Object

Representation ID: 7247

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

This section sets out specific comments on the Sustainability Appraisal (“SA”) prepared to accompany the Local Plan. Paragraph 32 of the Framework 2021states,
“Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements.”
The SA sets out the Sustainability objectives of the Plan and broadly assesses the policies, providing commentary on assessment and site allocations. The SA has not been undertaken on existing policies set to be carried forward. The SA is clearly an interim document and is not sufficient to meet the legal tests for plan making.
De Merke raise concern that the SA has not yet assessed a housing figure that is a result of positive discussion through the Duty to Cooperate process which could significantly increase the housing figure in the Borough.
De Merke look forward to the opportunity to consider a revised version of the SA which appropriately deals with the plan as a whole, including any new or re-imposes BBC existing policies.
At this stage of Plan production, De Merke Estates cannot support the Sustainability Appraisal. Whilst the methodology appears to be reasonable, it is incomplete and not representative of the plan as a whole. Gaining a true understanding of the housing numbers through Duty to Co-operate with neighbouring authorities, including those in the Housing Market Area, is a significant failing of the Council, which is also reflected in the Sustainability Appraisal and its resulting recommendations.