improving the resilience and reliability of

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS climate and in the light of future demand. It will be a priority for the places identified in Section 3 to determine potential future climate change impacts and plan ways in which key services and infrastructure needs to adapt

All Local Authorities in their LDDs will need to demonstrate how they intend to contribute towards the required 60% cut in CO2 emissions by 2050 and how they intend to identify and respond to the potential impacts of climate change in their area.

existing infrastructure to cope with changes in climate and in the light of future demand. It will be a priority for the places identified in Section 3 to determine potential future climate change impacts and plan ways in which key services and infrastructure needs to adapt.

All Local Authorities in their LDDs will need to demonstrate how they intend to contribute towards the required 60% cut in CO2 emissions by 2050 and how they intend to identify and respond to the potential impacts of climate change in their area.

Spatial Strategy Statement The Spatial Strategy for the South West is based on a recognition of the diverse needs and potential for change of different places and parts of the region. Development will be planned to meet the needs of all communities and to realise their potential within environmental limits. To deliver more sustainable communities and a more sustainable region there will be: - Significant change at 21 Strategically

Significant Cities and Towns (SSCTs) in order to support their economic and service role and regeneration

- Smaller scale change outside of those places to achieve more self contained, balanced communities and a better local environment

Across the region, the role and well-being of communities in all settlements and groups of settlements is of great importance to the quality of life enjoyed by residents and the development of new economic activity, services and housing will

Policy SS Overall Core Spatial Strategy 1. The Overall Core Spatial Strategy of the RSS will be advanced through the formulation of strategic and LDF policies and proposals that: a) seek to meet identified housing and community needs; b) improve inter- and intra-regional connectivity and the functional efficiency of places; c) minimise the environmental impact of development; and d) enhance economic prosperity. 2. Strategic and LDF policies, proposals and investment strategies will seek to achieve a more balanced economy across the region through applying the following strategy emphases: i) realising the economic and other potential, particularly of the SSCTs, to add to general regional prosperity and address local regeneration, particularly in the east of the region; and ii) stimulating economic activity and development to help achieve regeneration and reduce disparities, particularly in the western part of the

Policy CSS - The Core Spatial Strategy Across the region, provision will be made to: - meet identified housing and community

needs; - improve connectivity, accessibility and the

functional efficiency of places; and - enhance economic prosperity within

environmental limits. To accommodate and manage growth in the most sustainable way, most new development will be provided for at Strategically Significant Cities and Towns (SSCTs). Provision for more limited development will be made at market and coastal towns and in small towns and villages where this will increase self-containment and promote stronger communities.

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS be provided to enhance their future role and function. In recognition of the diversity of the region, this core Spatial Strategy has been given different emphases: - Realising the economic and other potential,

particularly of the SSCTs, to add to general regional prosperity and address local regeneration, particularly in the north and centre of the region

- Stimulating economic activity and development to help achieve regeneration and reduce disparities, particularly in the western part of the peninsula and the Forest of Dean

- Managing growth within identified environmental limits, particularly in the south eastern part of the region where development pressures are high and future outward expansion and development of the South East Dorset conurbation is heavily constrained by environmental designations

peninsula. These emphases may apply in different combinations across the region, and are not mutually exclusive. 3. In order to accommodate growth in the most sustainable way and to support their economic and service role and regeneration, most new development will be concentrated at 21 Strategically Significant Cities and Towns (SSCTs). More limited provision will be made for development in smaller settlements identified through the LDF process, where this would deliver more self-contained, balanced communities and a better local environment. 4. In providing for new development, policy formulation and implementation will seek to secure the timely delivery of necessary supporting infrastructure, the highest possible quality of sustainable design, a co-ordinated approach to development planning and the optimum use of previously developed land. 5. The Regional Transport Strategy will seek to improve connectivity within the region and between the South West and other regions, while reducing the environmental impact of travel, reducing congestion and promoting increased use of sustainable travel modes.

Development Policy C Development in Small Towns and Villages In small towns and villages not meeting all the criteria of Development Policy B, based on an analysis of roles and functions, development will be appropriate where it: • Supports small-scale economic activity which fits

Policy C1 Development in Small Towns and Villages Independently of Policy B, in small towns and villages identified following an analysis of roles and functions, development will be appropriate where it: • supports small-scale economic activity which fits

Development Policy C Development in at Small Towns and Villages In small towns and villages not meeting all the criteria of Development Policy B, based on an analysis of roles and functions, development will be appropriate where it: greater self-containment and stronger local communities will be promoted

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS the scale of the settlement and can accommodate the future growth of businesses in the development permitted • Extends the range of services available including outreach delivery of services, making use of existing premises where possible • Does not significantly increase traffic on local roads and where traffic implications can be demonstrated to be acceptable • Promotes self containment, strengthens local communities, and helps to support key services Development of housing in these settlements will be permitted where it relates to requirements identified in housing market studies and other assessments of local needs for housing verified by the local authority or where housing development is necessary to support employment provision locally.

the scale of the settlement and can accommodate the future growth of businesses in the development permitted; or • extends the range of services available including outreach delivery of services, making use of existing premises where possible; and • does not significantly increase traffic on local roads and where traffic implications can be demonstrated to be acceptable; and • promotes self containment, strengthens local communities, and helps to support key services. In their LDFs, Local Planning Authorities may identify or allocate housing in these settlements where it relates to requirements identified in housing market assessments and other studies of local needs for housing verified by the local authority or where housing development is necessary to support employment provision locally.

by making provision that: - supports small scale economic activity which

fits appropriate to the scale of the settlement and can accommodate the future growth of businesses in the development permitted;

- extends the range of services available to better meet the needs of the settlement and its surrounding area including outreach delivery of services, making use of existing premises where possible; and

- Does not significantly increase traffic on local roads and where traffic implications can be demonstrated to be acceptable

- meets identified local housing needs. - Promotes self containment, strengthens local

communities, and helps to support key services.

Development of housing in these settlements will be permitted where it relates to requirements identified in housing market studies and other assessments of local needs for housing verified by the Local Authority or where housing development is necessary to support employment provision locally.

Development Policy G Sustainable Construction Developers, local authorities, regional agencies and others must ensure that their strategies, plans and programmes achieve best practice in sustainable construction by: • Following the principles contained within the ‘Future Foundations’, the South West’s sustainable construction charter, to raise awareness of sustainable construction

Policy G Sustainable Construction Developers, local authorities, regional agencies and others must ensure that their strategies, plans and programmes achieve best practice in sustainable construction by: • Following the principles contained within the Future Foundations, the South West’s sustainable construction charter, to raise awareness of sustainable construction; and • Requiring that all new and refurbished residential

Development Policy G Sustainable Construction Local Planning Authorities should promote best practice in sustainable construction and help to achieve the national timetable for reducing carbon emissions from residential and non-residential buildings. This will include: - consideration of how all aspects of

development form can contribute to securing high standards of energy and water efficiency

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS • Requiring that all new and refurbished buildings achieve the requirements of BREEAM and Eco-homes, very good standard, or at least Level 3 above minimum building standards in the emerging ‘Code for Sustainable Homes’, in order to minimise lifetime resource use, energy consumption, water use and waste production • Requiring that all larger scale developments and, in particular, urban extensions, are designed and constructed to meet the top Level 5 of the emerging ‘Code for Sustainable Homes’, including carbon neutrality • Requiring the use of sustainability statements for larger scale residential and/or mixed-use planning applications (as defined in paragraph 3.7.7), the contents of which should meet, or exceed, the ‘South West Sustainability Checklist for Developments’ • Minimising the environmental impact of new and refurbished buildings, including reducing air, land, water, noise and light pollution throughout the building’s lifetime • Requiring the use of sustainable drainage systems to minimise flood risk associated with new developments • Designing homes which are safe and adaptable, for example by following Lifetime Homes standards, Secure by Design principles and including live/work space • Taking action to improve the energy efficiency of existing buildings, and ensuring that all refurbished buildings achieve the best current standards of energy efficiency

buildings achieve as a minimum the requirements of Level 3 of the Code for Sustainable Homes in order to minimise lifetime resource use, energy consumption, water use and waste production; and • Requiring that all new and refurbished non-residential buildings achieve, as a minimum, the requirements of BREEAM Very Good standard (or, in the case of buildings for which there is no such standard, the nearest comparable standard for the industry) in order to minimise lifetime resource use, energy consumption, water use and waste production; and • Requiring that all larger scale residential developments and, in particular, urban extensions, are designed and constructed to meet or exceed the levels of the Code for Sustainable Homes set out in appendix C (vii) table 1; and • Requiring that all larger scale non-residential developments are designed and constructed to meet or exceed the carbon reduction minimum requirements set out in appendix C (vii) table 2; and • Requiring the use of sustainability statements for larger scale residential and/or mixed-use planning applications (as defined in paragraph 3.7.7), the contents of which should meet, or exceed, the South West Sustainability Checklist for Developments; and • Minimising the environmental impact of new and refurbished buildings, including reducing air, land, water, noise and light pollution throughout the building’s lifetime; and • Requiring the use of sustainable drainage

- the use of sustainable drainage systems to minimise flood risk, manage surface water and encourage natural drainage and ground water recharge where appropriate

- designing for flexible use and adaptation to reflect changing lifestyles and needs and the principle of ‘whole life costing’.

There will be situations where it could be appropriate for local planning authorities to anticipate higher levels of building sustainability in advance of those set out nationally, for identified development area or site-specific opportunities. When proposing any local requirements for sustainable buildings, local planning authorities must be able to demonstrate clearly the local circumstances that warrant and allow this and set them out in Development Plan Documents.

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS systems to minimise flood risk associated with new developments; and • Designing homes which are safe and adaptable, for example by following Lifetime Homes standards, Secured by Design principles and including live/work space; and • Taking action to improve the energy efficiency of existing buildings, and ensuring that all refurbished buildings achieve the best current standards of energy efficiency.

Taunton and Bridgwater Spatial Strategy SR20 Somerset County Council, Sedgemoor and Taunton Deane District Councils should maintain the relative relationships between Taunton, Bridgwater and Wellington, plan for their complementary balanced growth, maximising the use of previously developed land and buildings, making provision for an urban extension at Taunton, for mixed-use development, to meet the longer-term needs SR21 The economic potential for all three urban areas will be realised with provision for job growth in the Taunton and Bridgwater TTWA made for about 18,500 jobs over the plan period. Provision should be made for an average of about 1,100 dwellings per annum at Taunton, Bridgwater and Wellington collectively over the plan period distributed as follows: • An average of about 700 dwellings per annum within and adjoining Taunton’s urban area • An average of about 310 dwellings per annum at Bridgwater • An average of about 90 dwellings per annum at

Taunton HMA Sub-Regional Strategy: Policy SR6.1 Sub-Regional Approach The Local Authorities within the HMA should seek to realise the potential of Taunton and Bridgwater to contribute to Regional prosperity and focus on the planning and regeneration of these two SSCTs in an integrated manner, especially in relation to the provision of appropriate levels and types of housing, employment, retail and leisure provision, and of facilities for sustainable travel and transport. This will require co-operation through work on LDDs and should be with a particular view to avoiding increased use of the M5 corridor and other parts of the strategic road network for car commuting, while minimising congestion that obstructs access to other parts of the sub-region. Where development has cross boundary implications, joint working on LDDs, addressing such matters as the distribution of funding arising from Section 106 agreements and other funding mechanisms to deliver key infrastructure may be necessary. Policy SR6.2 Role and Function

Policy HMA6: Taunton HMA In the Taunton HMA provision will be made for: growth of about 25,800 jobs growth of at least 34,500 homes, distributed between the local authorities as:

Taunton Deane 21800 Sedgemoor 10200 West Somerset 2500

Taunton SSCT Taunton will realise its economic potential and develop its role as an employment, service and cultural centre to meet the needs of an expanding population, while reducing the risk of flooding, by providing for expansion and regeneration of the town centre. Provision for sustainable housing growth will comprise: 11,000 new homes within the existing urban area of Taunton (Taunton Deane) 4,000 new homes at Area of Search 6A to the north east of Taunton (Taunton Deane) 3,000 new homes at Area of Search 6B to the south west of Taunton (Taunton Deane)

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS Wellington Development at Taunton will focus on the regeneration of the central area through the reuse of previously developed land and buildings within the urban area, maximising densities whilst seeking high quality design standards, complemented by the provision of a strategic urban extension north of Taunton for about 3,000 dwellings (Area of Search L) as shown on the Inset Diagram. Investment will be made in key infrastructure to enable the achievement of the development proposed in this Policy.

Growth in the sub-region should be planned on the basis that Taunton will develop its role as the major business, commercial, educational, service and cultural centre for this part of the Region, with Bridgwater diversifying its economy and retaining a subordinate but complementary role. In both towns regeneration and urban extensions will make sufficient and suitable provision for their respective strategic development needs, while addressing or avoiding areas at risk of flooding, particularly in Bridgwater. In other parts of the HMA, the planning of settlements should be based on the need to support local tourism and service centre functions, while avoiding creating or intensifying dormitory relationships. Policy SR6.3 Employment Provision Provision should be made for growth of 25,800 jobs within the HMA, of which 18,500 jobs should be within the TTWA and focused mainly on the SSCT area of Taunton and Bridgwater. This requires 34 ha of employment land in Taunton and 54 ha in Bridgwater. Elsewhere, provision should be for locally generated growth only. Policy SR6.4 Housing Provision Provision should be made within the HMA for about 34,500 dwellings, distributed as follows: Taunton 1. 11,000 dwellings within the existing urban area of Taunton; 2. 4,000 dwellings within an area of search to the north east of Taunton, within Taunton Deane

Planning for employment will provide for about 16,500 jobs in the Taunton TTWA including the provision of about 34 ha of employment land. Bridgwater SSCT Bridgwater will be regenerated, diversify its economy and increase self-containment, while reducing the risk of flooding, by providing for: ♦ the re-use of redundant employment site ♦ improving the town centre Provision for sustainable housing growth will comprise: ♦ 6,200 new homes within the existing urban

area of Bridgwater (Sedgemoor) ♦ 1,500 new homes within Area of Search 6C,

partly within the existing urban area and partly as an extension to it, to the north of Bridgwater (Sedgemoor)

Planning for employment will provide for about 7,500 jobs in the Bridgwater TTWA including the provision of about 54 ha of employment land. Transport outcomes Action should be taken to improve movement and accessibility for all on the corridor between Bridgwater and Taunton (avoiding the M5). This should comprise: ♦ demand management measures ♦ sustainable travel measures; and ♦ if necessary targeted new infrastructure

investment to unlock pinch points.

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS Borough; 3. 3,000 dwellings within an area of search to the south west of Taunton, within Taunton Deane Borough. Bridgwater 4. 6,200 dwellings within the existing urban area of Bridgwater; 5. 1,500 dwellings within an area of search partly within the existing urban area and partly as an extension to it, to the north of the Bridgwater, within Sedgemoor District. Elsewhere in the HMA, outside the SSCT area 6. 3,800 dwellings within the rest of Taunton Deane Borough; 7. 2,500 dwellings within the rest of Sedgemoor District; 8. 2,500 dwellings within West Somerset District.

Barnstaple and Bideford SR43 In the northern Devon area Barnstaple will be the prime focus for development, reflecting its dominance, with policies targeted at stimulating the economy, promoting a sustainable pattern of development and reflecting the high quality environmental assets. LDDs should make provision for about 6,300 jobs in the Barnstaple TTWA, and an average of about 240 dwellings per annum and about 50 hectares of employment land (in total) in Barnstaple over the plan period.

Polycentric Devon & Cornwall HMA Sub-Regional Strategy: P Policy SR10.1 Sub-Regional Approach In the northern Devon area Barnstaple will be the prime focus for development, particularly in terms of town centre uses. Cooperation will be required, however, between North Devon and Torridge District Councils concerning the spatial planning context for the Barnstaple/Bideford area to define the complementary role expected of Bideford as a Policy B category town. In the remainder of Torridge District and North Cornwall District the Policy B category towns will perform an important role as a focus for employment, services and significant housing provision in a manner that increases self containment and supports surrounding rural

Policy HMA10: Polycentric Devon and Cornwall HMA In the Polycentric Devon and Cornwall HMA provision will be made for: ♦ growth of about 20,300 jobs ♦ growth of at least 35,000 dwellings, distributed

between the local authorities as:

North Devon 10900 Torridge 10700 North Cornwall 13400

Barnstaple SSCT Barnstaple will enhance its role as an employment and service centre to meet the needs of a growing population and increase its self-containment by providing for:

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS communities. In view of the geography of the area a wider range of smaller towns and villages may be identified under Policy C to act as local service centres and housing locations. Policy SR10.2 Role and Function The planning of Barnstable should be based on its role as the functional and employment centre for the northern part of the sub-region. This role will be supported by measures to upgrade higher education facilities to ensure the availability of skills required for economic growth. The role and function of centres, other than Barnstaple, are important as local job and service centres. These will be supported through economic development and provision of housing and services according to Policies B and C in a manner that increases self-containment and supports surrounding rural communities. Development that stimulates the economy, and reflects the environmental quality of the locality with particular emphasis on other functionally important centres to be defined in LDFs will be supported. Policy SR10.3 Employment Provision Provision should be made for growth of 20,300 jobs within the HMA of which about 6,300 jobs should be in the Barnstaple TTWA and about 50 hectares of employment land (in total) in Barnstaple. LDF policies should be targeted at stimulating the economy, promoting a sustainable pattern of

♦ expansion of the town centre ♦ improvements to higher education facilities to

ensure the availability of skills required for economic growth

Provision for sustainable housing growth will comprise: ♦ 4,800 new homes within the existing urban

area of Barnstaple (North Devon) ♦ 2,400 new homes at Area of Search 10A at

Barnstaple (North Devon) Provision should be made for around 6,300 jobs in the Barnstaple TTWA including around 50 hectares of employment land.

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS development and reflecting the high quality environmental assets. Policy SR10.4 Housing Provision Housing provision within the HMA should be made for 35,000 dwellings distributed as follows: Within North Devon: 10,900 made up as follows; 4,800 in the Barnstaple urban area; 3,700 to be distributed in the district under Polices B and C. Within Torridge: 10,700 to be distributed in the district under Policies B and C. Within North Cornwall: 13,400 to be distributed in the district under Policies B and C.

HD1 Sub Regional Distribution of Housing 2006-2026 LDDs should deliver an average annual net increase in housing across their area according to the locational principles and priorities set out in the Development Policies A to C, and the sub regional statements SR1 to SR41. The overall distribution to 2026 is set out in Tables 4.1 and 4.2.

Policy HD1 Sub-Regional Distribution of Housing 2006-2026 LDDs should deliver an average annual net increase in housing across their area according to the locational principles and priorities set out in the Development Policies A to C, and the sub regional statements. The overall distribution to 2026 is set out in new Tables 4.1 and 4.2.

HD1 Sub-Regional Distribution of Housing 2006-2026: Managing and Stepping Up Supply Provision should be made across the HMAs and LPA areas to deliver the total number of dwellings in the periods between 2006-2016 and 2016-2026 as set out in Tables 4.1 and 4.2. To support the required step-up in the delivery of new homes and to ensure that new homes are in locations that accord with the Core Spatial Strategy; Local Planning Authorities should complete Strategic Housing Land Availability Assessments (SHLAAs) as evidence for LDFs Local Planning Authorities should identify and manage the release of land to maintain the momentum of housing delivery to meet the region's objectives for places by; ♦ Identifying sites and contributions form areas

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS of planned change in LDFs (based on Strategic Housing Land Availability Assessments and other evidence) to ensure a 15 year supply of land for housing , including a 5 year supply of specific, deliverable sites

♦ Where needed, identifying broad locations in LDFs so that these locations can be included in the 11-15 year supply and be further tested before sites are identified

♦ Co-ordinating the release of housing land with the necessary improvement to and/or provision of infrastructure

♦ Adopting a flexible approach to delivery by not treating housing figures as ceilings whilst ensuring that development is focused on locations that deliver the Plan's Core Spatial Strategy

♦ Maintaining housing and brownfield land trajectories, and managing delivery where actual performance is outside of acceptable ranges.

The Regional Planning Body should monitor the five-year supply in the region, along with levels and patterns of migration, household and population change, the recent and projected performance of the regional economy, housing mix, affordability, and delivery in rural areas. The RPB should maintain a regional housing trajectory, linked to regional and local Annual Monitoring Reports. Where monitoring suggests that the expected outcomes of the Plan are not being achieved, consideration should be given to reviewing the Plan. The Plan will be refined through a partial review to

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS ensure that additional and longer term housing growth is planned and accommodated in the most sustainable way by identifying broad locations to meet longer term development needs, taking account of New Growth Points, Ecotown initiatives, and other evidence.

TR12 Regional Freight Map The strategic network (national and regional routes) will be promoted for use by HGV vehicles rather than county routes. Local authorities, through their LTPs, will reflect the regional hierarchy of routes identified in the Regional Freight Map and give priority to strategic routes in determining allocations for road maintenance.

Policy TRANs11 Regional Freight Transport The strategic network (national and regional routes) as shown on Map 5.1 will be promoted for use by HGV vehicles. Local authorities, through their LTPs, will reflect the regional hierarchy of routes and give priority to strategic routes in determining allocations for road maintenance.

RTS4 - Freight and the Primary Route Network Relevant plans and strategies should include policies and proposals for rest and service areas for freight vehicles. The primary route network (including motorways and trunk roads) should be promoted for use by HGVs in preference to other roads. The routes should be signed appropriately. Environmental weight restrictions should not be placed on these routes. The priority for road maintenance investment should reflect the importance of the corridors identified in RTS1 and the rest of the Primary Route Network. A site for a road/rail freight interchange should be identified and safeguarded in Local Development Documents at or near Exeter subject to viability.

TR9 Airports Airports within the region should meet an increasing proportion of regional demand for air travel to reduce ‘leakage’ to other regions and the London airports, with the expected growth met by developing the major existing airports in the region – Bristol, Exeter and Bournemouth. Other airports will satisfy important local markets, for example Newquay, Plymouth and Staverton (Gloucester). Plymouth/Newquay should continue to provide business links to international hubs and London

Policy TRANs10 Airports Proposals for the growth of airports in the region should be supported as follows: • At Bristol, Bournemouth and Exeter Airports within the currently agreed levels of growth as set out in the Air Transport White Paper; • At Newquay as an important infrastructure asset to support Cornwall’s Objective 1 and Convergence Programme; and • At Plymouth and Gloucestershire Airport to sustain their roles as airports of sub-regional

RTS6 - Airports and Heliports Airports within the region should meet an increasing proportion of regional demand for air travel to reduce ‘leakage’ to other regions and the London airports. Relevant plans and strategies should include policies and proposals that: ♦ Support the development of Bristol,

Bournemouth and Exeter within the currently agreed levels of growth set out in the ‘Future of Air Transport’ White Paper;

♦ Support Plymouth City Airport and Newquay to

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS while facilitating tourist visits into the region. Local authorities, airport operators and other agencies will provide improvements to aviation facilities and access to airports (including public transport) in the region to meet future development requirements consistent with the overall transport strategies for the urban areas.

significance. Airport Surface Access Strategies should be provided by the airport operator to achieve: • The management of the environmental impact of surface access; and • A higher modal share in favour of public transport.

sustain and enhance their roles of serving local catchment areas;

♦ Support the role of Gloucestershire and Filton Airports in continuing to serve business aviation needs; and

♦ Support the role of Land’s End Aerodrome, Penzance Heliport, St Mary’s Airport and Tresco Heliport in providing lifeline air services to the Isles of Scilly.

Airport operators required to prepare Masterplans should also prepare Airport Surface Access Strategies and set targets for their airport to achieve: ♦ Minimising the environmental impact of

surface access; and ♦ A higher modal share in favour of public

transport, cycling and walking. CS1 Provision of Community Services Local authorities should work with their Local Strategic Partnerships and other relevant organisations to provide up-to-date assessments of need for a full range of community facilities and infrastructure suitable for all sections of the community. LDDs should ensure that timely and sufficient provision is planned in parallel with housing and other development. Service providers need to ensure that all provision meets uniformly high standards to minimise the number of users who would wish to choose any other than the closest provider.

No change – not considered at EiP CS1 Provision of Community Services and Community Infrastructure Local Authorities should work with their Local Strategic Partnerships and other relevant organisations to provide up to date assessments of the need for a full range of community facilities and services infrastructure suitable for all sections of the community. LDDs should ensure that timely and sufficient provision is planned in parallel with housing and other development. Service providers need to ensure that all provision meets uniformly high standards to minimise the number of users who would wish to choose any other than the closest provider.

GI1 Green Infrastructure Development of networks of Green Infrastructure

Policy GI1 Green infrastructure Development of networks of Green Infrastructure

GI1 Green Infrastructure Development of networks of Green Infrastructure

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS (GI) will be required to enhance quality of life in the region and support the successful accommodation of change. GI networks will comprise multifunctional, accessible, connected assets, planned around existing environmental characteristics. This may take the form of protection, enhancement or extension of existing resources or the provision of new or replacement facilities. When planning the proposed distribution of development, GI is required as an integral part of development, with provision for a network of GI incorporated in the Spatial Strategy. Local authorities and partners will: • Build upon existing expertise and initiatives to identify priorities and partnerships for GI • Incorporate GI policies setting out broad locations for GI appropriate to the extent and distribution of development proposed, co-ordinated across administrative boundaries as appropriate • Develop a GI Plan with a delivery programme to support GI policies

(GI) will be required to enhance quality of life in the region and support the successful accommodation of change. GI networks will comprise multifunctional, Accessible, connected assets, planned around existing environmental characteristics. Measures should be taken to realise the opportunities offered by major strategic components such as the River Stour Valley in South East Dorset. This may take the form of protection, enhancement or extension of existing resources or the provision of new or replacement facilities. When planning the proposed distribution of development, opportunity should be taken to extend the network. GI is required as an integral part of development, with provision for a network incorporated in the masterplan. Local authorities and partners will: • Build upon existing expertise and initiatives to identify priorities and partnerships for GI • Incorporate GI policies setting out broad locations for GI appropriate to the extent and distribution of development proposed, co-ordinated across administrative boundaries as appropriate. • Develop a GI Plan with a delivery programme to support GI policies

(GI) will be required to enhance quality of life in the region and support the successful accommodation of change. GI networks will comprise multifunctional, accessible, connected assets, planned around existing environmental characteristics. This may take the form of protection, enhancement or extension of existing resources or the provision of new or replacement facilities. Plans, strategies, proposals and schemes should aim to deliver wider spatial outcomes that incorporate environmental and socio-economic benefits by; ♦ Conserving and managing existing GI; ♦ Creating new GI; and ♦ Enhancing its functionality, quality and

connectivity. When planning the proposed distribution of development, GI is required as an integral part of development and should include the identification, development and management of new areas of open space, not just more intensive use of existing areas of open space. with provision for a network of GI incorporated in the Spatial Strategy. Local Authorities and partners will: ♦ Build Draw upon existing expertise and

initiatives to take forward GI planning and identify priorities and partnerships for GI.

♦ Incorporate GI policies setting out broad locations for GI appropriate to the extent and distribution of development proposed, coordinated across administrative boundaries as appropriate

♦ Integrate proposals to improve GI in the

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS delivery of new developments, particularly through area based regeneration initiatives and major development proposals

♦ Ensure that a key aim of green infrastructure is the maintenance and improvement of biodiversity

♦ Protect the integrity of sites of international importance and provide new areas of appropriate greenspace where development would otherwise cause unacceptable recreational pressure on sites of international ecological importance

♦ Maximise the role of GI in mitigating and adapting to climate change

♦ Develop a GI Plan with a delivery programme to support GI policies.

ENV1 Protecting and Enhancing the Region’s Natural and Historic Environment The quality, character, diversity and local distinctiveness of the natural and historic environment in the South West will be protected and enhanced, and developments which support their positive management will be encouraged. Where development and changes in land use are planned which would affect these assets, local authorities will first seek to avoid loss of or damage to the assets, then mitigate any unavoidable damage, and compensate for loss or damage through offsetting actions. Priority will be given to preserving and enhancing sites of international or national landscape, nature conservation, geological, archaeological or historic importance. Tools such as characterisation and surveys will be used to enhance local sites,

ENV1 Protecting and Enhancing the Region’s Natural and Historic Environment The quality, character, diversity and local distinctiveness of the natural and historic environment in the South West will be protected and enhanced, and developments which support their positive management will be encouraged. Where development and changes in land use are planned which would affect these assets, local authorities will first seek to avoid loss of or damage to the assets, then mitigate any unavoidable damage, and compensate for loss or damage through offsetting actions. Priority will be given to preserving and enhancing sites of international or national landscape, nature conservation, geological, archaeological or historic importance. Tools such as characterization and surveys will be used to enhance local sites,

ENV1 Protecting and Enhancing the Region’s Natural and Historic Environment The quality, character, diversity and local distinctiveness of the natural and historic environment in the South West will be protected and enhanced, and developments which support their positive management will be encouraged. Where development and changes in land use are planned which would affect these assets, Local Authorities will first seek to avoid loss of or damage to the assets, then mitigate any unavoidable damage, and compensate for loss or damage through offsetting actions. Priority will be given to preserving and enhancing sites of international or national landscape, nature conservation, geological, archaeological or historic importance. Tools such as characterisation and

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS features and distinctiveness through development, including the setting of settlements and buildings within the landscape and contributing to the regeneration and restoration of the area.

features and distinctiveness through development, including the setting of settlements and buildings within the landscape and contributing to the regeneration and restoration of the area. Any development that could have any negative effect on the integrity and conservation objectives of a N2K site would not be in accordance with the development plan. Further assessment of the implications for N2K sites may be required at subsequent levels including LDDs, and any development that would be likely to have a significant effect on a N2K site, either alone or in combination, will be subject to assessment at the project application stage. Three locations are considered to be particularly vulnerable and require special protection – Dorset Heaths, River Avon (Hampshire) and Severn Estuary.

surveys will be used to enhance local sites, features and distinctiveness through development, including the setting of settlements and buildings within the landscape and contributing to the regeneration and restoration of the area. Any development that could have any negative effect on the integrity and conservation objectives of a N2K site would not be in accordance with the development plan. Further assessment of the implications for N2K sites is required at subsequent levels including LDDs, and any development that would be likely to have a significant effect on a N2K site, either alone or in combination, will be subject to assessment at the project application stage. Three locations are considered to be particularly vulnerable and require special protection - Dorset Heath, River Avon (Hampshire) and Severn Estuary. Paragraph 4.1.16 identifies a number of other sites where further protection may be necessary depending on the impacts of new development proposed through LDDs or planning applications.

RE5 Renewable Energy and New Development Larger-scale developments will be expected to provide, as a minimum, sufficient on-site renewable energy to reduce CO2 emissions from energy use by users of the buildings constructed on site by 10%. Developers will be expected to demonstrate that they have explored all renewable energy options, and designed their developments to incorporate any renewable energy requirements. Individual Local Planning Authorities may use lower thresholds for what constitutes a larger-scale development and set higher

Policy RE5 Renewable Energy and New Development When meeting carbon reduction requirements in new developments set out in Policy G, larger-scale developments will be expected to provide, as a minimum, sufficient on-site renewable energy to reduce CO2 emissions from energy use by users of the buildings constructed on site by the equivalent of 20% of regulated emissions. Developers will be expected to demonstrate that they have explored all renewable energy options, and designed their developments to incorporate

RE5 Decentralised Energy to Supply New Development Local planning authorities should set targets in their DPDs for the energy to be used in new development to come from decentralised and renewable or low-carbon energy sources where it is feasible and viable, and the development thresholds to which such targets would apply. In the interim, before targets are set in DPDs, at least 10% of the energy to be used in new development of more than 10 dwellings or 1000m2 of non-residential floorspace should come from

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS percentages for on-site generation, taking into account the impact on initial and lifetime affordability of homes.

any renewable energy requirements. decentralised and renewable or low-carbon sources, unless, having regard to the type of development involved and its design, this is not feasible or viable.

RE6 Water Resources The region’s network of ground, surface and coastal waters and associated ecosystems will be protected and enhanced, taking account of the Environment Agency's ‘Regional Water Resources Strategy’, catchment abstraction management strategies, groundwater vulnerability maps, groundwater source protection zone maps and river basin management plans. Surface and groundwater pollution risks must be minimised so that environmental quality standards are achieved and where possible exceeded. Local Planning Authorities, through their LDDs, must ensure that rates of planned development do not exceed the capacity of existing water supply and wastewater treatment systems and do not proceed ahead of essential planned improvements to these systems.

Not considered – no change No change – relevant changes are made to the supporting text.

RE8 Woodlands and Forests Local authorities and other bodies will support the implementation of the RWFF, ensuring the environmental, social and economic value and character of the region’s woods and forests are protected and enhanced in a sustainable way. Woodland areas, including ancient and semi-natural woodland should be maintained at least at 2005 levels and expanded where possible to provide a buffer to core areas of woodland. Where woodland is unavoidably lost through development it should be replaced with appropriate new

Not considered – no change RE8 Woodlands and Forests Local Authorities and other bodies will support the implementation of the RWFF, ensuring the environmental, social and economic value and character of the region’s trees, woods and forests are protected and enhanced in a sustainable way. Woodland areas, including ancient and semi-natural woodland should be maintained at least at 2005 levels and expanded where possible to provide a buffer to core areas of woodland. Ancient or veteran trees should be protected against loss. Where woodland is unavoidably lost

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS woodland on at least the same scale. through development it should be replaced with

appropriate new woodland on at least the same scale.

NEW POLICY: Policy ES1 Successful and Competitive Business Local Authorities, working with SWRDA, other public sector organisations and the private sector, should include measures in their LDDs to promote a switch from employment-led to productivity-led growth. These measures should include: • Guiding investment to locations where it will have maximum benefit, recognising the role of the region’s large urban areas as key drivers of productivity, the need to diversify the rural economy and to achieve successful regeneration; • Ensuring a range and choice of appropriate sites and premises to meet business need, including a quota of smaller sites for micro, small and medium sized enterprises, to cater for both organic growth and inward investment; • Promoting innovation and the development of the knowledge driven economy by harnessing the potential of Higher and Further Education Institutions, hospitals and other knowledge intensive institutions; • Supporting the development of science parks, innovation centres and incubator units through the identification, provision and safeguarding of appropriate sites and premises; and • Supporting the development of priority business sectors (as identified in the RES), including clusters of related activity and other key sectors of importance sub-regionally.

ES1 Sustainable Economic Prosperity Local Authorities, working with SWRDA, other public sector organisations and the private sector, should include measures in their LDDs to promote a switch from employment-led to productivity-led growth. These measures should include: ♦ Guiding investment to locations where it will

have maximum benefit and reduce the need to travel recognising;

o the role of the region's large urban areas as key drivers of productivity

o the need to support and diversify the rural economy and promote sustainable communities

o the need to achieve successful regeneration as well as ongoing economic development;

♦ Ensuring a range and choice of appropriate sites and premises to meet business need, including a quota of smaller sites for micro, small and medium sized enterprises, to cater for both organic growth and inward investment;

♦ Promoting innovation and the development of the knowledge driven economy by harnessing the potential of Higher and Further Education Institutions, hospitals and other knowledge intensive institutions.

♦ Supporting the development of science parks, innovation centres and incubator units through the identification and safeguarding of

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS appropriate sites and premises; and

♦ Supporting the development of priority business sectors (as identified in the RES), including clusters of related activity and other key sectors of importance sub-regionally.

TO1 Sustainable Tourism Local authorities, stakeholders and the tourism industry will promote the development of tourism by: • Improving the quality and diversity of existing facilities and accommodation throughout the region, particularly where this would reduce seasonality • Maintaining and enhancing the role of existing resorts, especially the major resorts of Bournemouth, Poole, Torbay, Weymouth, Weston-super-Mare and Newquay, by safeguarding existing high quality accommodation and facilities, and investing in new facilities where these would be viable and of an appropriate scale • Realising the potential of the region’s environmental, cultural and heritage assets as a basis for the development of sustainable tourism, where consistent with their conservation • Identifying opportunities for the development of new facilities and accommodation related to recreational cycle and footpath networks within the region

Policy TO1 Sustainable Tourism Local Authorities, regional partners, stakeholders and the tourism industry (particularly Destination Management Organizations) should have regard to the development of sustainable tourism by: • embedding sustainability practices in all new tourism development; • taking into account identified regional and sub-regional cultural needs of our visitors and local communities; • improving the quality and diversity of existing facilities and accommodation throughout the region, particularly where this would increase out of season visitation especially in the winter and spring periods; • realising the potential of the region’s environmental, cultural and heritage assets as a basis for the development of sustainable tourism, where consistent with their conservation; • ensuring that, as far as possible, new tourism developments are accessible by public transport and supported by green transport plans and visitor management programmes. In rural areas creative and collaborative solutions may need to be found where it is difficult to meet the objectives of access by sustainable modes of transport; and, • identifying opportunities for the development of new facilities and accommodation related to outdoor leisure pursuits and recreational cycle and

TO1 Sustainable Tourism Local Authorities, regional partners, stakeholders and the tourism industry (particularly Destination Management Organisations) should have regard to the development of sustainable tourism by: embedding sustainability practices in all new tourism development; ♦ taking into account identified regional and sub-

regional cultural needs of our visitors and local communities;

♦ improving the quality and diversity of existing facilities and accommodation throughout the region, particularly where this would increase out of season visits especially in the winter and spring periods;

♦ realising the potential of the region's environmental, cultural and heritage assets as

♦ a basis for the development of sustainable tourism, where consistent with their conservation;

♦ ensuring that, as far as possible, new tourism developments are accessible by public transport and supported by green transport plan and visitor management programmes. In rural areas creative and collaborative solutions may need to be found where it is difficult to meet the objectives of access by sustainable modes of transport; and,

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Submission Draft RSS Panel Report Recommendation SoS Proposed Changes to Draft RSS footpath networks within the region. ♦ identifying opportunities for the development of

new facilities and accommodation related to outdoor leisure pursuits and recreational cycle and footpath networks within the region.