Object

Representation ID: 5040

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 4
By promoting heavily urbanising major residential development across sensitive greenfield sites within areas of open countryside, we maintain our view that the Publication Stage Report (November 2022) is promoting inappropriate, damaging and unsustainable patterns of development within the district, in direct conflict with sustainability development focused guidance reinforced in paragraphs 7, 8, 10, 11 (indent a), 16 (indent a), 35 (indent d), 38, 119, and 120 (indents d and e) of the Revised NPPF (2021).
The proposed housing sites within the Publication Stage Report (November 2022) are proposing a net site density level of 35 dwellings per hectare (dph) across sensitive greenfield sites. This is fairly high-density residential development for these sensitive greenfield sites within the Green Belt countryside, and will therefore result in future new housing development site layouts coming forward which would be heavily urbanised and therefore fail to deliver any meaningful on-site biodiversity/ nature conservation enhancement features and climate change mitigation benefits.
The ongoing failure and continued refusal to promote the most sustainable patterns of new housing development across the district, means that the emerging Local Plan Review is therefore vulnerable to potential future Legal challenge at the later Examination in Public (EIP) stage - against the ‘Sustainability tests of soundness’ for Local Plan preparation, as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).