We notice this consultation on site selection criteria was not included in the Council’s recently published Local Development Scheme (LDS). The LDS also lacks detail concerning its content, timing and who will be consulted at each stage of plan making. The Inspector involved with examining the Council’s withdrawn Development Strategy criticized the Council’s consultation process. A detailed LDS would help counter this criticism and contribute to improving the quality of comment from public and statutory consultees. We have alerted statutory consultees to this consultation of which they were unaware.
The Council’s approach to this consultation is dubious as a ‘call for sites’ is running in parallel with this consultation. Clearly this approach allows the Council to change its site selection criteria to favor sites emerging form its ‘call for sites’. We also note sites identified during the making of the Council’s Development Strategy will be subject to these selection criteria. It is unlikely many of these sites will be deselected as the Council’s ability to deliver a 5 year land supply will be adversely affected. So this consultation is a sham.
Size of Site; this criterion will mean a site of less than 10 dwellings will be excluded from selection. This criterion does not define a maximum amount of land required to accomodate 10 dwellings. We are concerned this will lead to the profligate use of land in high quality landscape areas, the Green Belt and the Chilterns Area of Outstanding Natural Beauty (AONB). This will occur because developers will not want their sites excluded because they are too small to accommodate the size of dwellings they want to build. The larger the dwelling the more land is required to build 10 of them. We recommend sites of 10 dwellings or less are not excluded from selection and a maximum area of a 10 dwelling site is set so ‘land hungry’ sites at inappropriate locations are excluded from selection.
Flood Risk; we are concerned this criterion will mean 50% of an unspecified size of development site cannot be excluded from selection. The Council has not specified the method it will use to assess flood risk. We recommend the Council uses the method found here at http://planningguidance.communities.gov.uk/blog/guidance/flood-risk-and-coastal-change/the-aim-of-the-sequential-test/ and here at https://www.gov.uk/guidance/flood-risk-assessment-the-sequential-test-for-applicants
Nationally Significant Designations; the nationally significant Green Belt designation is not included in this criterion. This will mean a proposal for an inappropriate development site within the Green Belt cannot be excluded from selection. We recommend Green Belt is recognized for what it is a nationally significant designation and therefore an exclusionary criterion.
We are concerned this criterion will mean 50% of an unspecified size of development site within the Chilterns Area of Outstanding Natural Beauty cannot be excluded from selection. As well this criterion would allow development to abut this AONB adversely affecting the character of its setting.
This criterion will exclude from selection development sites within a Site of Special Scientific Interest (SSI). We recommend the criterion should also exclude a development site from selection if it is adjacent to a SSSI and adversely affects the environment that sustains the sites special characteristics.
Brownfield Land; unlike the Green Belt – the Chilterns AONB, SSSI’s, County Wildlife Sites and heritage assets – brownfield is not a designation. Previously developed land in the Green Belt is Green Belt. We are therefore concerned this criterion will mean a new site on previously developed land within the Green Belt cannot be excluded from selection.
Community; the Council has not specified a criterion for assessing community support for a site in a designated Neighborhood Plan area. We recommend such sites are excluded from assessment until a Neighborhood Plan is supported by a referendum.
Agricultural Land; we are concerned this criterion will mean 50% of an unspecified size of development site on agricultural land grades 1, 2 and 3a cannot be excluded from selection.
We are disappointed there is no exclusionary selection criterion to protect nationally designated heritage assets, ancient woodland and footpaths.
Feeding into the ‘call for sites’ selection process is a Strategic Green Belt Review. We strongly object to need for a review. The Green Belt is immutable and is fulfilling its purpose. It is a justifiable constraint on urban sprawl. Urban sprawl is manifest in Central Bedfordshire on the Green Belt North of Houghton Regis. The Council has chosen to needlessly undermine the Green Belt and its prestigious Chilterns AONB contrary to the will of people who live in Central Bedfordshire.