For your information I have submitted my response to the draft SADPD which can be found on the Council web site at:
In the first instance you need to register and then complete the form. There is no need to hurry this as it can be saved as a draft and then submitted once you are satisfied with your response, but you MUST reply before MONDAY 27th FEBRUARY 2012.
I believe that as many as possible need to make a submission as this will be the only route considered by BFBC or the Inspector.
My own response has been given below and I hope that you will all follow suit and encourage as many as possible to do the same.
Site Allocations Development Plan Document Draft Submission
Question 1 – Do you consider the Draft Submission Site Allocations Development Plan Document to be legally compliant? (Please refer to section 2 of the guidance notes)
Question 2 – Do you consider the Draft Submission Site Allocations Development Plan Document to be: (Please refer to section 3 of the guidance notes)
Question 2a – Why do you consider the Draft Submission Site Allocations Development Plan Document to be unsound?
- Not effective
- Not justified
Question 3 – Why do you consider the Draft Submission Site Allocations Development Plan Document not to be legally compliant or to be unsound? Alternatively, if you wish to support the legal compliance or soundness of the document, use the same box to set out your comments. Please be as precise as possible.
I would object to the proposed SADPD on the basis that it is neither legally compliant nor sound.
The proposed SADPD cannot be considered legal for the following reasons:
- The proposal is one of the most wide ranging and damaging that has been put forward and will adversely affect generations to come. There has been insufficient public consultation and most residents are not aware of the proposals.
- There has been very limited consultation with adjoining Borough’s and as a result the present proposals are complex, overlapping and in many instances not necessary.
- The Council has chosen to ignore the signed protest of more than 3,000 residents and as a result any involvement with the community must be considered as a sham. Public consultation has been complex and residents have not been sufficiently informed. For example during door to door surveys, most residents in Warfield were unaware of Council proposals to build on Cabbage Hill.
- The present Council is planning to overturn the Section 25 Agreement on Blue Mountain against the wishes of the vast majority of residents and this agreement was specifically put in place to protect the rural nature of the area and the green gap.
- Residents have been expected to read 41 documents containing 262,674.38Kof data in only 4 weeks. This is insufficient time to read and understand such a complex series of documents and as such cannot be considered as a public consultation.
The proposed SADPD cannot be considered sound for the following reasons:
- The plan is neither robust nor credible. By their own admission the Council have no funds available to undertake the necessary infrastructure works and as a result any proposal cannot be considered credible.
- The plan has not taken into account all other alternatives, many of which have been put forward by residents. As example there is about 1.5m sq ft of empty office space which is not being considered for housing development or educational use. Land offered in the south of the Borough was not considered even though it was both available and uncontentious.
- The plan is not deliverable not least because the Council do not own the land they are offering for development and owners have not agreed to sell.
- The Council have admitted they have no funds for the necessary road works and as a result the plan cannot be delivered.
- The proposed SADPD is inflexible and wholly reliant on building on green land. Brown land has not been well considered within the proposal. This will affect generations to come and such development is irreversible.
- The Council are defying their own policies by planning to build on the green gaps which separate the town from villages.
- The Council is flagrantly planning to destroy open countryside which is contrary to their environmental policies.
- Plans for local services to support any new housing are insufficient and undeliverable. This Council has a record of not providing services or infrastructure to support development and residents are very wary of their ongoing broken promises.
- The case for providing additional educational facilities cannot be justified when the Council have over 1,000 places which were available 7 years ago and have now disappeared. The location of the planned facilities are not within reasonable distance of the planned new housing and will add an unnecessary strain on an already overcrowded road system.
- There is no justification for constructing a football stadium on the existing golf course and undue vested interests should be closely examined in this regard. Alternative viable suggestions to locate the football stadium have been ignored.
- The Council have not pursued the development of homes in the town centre or on brown land and by their own admission many of the planned homes on green areas can be absorbed in these areas.
- The Council have not taken into account the dramatic change in the economy and most residents feel that the planned homes are not necessary.
Question 4 – What change(s) do you consider necessary to make the Draft Submission Site Allocations Development Plan Document legally compliant or sound, having regard to the test(s) of soundness. You will need to say why this change will make the document legally compliant or sound. It would be helpful if you could put forward your suggested revised wording of the policy or text. Where a change relates to a map or the Proposals Map it would be helpful if you could submit a drawing to show the suggested change. Please be as precise as possible.
See previous comments plus:
- The SADPD does not take into consideration changes in the economy and one of the largest falls in house purchases since records began.
- Under the SADPD the planned number of houses cannot be justified given the current availability in the market. The number of houses needs to be reduced.
- The Council have no funds for infrastructure works. A viable plan for providing essential services must be made available and be justified.
- The SADPD does not take account of using available brown land and has focussed almost exclusively on green land for new development. This is contrary to the Council stated objectives and will be a blight for generations to come.
- The Council has not adequately consulted with neighbouring Boroughs and this is resulting in duplication and inadequate infrastructure.
- The Council is planning to break legal commitments and agreements previously made with residents to protect green gaps, preserve open countryside and retain recreational facilities.
Question 5 – If your representation is seeking a change, do you consider it necessary to participate, in person, at an examination session(s)?
Yes, I wish to participate in person at an examination session(s).
Question 6 – If you wish to participate at an examination session(s), please outline why you consider this to be necessary:
I do not consider that my elected representatives are either credible or genuinely wish to make changes. As a result they will acquiesce with the current proposals and not put forward any counter argument.