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

Object

Representation ID: 9055

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.1. The Draft Local Plan explains the reason that a Local Plan update is needed is in order to reflect emerging national policies for the Oxford to Cambridge Arc. However the Spatial Framework for the Arc has not been determined by Government. .
“Normally local plans are reviewed every five years but this update is require sooner in order to reflect emerging national policies for the Oxford to Cambridge Arc.”
1.2. Indeed, the Local Plan Inspectors for the currently adopted Local Plan 2030 necessitated an early review of the Local Plan in their Report2. However, it is critical that the context of this conclusion by the Inspectors is understood and appreciated. The Inspectors considered that there was a need for the plan to respond appropriately to longer term requirements, particularly the Arc. It was envisaged by the Inspectors that a review of the Local Plan and any update to it be submitted for examination within three years of adoption would be an ample amount of time for sufficient clarity about the implications (for Bedford and its neighbours) of the Arc to be known to enable such a review.
“Nevertheless, there is a need for the plan to respond appropriately to longer term requirements, and in particular the Arc, as soon as possible. Consequently, notwithstanding the statutory requirement for the plan to be reviewed, and then updated if necessary, within five years of its adoption, it is necessary for a review and update to be completed more quickly. On this basis (and for other reasons detailed elsewhere in this report), MM1 is necessary for the plan to be justified and effective. This requires a review of the plan and any update of it/new plan to be submitted for examination within three years of adoption of the current plan. Based on the discussion at the hearings the three year deadline appropriately balances the need for the plan to be reviewed and updated as quickly as possible with the realities of the time likely to be necessary for the Council to effectively undertake this work.”
“The wording of the policy recognises the need to align strategic growth with the delivery of planned infrastructure and refers to the aspiration of preparing a joint strategic plan in future. These are both appropriate aims and whilst we recognise that the policy cannot dictate the parameters of a future plan, we are satisfied that the wording proposed is effective and justified.”

Object

Representation ID: 9056

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.3. As the Draft Local Plan explains, there still is not sufficient clarity about the implications of the Arc for Bedford Borough and its neighbours including that there is no information regarding housing numbers. BBC stresses the critical need for ‘collective determination over the long-term’ to plan and deliver the right quality and in the right places to meet it needs. BBC explains that it might include the expansion of existing settlements and new settlements but that it will require ‘long-term commitments to provide the enabling infrastructure and to deliver that ahead of the arrival of new communities’. Despite this clear stated need for collective determination for planning at a ‘larger than local’ scale, there is no evidence provided by BBC on how it has worked with any of its neighbours or Duty to Cooperate prescribed bodies which contradicts BBCs identification of the critical need for joint working on what are very complex issues.
many important strategic decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years.”3
“The declaration itself is silent on housing numbers. It recognises that the Arc is first and foremost an area of significant economic strength and opportunity, and through the joint declaration the partners (including the then 43 local authorities across the Arc) set out to meet the Arc’s full economic potential for the benefit of existing and future local communities and businesses, and in the national interest. There is acknowledgement that to achieve this will demand collective determination over the long-term, to deliver significantly more homes in the Arc, of the right quality and in the right places to meet its needs. Also that this might include the expansion of existing as well as the development of new settlements. It will require long-term commitments to provide the enabling infrastructure and to deliver that ahead of the arrival of new communities, and to meet economic and housing ambitions while overall improving rather than degrading the environment in the Arc, in line with commitments in the government’s 25 Year Environment Plan”

Object

Representation ID: 9057

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.4. BBC explains that it plans to make provision for significantly more homes as described in the ‘Arc joint declaration’ by creating an uplift of 33% when compared with the locally-calculated housing growth planned for the Local Plan 20305. This statement by BBC requires much further clarification as it is unclear how an additional 33% is being calculated.
1.5. BBC explains that it must submit the Local Plan Review to Government to Examination by January 2023 or else the Local Plan policies will be deemed ‘out of date’. However, given the circumstances, as explained above the central purpose of requiring the quick review of the Local Plan is due to the Inspectors predicting that the details of the Arc would have been known by this time. In terms of the risk and threat of Local Plan policies being deemed ‘out of date’, recent case law has clarified the position in relation to this point and it is not as black and white as BBC has explained. We consider that this point needs much closer examination by the Council in discussion with the Secretary of State before concluding that the Local Plan must be updated ‘at all costs’ given the current local and national circumstances.

Object

Representation ID: 9058

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.6. As explained above, the Local Plan Inspectors required an ‘early review’ of the Local Plan to deal principally with the strategic issues of the Arc as it relates to BBC and its neighbours, however this is not currently possible as explained above. It seems that the point was to avoid another ‘piecemeal’ review of the Local Plan. Therefore, BBC’s proposed scope of the Local Plan update is difficult to follow. BBC explains that the 2040 Local Plan will be a partial update of existing policies given that it considers the vast majority of its policies are up to date and do not need to change7. BBC explains that the Local Plan update will cover the following:
• Development Strategy to 2040 and delivery of growth in order to meet national policy requirements
• Town centre and retail policies in order to support a more flexible future for our centres with a reduced focus on retailing
• Updated development management policies (those used to help make decisions on planning applications to do with:
o Self-building and custom homebuilding
o Quality of development and residential space standards
o Environmental net gain
1.7. We do not consider it possible to update the entire Development Strategy for the borough as part of partial review to plan for the proposed large scale of growth in the borough with a minimum of 12,500 dwellings and 123 hectares of employment land whilst attempting to align with the emerging strategy for the Arc. BBC should be preparing a full Local Plan Review rather than its current incremental approach which does not allow for long term and comprehensive planning based on effective cooperation which is so clearly needed for the borough and the surrounding area.

Object

Representation ID: 9059

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

2.1. The Draft Local Plan proposes a plan period of 2020-2040. It states:
“A longer timescale would have the advantage of giving certainty for a longer period but… many important decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and long term are likely to be made the next few years. As a result, and having considered the 2020 consultation responses, the Council’s view is that 2020 - 2040 is an appropriate time period for this plan. With a requirement now for five-yearly local plan reviews there will be sufficient opportunity to plan beyond 2040 once the regional planning context is clearer.”
2.2. The New NPPF (2021) requires a minimum 15 year period from the adoption of the Local Plan. BBC’s Local Development Scheme (Feb 2021) indicates a Local Plan adoption date of December 2023 which covers the monitoring period of 2023/2024 so the minimum Local Plan period would end 2038/2039. The proposed Local Plan period would therefore be compliant with the new NPPF (2021) if it weren’t for a new requirement imposed by Paragraph 22 of the NPPF which states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.3. There are a number of options in the Draft Local Plan that do propose ‘larger scale developments’ such as new settlements or significant extensions of existing villages and towns’. In this case Local Plan policies should look further ahead at least 30 years to account for the likely delivery time required for delivering strategic development.
2.4. Therefore, if the Local Plan proposes larger scale developments then the plan and its policies clearly need to develop a vision which covers at least 30 years from the point of Local Plan adoption. If one assumes that the Local Plan adoption date is in 2023/2024 then the policies and vision will need to extend to at least 2053/2054.
2.5. MHCLG introduced this change to the NPPF in response to the Building Better Building Beautiful Commission recommendations to clarify that councils need to take into account the likely timescale for delivery of larger scale developments which, as we explain in our representations, take considerable time to plan and deliver.
2.6. Therefore, the plan period should be changed to 2020-2053. As a result of this change in the plan-period the majority of the Council’s evidence base will need to be reviewed and updated. Given the extent of time that will be required to update the evidence base and proposed policies we suggest that BBC reconsider its timetable for production of the Local Plan so that it can prepare sound evidence base and properly align with the Arc proposals whilst working closely with its neighbouring authorities and prescribed bodies.
2.7. This recent change to the NPPF has all sorts of serious implications for BBC as it prepares its Local Plan and evidence base in terms of transport modelling, infrastructure delivery and phasing and housing and employment delivery. The Council’s stated logic for only planning to 2040 cannot be justified given the Government’s change in policy as explained above. However, it is not just the fact that the NPPF now requires at least a 30 year plan period from time of adoption, this should be a fundamental principle and practice of preparing the strategic plan for the Borough rather than another short term and piecemeal review. This is exactly the short-term approach to planning the Government is seeking to avoid through the new change to the NPPF particularly where larger scale developments are proposed.
2.8. It is disingenuous of BBC to only test the potential new settlements for the amount of development potentially deliverable by the end of the stated plan period (2040). For example the Dennybrook site is tested for 2,500 dwellings in BBC’s Sustainability Appraisal when the site promoters have promoted the site for 7,500 – 10,150 dwellings. The outputs of any evidence base which assesses the site on a fraction (25%-33%) of its promoted potential is clearly not an effective or genuine approach to plan-making.

Object

Representation ID: 9060

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

3.1. Section 33A of the Planning and Compulsory Purchase Act 2004, as inserted by section 110 of the Localism Act 2011 requires the council to cooperate with other local planning authorities and other ‘prescribed bodies’ in preparing and developing development plan documents and other local development documents so far as it relates to a strategic matter.
3.2. Local authorities must fulfil the legal requirement to cooperate with the Duty to Cooperate prescribed bodies by “engaging constructively, actively and on an ongoing basis” on cross boundary strategic matters from the commencement of preparing the Local Plan to submission of the Local Plan to the Secretary of State for examination.
3.3. There is no reference in the consultation documents or the supporting evidence to the ouncil’s legal requirements to discharge its Duty to Cooperate as part of the plan-making process. Given the potential for strategic development proposed in close proximity to neighbouring authorities and clear cross boundary strategic matters one would expect cross boundary working on these matters to be active, ongoing and constructive from the commencing of Local Plan preparation.
3.4. Furthermore, BBC purports its main purpose for undertaking a Local Plan update is to ensure compliance with Policy 1 of the adopted Local Plan. A key part of this policy is where it states that “The review will also serve to build stronger working relationships with adjoining and nearby authorities and may result in the preparation of a joint strategic plan based on a wider geography”. Yet the Draft Local Plan fails to acknowledge how BBC has worked with adjoining and nearby authorities or address whether a strategic plan for the wider geography is still being pursued or has been shelved and any reasoning for this.
3.5. BBC has also failed to comply with the Town and Country Planning (Local Planning) (England) Regulations 2012 which states that:
“(6) Where a local planning authority have co-operated with another local planning authority, county council, or a body or person prescribed under section 33A of the Act, the local planning authority’s monitoring report must give details of what action they have taken during the period covered by the report.”
It is therefore impossible to determine what Duty to Cooperate activities have taken place since commencement of local plan preparation as BBC has not made this information available.
3.6. In any case Planning Practice Guidance (PPG) states that authorities should make any statements of common ground (SOCG) available on their website by the time they publish their draft plan so that communities and stakeholders have a transparent picture of how they have collaborated:
Authorities should have made a statement of common ground available on their website by the time they publish their draft plan, in order to provide communities and other stakeholders with a transparent picture of how they have collaborated.
3.7. There are no published SOCGs with any prescribed bodies for communities and other stakeholders to demonstrate that BBC has fulfilled the legal and policy requirements of Government.
3.8. The PPG explains what a Statement of Common Ground should contain. The PPG also tates that “The level of cooperation detailed in the statement is expected to be proportionate to the matters being addressed. The statement is expected to be concise and is not intended to document every occasion that strategic policy-making authorities meet, consult with each other, or for example, contact prescribed bodies under the duty to cooperate. The statement is a means of detailing key information, providing clear signposting or links to available evidence on authorities’ websites.”
3.9. As there is no mention of cross-boundary strategic matters or joint working in the Draft Local Plan or its supporting documentation, it is impossible to comment on this topic apart from saying that the Council is clearly not discharging its legal Duty to Cooperate as required by Government.

Object

Representation ID: 9061

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

4.1. We bring into question the validity of the methodology and the results of some of BBC’s Draft Sustainability Appraisal. We summarise our points in relation to the Sustainability Appraisal below. Please note, we make extensive representations about the ‘Urban’ component of the Sustainability Appraisal and its Reasonable Alternatives in our ‘Urban and Settlement Capacity section’ – we request that BBC please ensures that those representations are captured in response to the Sustainability Appraisal as well as urban and settlement capacity (including previously developed land) more generally.
• As we state in the Urban and Settlement Capacity section of our representations, it is not reasonable to only show in Option 1a the potential ‘urban capacity’ and ‘adjoining urban areas’ as 1,500 dwellings each giving a total of 3,000 dwellings. As BBC states, these capacity figures are not based on any robust analysis of site availability or development capacity testing therefore this option will need to be revisited once the Council has done a proper capacity study.
• The rejection of Option 1b in the SA has not been justified as the Council cannot conclude that delivering 12,500 dwellings would require ‘extreme densities’ given that the Council has not fully assessed the land available in the urban area.
• If the urban capacity figures were increased to a reasonable level based on sound evidence base, the need to deliver development in less sustainable options such as new settlements or villages would likely not be required.
The SA scores the ‘urban area’ component as ‘negative’ against the air quality objective. It states that “concentrating development of all types in the urban area will mean that remaining areas receive no growth. This will have the effect of concentrating human activity (both long term and short term construction) which is the main cause of poor air quality. Much of the borough will therefore see no worsening of air quality, however the area within the urban area is likely to see worse air quality. This can be minimised with greater use of sustainable transport, which is more likely to occur with concentrated development patterns”16. Apart from being a confusing and contradictory assessment its overall conclusion is poorly considered. Clearly developing in the urban area where facilities and sustainable infrastructure are closest to the population they serve, reduces the need to travel and reinforces important investment in sustainable infrastructure such as Bedford Station and aligns with the Council’s stated Vision and Objectives. We consider this assessment against air quality for this component needs to be revisited.
• We question the SA assessment of ‘new settlements’ component in relation to ‘protect the quantity and quality of water sources’ which scores it as ‘positive’. It states that “locating growth in a few new settlements so that more are unaffected by development is likely to make it easier to protect the quality of water resources”17. We are confused as to the meaning of this statement and how BBC has arrived at such a conclusion.
• It is entirely unclear as to how BBC has merged the 6 development locations into
5. This approach has effectively ensured that the Dennybrook is classified under both point 4 (new settlements) and 5 (rail-based growth).
• Some of the promoted new settlements contain previously developed land whereas Dennybrook does not. We seek clarification as to how this has been taken into consideration in the Sustainability Appraisal as this should be an important factor for the technical assessments undertaken. This point highlights the lack of site specific details contained within the SA about particular sites which leads to the SA amounting to a theoretical exercise in many cases where the important constraints of a site or area have not been taken into account.

Support

Representation ID: 9062

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

5.1. We consider the draft Vision and Objectives to contain a number of important elements for guiding the Local Plan. However, we do consider that the Vision and Objectives, whilst mentioning some local names and places, should be more locally distinctive to give a greater ‘sense of place’ of the borough and the clear vision for its future. It is important it does not read as an ‘anywhere’ place.
5.2. In terms of the important elements of the Vision and Objectives we note that the Vision rightly has considerable focus on the urban areas with a particular focus on Bedford (and Kempston) as sustainable locations to deliver growth, infrastructure and place-making. We also note that there is no mention of the new settlements or urban extensions in the Vision for the borough.

Object

Representation ID: 9063

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

6.1. At the heart of the NPPF is a presumption in favour of sustainable development. Plans and decision should apply a presumption in favour of sustainable development. The NPPF explains what this means for plan-making with making effective use of land in urban areas at the heart of mitigating climate change stating that (our emphasis added):
"all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects”
6.2. Section 11 of the NPPF is called ‘Making effective use of land’. There are a number of important requirements set out in this section of the NPPF for plan-makers including the following:
• “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land”20
• “give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”21
• “promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure)”22
• “Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.”
6.3. Given that the NPPF places such great weight and emphasis on the need to make the most effective use of previously developed land and land within settlements it is surprising how little the Draft Local Plan and its evidence have to say about how the Council intends to comply with the NPPF as part of its plan-making.
6.4. We note that the key point of the Issues and Options consultation was that urban based developed (along with A421 and rail-based growth) was the most strongly supported by consultees:
“The results are reported in full in the Issues & Options Consultation - summary and responses document and the key point was that the (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth.”
“The most common combination put forward by respondents was urban (brown) with A421 (yellow).”
6.5. BBC’s Development Strategy Topic Paper explains that one of the five ‘components of growth’ it has tested is ‘within the urban area (sites within the urban area boundary)’. BBC explains that the Sustainability Appraisal (SA)concluded that the ‘within the urban area’ component performed the best of all of the potential components:
“In relation to the broad components of growth, the sustainability appraisal found that the 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, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth.”
6.6. BBC explains that following the SA work more detailed work was undertaken to generate specific strategy options based on different combinations of the broad components using the remaining housing target of 12,500 dwellings and employment land target of 123 hectares. BBC states that the assumptions had to be made about the capacity of each ‘broad location for housing and employment growth’ however this phrase ‘broad location’ is not explained elsewhere which is confusing. BBC explains that the capacity assumptions are informed not by the Council’s own work but simply through the quantum of development put forward through the call for sites process and that further testing will take place following this current consultation. This is a very important point that the Council has not undertaken any assessment of its own as to the potential development capacity of sites and locations in the borough. It is neglectful of BBC to even consider it possible to assess development strategy options let alone select a number of preferred options without having properly assessed site constraints, the realistic capacity of the sites or broad areas being promoted by developers and landowners.
6.7. Regarding the ‘urban component of growth’ BBC explains that given that it performs most strongly “the assumption for the urban and adjoining areas is deliberately ambitious” explaining that: “Development at scale in some parts of the urban area will be challenging and will require comprehensively master planned proposals and may require land assembly powers and significant investment in the infrastructure necessary in order to deliver the development”
6.8. In the following section of the Development Strategy Topic Paper it summarises the development assumptions for options generation with ‘sites within urban area’ showing 1,500 dwellings. BBC has confirmed to us that this assumption is not based on actual sites in the ‘urban area’ and only based on sites submitted to the Council so this figure is entirely unreliable and seems extremely low. BBC’s options that it tests include this 1,500 dwelling figure for the ‘within urban area’ component of growth for Options 1a, 2a, 2b, 2c, 2d, 3a, 3b, 3c and then show 12,500 for Option 1b. BBC rejects Option 1b as it states that it is “Theoretically possible to meet residential growth needs but the densities required would have unacceptable significant impacts”
6.9. How can BBC possibly come to this conclusion when it has not undertaken its own assessment of previously developed land and settlement capacity for Bedford and the other settlements? In terms of the other options it holds the ‘within urban area’ and ‘adjoining urban area’ at a constant of 1,500 dwellings for each component respectively. There is clearly no logic to the housing numbers and shows a serious lack of sensitivity testing of a range of potential urban and settlement capacity assumptions for the options generated by the Council. Clearly if the ‘urban’ and ‘adjoining urban’ components had higher capacity yields then they would form a greater percentage of the overall housing targets and result in less need for housing elsewhere in the borough including the new settlement options. The performance of any option with an increased urban capacity would increase in terms of its performance in the Sustainability Appraisal given that this is the most sustainable location for BBC to plan its future growth.

INCLUDES TABLE OF OPTIONS FROM P23 OF DEVELOPMENT STRATEGY TOPIC PAPER

6.10. We have so many questions that are left unanswered regarding BBC’s approach to assessing its urban and settlement capacity (and previously developed land) which we set out below:
• What does BBC consider to be the ‘urban area’?
• Does BBC only consider the urban area of Bedford town for its previously developed land capacity?
• Does BBC not consider previously development land in the other settlements in the borough apart from Bedford for its development capacity?
• The NPPF expressly requires that authorities need to make as much use as possible of previously developed and brownfield land in the borough – how can BBC demonstrate that it has made any material steps towards fulfilling this requirement?
• How has BBC taken into consideration the potential release of some of its employment sites for potential housing development? We note that there are at least 16 existing employment sites assessed as ‘monitor and manage’ in the Council’s Employment Land Review. Have these been assumed as part of the potential supply of land that could be identified and released for housing?

Object

Representation ID: 9064

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

7.1. The NPPF requires local planning authorities, through their local plans, to accommodate at least 10% of their housing requirement on sites no larger than one hectare unless there are strong reasons why this 10% target cannot be achieved. The NPPF states:
“Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should:
a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved;”
7.2. BBC states that It will not comply with the NPPF regarding its requirement for identifying small sites as it states it will deliver this through windfall development:
“the Local Plan 2040 will not include allocation policies for small sites simply to satisfy this specific requirement of government policy, as we expect sufficient small sites to continue to be delivered as a result of windfall development. Small sites may however be allocated in accordance with development strategy, once it is finalised.”
7.3. BBC’s Small Sites Topic Paper includes an estimate of their 10% requirement for small sites which estimates 2,550 are required to 2040. It then provides a summary of supply from the following sources in an attempt to demonstrate that it has enough small sites to meet the Government’s requirement.
• Qualifying commitments from monitoring
• Likely supply from Neighbourhood Plans
• Likely supply from windfall
• Potential supply from urban sites in Local Plan 2040

INCLUDES FIGURE 7.1: TABLE FROM SMALL SITES TOPIC PAPER

7.4. BBC provides no background information on any of these assumptions so it is impossible for the reader to verify or not the Council’s assumptions. We request that BBC provides this information and that it is made public as soon as possible
7.5. BBC misinterprets the NPPF which does support the delivery of windfall housing sites in existing settlements through local policies and decisions however this is in addition to the NPPF’s requirement to identify small sites.
7.6. We therefore object to BBC’s proposed approach to small sites as these can form an important component of land supply in sustainable locations. BBC should undertake a small sites study in order to identify at least 10% of its housing requirement on small sites allocations.