Object

Representation ID: 5043

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 12
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 approach being taken within the emerging Local Plan will worsen the effects of the Urban Heat Island Effect and cause increased levels of surface water run-off (creating flood risk pressures), given that greenfield sites (green space vegetated surfaces) within the open countryside will be replaced by heavily urbanising brick, concrete, tile and macadam surfacing. We have concerns that the Council appears to have no understanding of the urban heat island effect or surface water run-off issues.
The position is perfectly clear, the emerging Local Plan Review will promote highly damaging and unsustainable patterns of new housing and employment land development across the district, contrary to the ‘Sustainability’ test of ‘Soundness’ as reinforced in paragraph 35 (indent d) of the Revised NPPF (2021). The Council is taking forward an unsound Local Plan Review.