Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4924

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

Representation Summary:

We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date. The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.