Object

Representation ID: 7316

Received: 02/09/2021

Respondent: Miss Emma Pegler

I refer to the National Planning Policy Framework. It places great emphasis on the need to make the most effective use of previously developed land and land within settlements. The Draft Local Plan needs to provide evidence as to how the BBC will comply with the NPFF.

BBC has not undertaken any assessment as to the potential development capacity of sites in the Borough. It is not appropriate nor transparent to select preferred options without properly having assessed the capacity of the sites being promoted by developers and land owners who will make considerable money out of these ventures. Why is BBC not doing any assessment of its own but is saying that the capacity assumptions are informed NOT by the Council’s own work but through the quantum of development put forward through the call for sites and then there will be further testing. Why are we asked to comment on theoretical assumptions and not hard fact? That is not transparent. Further if the assumptions prove not to be correct, BBC cannot rely on any feedback given at this stage and will have to have further consultation with failure to do so being at best a lack of transparency could be challenged legally.

BBC’s Development Strategy Topic Paper states that one of the 5 ‘components of growth’ it has tested is ‘within the urban area (sites within the urban area boundary)’. BBC states that Sustainability Appraisal concluded that the ‘within the urban area’ component performed the best of all of the potential components….”within the urban area component performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth…”

It therefore follows that a development like Dennybrook which is miles away from a town centre that requires cars to get anywhere (see my later comments on the fact it is too far to walk or cycle to amenities and stations) is completely contra to those statements and should not be supported. These findings must be addressed as they are absolutely key to the future of the county and the country and we should not be making short term decisions on housing to the expense of the overall agenda for reversing climate change and promoting sustainability. I cannot see why we would not target smaller pockets of growth in a sustainable way instead of paving over large tracts of prime agricultural land. We should look at already developed land and urban areas and smaller developments and BBC should be aware that it has to address these inconsistencies in its approach.

Further the NPPF expressly requires that the authorities need to make as much use as possible of previously developed and brownfield land in the Borough. BBC needs to demonstrate that it has made material steps towards fulfilling this stipulation.

BBC has not taken into consideration the potential release of a proportion of its employment sites for potential housing development eg the existing employment sites assessed as ‘monitor and manage’ in the Council’s Employment Land Review.