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

Representation ID: 4926

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

Representation Summary:

We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our responses to the Site Assessment Pro formas. These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
Finally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.