Lot 21 – Pre Application Response from Somerset Planning Department
Rebecca Randall has kindly provided us with, and given permission for us to share, the pre-application response she has received from Somerset Council.
Published: 28 September 2026
Summary:
The proposal relates to the development of agricultural land adjoining the settlement boundary of
Edington for a mixed residential development incorporating affordable and market housing,
alongside community infrastructure. Based on the information submitted, and subject to
demonstrating an identified local housing need together with Parish Council support for the
proposed community infrastructure, the principle of development appears capable of being
supported under Policy T3a. No fundamental constraints have been identified at this stage,
although a number of technical matters, including highways, ecology, drainage, heritage and
residential amenity, will need to be addressed through any future planning application. Careful
consideration will also need to be given to the detailed design and landscaping of the scheme to
ensure that it responds appropriately to its surroundings and the character of the area.
Planning Policies, legislation and other information relevant to your proposal:
The Council’s statutory Development Plan comprises the Sedgemoor Local Plan and the following
policies are relevant to the determination of this proposal:
S1 Presumption in Favour of Sustainable development
S2 Spatial Strategy for Sedgemoor
S3 Infrastructure Delivery
S4 Sustainable Development Principles
T3a Tier 3 Settlements – Housing
D2 Promoting High Quality and Inclusive Design
D5 Housing Mix
D6 Affordable Housing
D13 Sustainable Transport and Movement
D14 Managing the Transport Impacts of Development
D19 Landscape
D20 Biodiversity and Geodiversity
D21 Ecological Networks
D25 Protecting Residential Amenity
D26 Heritage Assets
D34 Outdoor Public Recreational Space and New Residential Areas
As a result of local government reorganisation Somerset Council was established on 1 April 2023
and the Council has started the preparation of a new local plan. The timetable for the plan is set
out in an updated Local Development Scheme agreed in April 2026. The emerging Local Plan is
not currently at a stage where any significant weight can be attached. However, where applicable
up to date evidence based studies which have been completed to support the preparation of the
Local Plan will be taken into account in decision making. These can be found on the Council’s
website – Local Plan Evidence Base and Monitoring.
The following policies of the National Planning Policy Framework are also relevant:
S3: Presumption in favour of sustainable development
S5: Principle of development outside settlements
CC2: Mitigation of climate change
CC3: Adaptation to climate change
HO7: Meeting the need for homes
HO8: Providing affordable homes
HO10: Exception sites
L2: Making effective use of land
L3: Achieving appropriate densities
DP3: Key principles for well-designed places
TR4: Street design, access and parking
TR6: Assessing transport impacts
TR8: Public rights of way
P2: Ground conditions
P3: Living conditions and pollution
P4: Impact of development on existing activities
N2: Improving the natural environment
N3: Trees in new development
HE5: Assessing effects on heritage assets
HE6: Proposals affecting designated heritage assets
Other possible Relevant Considerations (without limitation):
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National Planning Practice Guidance
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National Design Guide/Code
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The Countywide Parking Strategy (2013)
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Somerset County Council Highways Development Control Standing Advice
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Edington Village Design Statement
ASSESSMENT OF MAIN ISSUES:
Background
The site is located adjacent to, but outside of, the defined settlement boundary of Edington. The
main part of the village lies to the west, however there is existing built form to the south and east
which largely forms continuous development with the adjoining settlement of Catcott, though
notably this site is one of the primary undeveloped areas between the two.
The site comprises undeveloped agricultural land. Access is currently available via existing
vehicular entrances located in the south-western corner and along the western boundary. The site
has no relevant planning history.
Principle of development
Policy T3a of the Sedgemoor Local Plan provides the policy framework for considering
development proposals at Tier 3 settlements, including circumstances where land outside, but
adjoining, settlement boundaries may be released to meet identified local housing needs. The
policy sets out a series of criteria against which proposals must be assessed.
Policies S5 and H10 of the NPPF are also relevant. S5 states that outside of settlements, only
certain forms of development should be approved. This provision includes schemes which would
address an evidenced unmet need for housing, where the local planning authority cannot
demonstrate a five year supply of deliverable housing sites. It also includes exception site
schemes in accordance with Policy HO10. I will turn to these matters in due course.
A key requirement of Policy T3a is that development should address an identified local need for
affordable housing. Your submission notes the intention to undertake a Housing Needs Survey to
establish the current level of need for affordable housing. Enclosed are the comments of the
Council’s Affordable Housing officer who supports this approach.
I am mindful of our discussion on site and advice provided on other sites in recent years. The
Council has accepted relaxing the requirement for provision of a Housing Needs Survey, and is
content to allow information taken from the housing register to inform an understanding of need.
This approach seems supported by policy HO10 criteria (a) which says that local needs can be
identified through a housing need surveys or via secondary data (which is no more than five years
old). This approach can avoid the need to undertake costly and time-consuming needs surveys,
and can more quickly identify outstanding levels of need.
Details of the current outstanding levels of need on the housing register have not been provided in
the response by the Affordable Housing officer. These have subsequently been requested and will
be provided in due course. The Coucnil is content, given the spatial and functional relationship
between Catcott and Edington that need in Catcott can be taken into account. Conseqeuntly the
need arising in both parishes has been requested.
It is noted a ‘hybrid’ approach of affordable housing provision and other community benefit is
proposed. It is proposed that 30% affordable housing is provided, rather than the minimum 40%
policy requirement, alongside other infrastructure. Policy T3a is supportive of this approach but it is
subject to a number of caveats. O
It is noted a ‘hybrid’ approach of affordable housing provision and other community benefit is
proposed. It is proposed that 30% affordable housing is provided, rather than the minimum 40%
policy requirement, alongside other infrastructure. Policy T3a is supportive of this approach but it is
subject to a number of caveats.
Firstly, the policy requires that any alternative infrastructure provision is supported by the Parish
Council. As such, it would be necessary to demonstrate that the proposed infrastructure has the
support of Edington Parish Council. In the absence of that support, the Council would be unlikely to
take a favourable view of a reduction in affordable housing provision below the policy requirement.
Secondly, it would need to be demonstrated that the value of the proposed infrastructure is
equivalent to the value of the affordable housing provision being foregone. To do so, a viability
appraisal would need to be submitted in support of any future application. Given the nature of the
proposal, the Council would require that appraisal to be independently reviewed at the applicant’s
expense, with the findings informing consideration of whether the reduction in affordable housing
provision is justified.
Subject to these matters being satisfactorily addressed, and subject to confirmation of the extent of
local housing need, the Council’s current view is that the principle of residential development on
the site is capable of being supported under the provisions of Policy T3a.
Furthermore, it is a material consideration that the Council can currently demonstrate only 3.31
years’ supply of deliverable housing sites against its identified requirement. Accordingly, the
provisions of NPPF policy S5(j) are engaged. On the basis of the information currently available,
the site appears well related to the existing settlement and the scale of development proposed
appears proportionate. As such, S5(j) is likely to weigh in favour of the proposal.
Design, Layout and Landscape
The revised layout and sketch masterplan submitted on 21 August 2026 has informed the
Council’s comments. The amended proposals seek to focus the majority of the residential
development within the south-eastern part of the site, with the south-western corner reserved for
community infrastructure and/or play provision, the precise nature of which is yet to be determined.
In considering the acceptability of the layout, we discussed during the site visit the extent to which
the site contributes to the separation between Edington and Catcott. Whilst the main built form of
Edington lies to the west of the site, there is also relatively continuous development extending
along Broadway to the south. The site therefore forms one of the more prominent breaks in built
development between the two settlements. This is an important consideration in the assessment of
the proposals.
In this regard, the broad principles of the revised layout appear logical. By concentrating the built
development within the south-eastern corner of the site and retaining the south-western part as
open space and community infrastructure, the proposal would retain a degree of openness within
the site and maintain a degree of separation and openness between the existing built form
associated with Edington and Catcott, whilst limiting the extent to which development would spread
across the whole parcel.
The proposed arrangement of development is also considered positive in that dwellings generally
provide an outward-facing relationship towards Broadway and the open areas along the northern
part of the site, rather than presenting rear garden boundaries to these more publicly visible areas.
This approach has the potential to create a more attractive development edge. The indicative
street pattern also appears capable of providing an appropriate level of connectivity and
permeability throughout the development.
We also discussed during the site visit whether additional landscaping may be appropriate along
the northern part of the site. In particular, consideration should be given to the public right of way
which passes on an east-west alignment to the north of the proposed built form. Whilst detailed
landscape proposals have not been provided at this stage, there may be opportunities to introduce
tree and landscaping planting in the northern part of the site. This could assist in filtering views of
the new housing from the public right of way, soften the transition between the built form and the
wider countryside, and potentially contribute towards the delivery of biodiversity net gain
requirements. The appropriateness, extent and species composition of any such planting would
need to be considered as part of any future planning application.
Overall, whilst a detailed assessment would need to be undertaken on the basis of a fully
worked-up scheme, no in-principle concerns are raised regarding the broad layout approach
shown on the revised masterplan. The final acceptability of the proposals will, however, depend
upon the quality of the detailed design, landscaping strategy and the extent to which the
development successfully integrates with the existing settlement pattern and local character.
In developing the detailed design of the scheme, particular regard should be had to the Edington
Village Design Statement, which provides guidance on the distinctive character of the village and
the design principles expected of new development. Any future application should demonstrate
how the layout, scale, appearance, materials, landscaping and boundary treatments have been
informed by the guidance contained within that document. Early consideration of these matters will
assist in ensuring that the development responds positively to local character and integrates
successfully with its surroundings.
Residential Amenity
The site lies immediately adjacent to the Suprema Industrial Estate along its eastern boundary. As
such, careful consideration will need to be given to the relationship between the proposed
residential development and the existing commercial uses operating from the estate.
Depending on the nature of the activities undertaken within the industrial estate, there is potential
for noise, disturbance and other amenity impacts to affect future occupiers of the proposed
dwellings, particularly those located along the eastern edge of the site. Equally, the Council is
mindful of the agent of change principle, whereby new residential development should not result in
unreasonable restrictions being placed on existing businesses that are already lawfully operating in
the area.
Accordingly, any future planning application should be supported by an appropriate assessment of
potential amenity impacts, likely including a noise assessment. This should examine the nature
and extent of any noise arising from activities within the adjacent industrial estate, consider the
likely effect on future residents and identify any mitigation measures necessary to secure an
acceptable standard of living conditions. Where impacts are identified, it will need to be
demonstrated that they can be appropriately mitigated through site layout, separation distances,
acoustic fencing or other suitable interventions.
More generally, the indicative layout appears to provide adequate separation distances between
the proposed dwellings and neighbouring residential properties. On the basis of the information
currently available, there are no obvious concerns regarding overlooking, loss of privacy,
overbearing impacts or loss of light to existing neighbouring occupiers. Nevertheless, these
matters would need to be fully assessed as part of any future planning application once detailed
plans, dwelling designs and site levels have been finalised.
Overall, whilst no in-principle concerns are raised at this stage regarding residential amenity,
further assessment will be required to demonstrate that future occupiers can be provided with an
acceptable standard of amenity whilst ensuring the continued operation of existing neighbouring
businesses is not prejudiced.
Highways and Access
It is noted that vehicular access is proposed from a new priority junction formed approximately
centrally within the site’s southern boundary.
Any future application would need to demonstrate that visibility splays can be achieved and
maintained. These would need to be 2.4m x 43 m in either direction given the site entrance falls
within the 30mph speed limit. Based on observations made during the site visit, there does not
appear to be any obvious reason why this could not be achieved, although this would ultimately be
a matter for detailed assessment by the Highway Authority.
Parking provision would need to accord with the Council’s adopted parking standards and sufficient
space should also be provided for turning and servicing within the site.
We have consulted the Highway Authority regarding your proposal not to provide street lighting
within the development. At the time of writing, a response has not been received. We will continue
to pursue this matter and any further advice received will be forwarded separately once available.
Ecology and Biodiversity
The site falls within the catchment of the Somerset Levels and Moors Ramsar site, which is
affected by the issue of phosphate pollution. It appears that there is an existing mains foul sewer in
vicinity of the site. Provided your scheme can connect to mains drains, foul waste arising would
discharge downstream of the Ramsar site, and it would therefore be confirmed that no Likely
Significant Effect arises, and impacts on the Ramsar could be screened out.
If connection cannot be secured, the application would need to be accompanied by a Nutrient
Neutrality Assessment and Mitigation Strategy. Guidance for applicants on this process and
information required can be found on our website here:
https://www.somerset.gov.uk/planning-buildings-and-land/phosphates-on-the-somerset-levels-and-
moors-ramsar-site/
The site falls outside of any other designated areas such as bat consultation zone and county
wildlife sites. The scheme would need to be accompanied by protected species surveys, and any
follow up surveys required. The 10% mandatory biodiversity net gain will also need to be delivered.
As a general point, Biodiversity Net Gain should be considered from the earliest opportunity. The
mitigation hierarchy should be applied and ability to comply with the Biodiversity Gain Hierarchy be
actively considered from the start. The Somerset BNG Principles should be applied in designing
any BNG proposals. An applicant should have a reasonably clear idea of how they will deliver their
BNG requirements on-site, and an idea of the quantum of off-site units or Statutory Credits that
may be required and be able to justify this approach. Applicants should refer to the Somerset BNG
Guidance Note for further guidance on how to consider Biodiversity Net Gain in relation to their
application (see link below).
In Somerset, additional information needs to be submitted alongside any Biodiversity Net Gain
liable planning application before the application can be validated.
These requirements build on the minimum information required nationally. They are intended to
make sure that sufficient information is available to consider and determine planning applications
where Biodiversity Net Gain is a material consideration. These validation requirements are set out
below. For further information on the requirements for planning applications in respect of
Biodiversity Net Gain please follow the link to the Somerset Council webpage:
Heritage Assets
A Grade II listed building, Great House, is located to the west of the site. Any future planning
application should therefore be accompanied by a Heritage Statement which assesses the
significance of the asset and the contribution that the application site makes to its setting. It is
noted that the layout seeks to concentrate built development towards the eastern part of the site,
whilst retaining a more open character in the western section. This approach has the potential to
minimise impacts on the setting of the listed building, although a detailed assessment would be
required as part of any future application.
Flood Risk and Drainage
The site is within Flood Zone 1 and is therefore at low risk of fluvial flooding. Nevertheless, any
future application will need to be accompanied by a Flood Risk Assessment and Surface Water
Drainage Strategy demonstrating that surface water can be managed appropriately and without
increasing flood risk elsewhere. The Council would generally expect opportunities for sustainable
drainage measures to be incorporated into the design of the development wherever feasible.
Footway Connection
The submitted information indicates that a pedestrian link may be provided along the southern
boundary of the site to connect it with the existing bus stop and nearby facilities. Whilst the Council
will ultimately be guided by the advice of the Highway Authority on this matter, the principle of
providing a pedestrian route which allows users to access the bus stop without walking within the
carriageway is welcomed.
At this stage, however, it is unclear what works may be required to facilitate such a route and, in
particular, whether any hedgerow, trees or vegetation would need to be removed to accommodate
it. This would need to be fully understood and assessed as part of any future planning application,
having regard to landscape, ecological and highway safety considerations.
Community Infrastructure Levy (CIL) and Planning Obligations:
CIL – Submitting ‘Form 1’ with your application will save time, as your eventual application may be
delayed if we have to request this at a later time, advice and forms can be found on the Planning
Portal.
Based on the number of dwellings proposed a Local Area of Play (LAP) will need to be provided.
Heads of Terms / S106
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Affordable Housing
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Play space / public open space
It is possible that consultees may request other obligations through the application process, which
may need to be secured by s106 legal agreement (for example infrastructure agreed with the
Parish Council, off-site highway works, ecological monitoring, NHS contributions etc).
OTHER RELEVANT MATTERS:
Validation-Information requirements for a planning application:
A significant proportion of applications received by the Council are invalid. This means they do not
contain the necessary information to assess the application and the evident issues.
Therefore, if you choose to submit an application for the proposed development, as set out at the
bottom of the supporting letter, it should include the following (assuming the application is
submitted in full):
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Application form;
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Site Location Plan;
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Site/Block Plan;
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Elevation Plans;
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Floor Plans;
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Section Plans;
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Levels;
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Ecological Report (and any recommended follow reports);
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Flood Risk Assessment including Surface Water Drainage Assessment;
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Draft Local Labour Agreement;
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Design & Access Statement;
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Tree Survey/Report (if any trees are affected by the proposal);
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Planning Statement;
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Sustainability Statement;
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Heritage Statement;
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Transport Assessment;
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Travel Plan;
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Noise Assessment;
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Site Waste Management Plan;
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Nutrient Neutrality and Mitigation Strategy (if cannot connect to mains drains)
In Somerset, we require additional information to be submitted alongside any Biodiversity Net Gain
liable planning application before the application can be validated. These requirements build on
the minimum information required nationally. They are intended to make sure that sufficient
information is available to consider and determine planning applications where Biodiversity Net
Gain is a material consideration.
Local Biodiversity Net Gain Validation Requirements include:
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Wildlife and Ecology Survey
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Biodiversity Checklist
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Arboriculture Report
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Biodiversity Net Gain Statement Template
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Completed Biodiversity Net Gain Metric
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Biodiversity Net Gain plans and drawings
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Declaration Form
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Completed SHEP/HEP Metric (where necessary)
Further guidance on the requirements can be found on the Council’s website:
https://www.somerset.gov.uk/planning-buildings-and-land/information-requirements-for-planning-ap
plications/
This advice is given without prejudice to any future application and is based upon the information submitted
and available at this time, and is not a formal decision of the council.
Since 1st April 2015, Community Infrastructure Levy (CIL) has been charged on liable developments. It is
strongly advised you familiarise yourself with CIL, the types of developments which are liable, and the
process involved. More information can be found at
https://www.somerset.gov.uk/planning-buildings-and-land/community-infrastructure-levy/cil-process-and-for
ms/.