Object

Proposed Submission Core Strategy

Representation ID: 20835

Received: 03/11/2011

Respondent: Friends, Families and Travellers

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We object to several of the criteria on the grounds that they conflict with national policy (circular 1/2006)and are unduly restrictive and not justified or effective.

Full text:

Criteria in Policy LHN6
We object on the basis that some of the criteria are in conlfict with Ciruclar 1/2006 and are unduly restrictive and not justified or effective.

1. The stricture that the site is not located in a nature conservation area does conflict with para 53 of C 1/2006 (which still stands) which states that local nature conservation designations should not in themselves be used to refuse planning permission for sites.

2. Flood risk - this quite properly excludes sites from high flood risk but does not take into account the problems associated with EA mapping which are sometimes found to be wrong. This does not accord with a risk based approach and should be amended to states that where a site is in an area liable to flood as indicated in the EA Maps permission should not be permitted unless a flood risk assessment indicates otherwise. This would give applicants the opportunity to challenge the validity and reliability of the EA mapping system.

3. Whilst location close to or within an existing settlement is a laudable aim this may not be achievable in practice and may exclude otherwise suitable sites. A more reasonable approach to sustainability issues is required in line with para 54 of C 1/2006.