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Representation ID: 8987

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

4.1 From an initial review of the potential employment sites submitted to the Local Planning Authority for consideration, the conclusions to not appear to be underpinned by a detailed evidence base or all of the available to the Council.
4.2 The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. 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. Additionally, and importantly, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer.
4.3 The assessment process for sites should be thorough and draw information from an existing evidence base held by the Council. To be sound, and justify the selection of sites, there should be a greater degree of transparency in the site assessment process. This is an important consideration as it is noted that plans in other local authorities have been found unsound in recent years due to the failure to justify decisions and properly back up why certain sites have been chosen over others.
4.4 With regard to the land at Manton Lane, the only constraint to development is the historic use of the site as a sports pitch – the development of which could trigger a Sports England objection. This is effectively a policy constraint and should not be a reason for not allocating the site which is otherwise suitable for development.
4.5 On the site proforma, there are unsubstantiated references to potential harm to unmanned heritage assets. It is unclear what these assets are and how the conclusion has been drawn and indeed whether they take into consideration the impact of building out the consented school on the heritage assets. Similarly, there are ‘uncertain’ conclusions around matters such as ecology and biodiversity. These are examples of where the Council will need to commission further evidence to fully assess sites and enable a robust consideration of alternatives.
4.6 The benefits of allocating the site should also be recognised in the assessment process, particularly the fact that the use of the site can effectively replace the employment land lost to the approval of a secondary school on the adjacent site.