Object

Representation ID: 4998

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The reasons the Council has not allocated the Site are set out in the Council’s ESES Topic Paper. Fundamentally, the Council considers that these relate to the lack of ‘need’ for additional employment land within the District to meet its needs or the unmet needs of the FEMA and that the Site performs ‘strongly’ against the five Green Belt purposes.

However, Richborough strongly contends that there is a clear and cogent need for additional employment land within the District to meet not just only the District’s own employment needs, but to assist in addressing the acute shortfall arising from the BCAs. Moreover, Richborough considers that it is entirely reasonable, and appropriate, for land which fulfils strong Green Belt purposes to be released where exceptional circumstances are evidenced (i.e., a locational requirement for the logistics sector). The supporting ELNA has clearly shown that there are no other ‘sequentially preferable’ strategic employment opportunities. As such, it is entirely reasonable to release ‘high’ performing Green Belt land at Gailey Lea to address the unmet employment needs of the FEMA.
In addition, the Council’s other reasons for discounting the Site appear to be poorly evidenced, overly critical or could easily be mitigated – as demonstrated in Richborough’s Vision Document for the Site. Indeed, this is clearly shown in the Council’s Reg 19 SA’s testing of Reasonable Alternatives, which shows that, despite the overly critical scoring in the ESES Topic Paper, the Site scores the same as other sites that the Council has elected to allocate in the PP in SA terms.
Therefore, at present, the Council runs the risk of potentially falling into a position where either the evaluation of reasonable alternatives in the SA and Site Selection Process could be interpreted to either have not been undertaken properly or to have been ‘improperly restricted’, in the context of the iterative process necessary for progressing a plan.
To this end, it is clear that through a future Local Plan Review the Council will need to release further employment land, either to address wider FEMA needs or the District’s. As shown in the ELNS Alternative Site Assessment, there are limited options for meeting these long-term needs outside of the Green Belt, by virtue of a majority of the sites that are adjacent to the SRN being within the Green Belt. As such, the permanence of the Council’s currently proposed Green Belt boundaries is in doubt, as it is very likely that the Council will again need to revisit releasing Green Belt land in due course. In this regard, the identification of additional safeguarded land will ensure that Green Belt boundaries will not need to be altered at the end of the plan period. Indeed, this is an approach that the Council has previously adopted in the current Core Strategy (2012) (i.e. Policy GB2: Land Safeguarded for Longer Term Needs). Therefore, at the very least, Richborough considers that a reasonable alternative to allocating the Site in the current Local Plan Review would be to safeguard the land for future development. This approach would be entirely in accordance with the NPPF and will ensure that the Green Belt boundaries will not need to be reviewed again until the end of the next plan period (Para 143c, NPPF).