Object

Representation ID: 1802

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

Duty to Co-operate Statements: The Council has failed to prepare a Statement of Common Ground (draft or finalised) contrary to PPG requirements. Unclear how legal test of ‘constructive and on-going’ engagement has been met.

Sustainability Appraisal (SA):
Reasoning behind post-mitigation scores is not clear. Question the relevance of Green Belt in landscape objective as it is not a landscape designation. Previous proposals and inspectors decisions (06/00638/OUT) indicate Site 170 would not have significant landscape impacts and score should be ‘neutral’.

Any potential noise, air and water quality effects can be mitigated through design on Site 170, so the sites score against pollution and waste should be ‘neutral’.

Site 170 is incorrectly classified as BMV agricultural land, with no evidence that it is Grade 3a. No score should be applied against natural resources given errors in methodology.

Under health and well-being, dispute the finding that Site 170 is over 800m from a GP surgery due to distance indicated on Google maps measurement tool (710m).

Transport and accessibility: 800m is a more appropriate catchment for a bus stop, in accordance with Manual for Streets and the national definition of walkable neighbourhoods. The SA incorrectly concludes Site 170 is over 2km from a convenience store.

For education a higher threshold of 3 miles should be applied for secondary education to reflect Department of Education guidance.

The Hansen scores in the RSFA indicate Featherstone is in the upper half of Hansen scores (i.e. ‘medium’ access to employment), and this has not been correctly reflected against Site 170 in the SA.