Object

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

Representation ID: 8854

Received: 29/09/2021

Respondent: Mr Alex Simpson

Agent: Bidwells

Representation Summary:

The Site Assessment process to date has not been thorough in terms of the assessment of the suitability of sites and in the general conclusions reached.
6.2 The site assessment forms have not been underpinned by a detailed review of the evidence available to the Council. For example, the site assessment form for Site ID 1337 states that the site “has the potential to cause very high harm to a heritage asset”, however, this site submission was accompanied by an initial heritage appraisal which has not been referred to in the response and does not recognise the conclusions stated. No evidence to disregard the conclusions of the heritage appears to be provided, calling into question the justification for such a conclusion by the Council.
6.3 The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. For example, in relation to Site ID 1332, it states in 11a of the site assessment that “the majority of the site is within flood zone 2.” However, as noted in the original Call for Sites submission, whilst it is recognised that some of the site is located outside of Flood Risk Zone 1, there is a significant area outside of this and it will be possible to focus development in such locations, with potential enhancements to flood risk overall. This is recognised in the recent changes to the NPPF (2021) at Paragraph 161c which state that opportunities within new development should be used to reduce the causes and impacts of flooding.
6.4 Generally, a more detailed and informed assessment of all sites is necessary before any site selection process is undertaken. Each site should be properly assessed and a firm conclusion reached on whether key areas such as highways, heritage, noise, etc. are an insurmountable issue or not, with conclusions backed up by an evidence base. Without this, the process is not sound.
6.5 Additionally, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer. For example, as a result of the potential scale of development proposed, the larger site (ID 1332) has the ability to accommodate new local services such as a convenience store, local sports centre or health centre and play a significant role in supporting the viability of existing services.
6.6 Generally, there should be a greater degree of transparency in the site assessment and selection process – it is noted that plans in other local authorities have been brought down in recent years for failure to do this on the basis that it undermined the conclusions made.
Summary
The site assessment process should thoroughly assess the suitability of sites reaching conclusions on key areas of interest and should draw upon all available evidence to substantiate the information. This should allow proper consideration of site suitability.