Proposed Submission Development and Site Allocations (DaSA) Local Plan

Site BEX3c is allocated for development in the proposed submission version of the DaSA. As detailed in section 3, the Site constitutes an area of 8.8ha to the north of the settlement of Bexhill, south of the recently constructed NBAR, and has been identified as a draft allocation in the Regulation 19 Proposed Submission Consultation of the DaSA. The allocation of the Site under Policy BEX3c: Land east of Watermill Lane sets out that the site is allocated for housing ("some 150 dwellings") and open space.

The allocation of this site is supported. The site is located in a sustainable and accessible location, with a direct relationship with the existing residential development of Bexhill and the wider north east Bexhill strategic growth area. The existing topography presents a site that is enclosed by natural landscape features and one that would not negatively impact upon the wider countryside.

There are, however, two technical amendments that we wish to see:

1) Removal of gypsy/traveller section on draft allocation site BEX3c

The allocation of Site BEX3c includes the provision of up to five gypsy and traveller site pitches for permanent residential use by gypsies. This aspect of the allocation is sought to be removed for three primary reasons:
i. the proposed gypsy and traveller pitches are not distributed evenly across all proposed allocations;
ii. there is insufficient evidence indicating that any Gypsy and Traveller pitches are necessary;
iii. The site of the allocation is the same as the location of an area of mitigation/compensation approved as part of the NBAR planning application.

The inclusion of all Gypsy and traveller sites on one prospective allocation site is an unbalanced approach that will not allow for integration, creating a clustering effect that would be detrimental to both the travelling community and local residents. If they are proven to be needed, the provision of a number of smaller sites across various site allocations set out in the DaSA would allow for a better approach to integration with the local community and allow an even distribution of traveller pitches, ensuring that not only were all sites close to amenities, but no amenity provider was overburdened.

The allocation of Gypsy and Traveller pitches on site BEX3c would be fundamentally unsound as the proposed allocation of part of the site for such pitches has not been based upon any recent evidence that details specific Gypsy and Traveller need. The evidence that has been submitted in association with the DaSA dates from 2011 and refers to Planning Policy Statements and Planning Circulars - both of which pre-date the current National Planning Policy Framework and are therefore out-of-date. As a clearly outdated piece of evidence, it cannot be relied upon to be indicative of any current or future need.

The construction of the NBAR was approved under application RR/2015/2260/P. As part of the application an Ecological Design Strategy showing a landscape and ecological mitigation plan was required as part of the pre-commencement conditions. This was submitted and approved. As part of this, Drawing (08)011 Rev.B Landscape Masterplan - E3 Specification for mitigation/compensation (Figure B.2.1) clearly shows the location of Native Broadleaved Wet Woodland Planting on the area that has been identified for the Gypsy and Traveller pitches. Therefore allocation of this site for development of Gypsy and Traveller pitches would be in direct conflict with the approved Ecological Design Strategy & Biodiversity Monitoring Strategy (March 2017) submitted and approved under application 2015/2260/P for the NBAR.

2) Allocation of land to the north of the North Bexhill Access Road (NBAR)

In the representation made to the regulation 18 DaSA, land to the north of the NBAR was highlighted as being suitable for inclusion as a site allocation, however it has been overlooked in the Proposed Submission version of the DaSA. Given the additional need for housing allocations in the DaSA, as identified and set out in the first part of this section, and the sites availability within the first five years of the plan period, it would be erroneous to not include land to the north of the NBAR as a further site allocation in the DaSA.

As set out in section 3, the site consists of approximately 4.6ha, is bounded to the north and east by ancient woodland, to the south by the NBAR, and is in flood zone 1. The proposed masterplan for the site includes development of housing and the development of community sports facilities. This would entail the development of approximately 25 units on the eastern portion of the site, with a cricket pitch and associated pavilion on the western part of the site.

The need for a ground for the cricket club has been identified in the DaSA, in particular in paragraph 9.13, where the specific needs of Sidley Cricket Club are identified. The supporting Sidley Sports Ground Feasibility Study, that has been prepared as part of the evidence base for the DaSA, identifies that the Sidley sports ground has been closed and a number of sports teams have been forced to relocate outside of the District on order to continue operating. Redevelopment options for the sports ground have concluded that an artificial turf football facility would be the most beneficial development on the site. However, this results in the playing surface being unsuitable for cricket, and there remaining a need for a cricket ground. The allocation of the land to the north of the NBAR would enable this community facility to be accommodated and the retention of Sidley Cricket club in the local area. If the site were to be allocated and the residential development of 25 units on the northern part of the site to go ahead, it would enable the cricket ground to be gifted to the community and enhance the recreation facilities available to the local population.

The erection of the cricket ground on the west of the site and the modest element of housing on the east would enable the open nature of the west part of the site to be maintained, whilst making best use of the available land resource to the east which is more naturally screened from wider views and therefore readily able to contribute towards the much needed housing supply.

Whilst the newly constructed North Bexhill Access Road has been identified in the DaSA paragraph 9.17 as "a clear edge between the urban area and the countryside to the north", it is a man-made boundary. The stronger, more defensible natural boundary that exists to the north of the road - the area of ancient woodland - which would provide a more robust and natural feature and would provide a natural limit for the settlement boundary. In the Core Strategy (2006), it is set out in paragraph 10.19 that "development to the north and north east of Bexhill should plan for the creation of a robust, long-term urban edge, with development contained from the wider countryside setting by well-defined topographical and landscape features."

Accordingly it would be in keeping with existing approaches and a far more logical step to include the site as part of the allocations of the DaSA through extending the settlement boundary to the edge of the woodland area, utilising a natural landscape feature of ancient woodland to set a firm, defensible boundary.

Additionally, the road need not be seen solely as a boundary and a limiting factor in development to the north, as it could readily operate as a spine road providing access to both its northern and southern sides without impacting upon the traffic flows through the area. A Highways Access report has been prepared by GTA Civils (August 2018) that has examined the capacity of the road and its ability to effectively service development to the north of the road. The road has been designed and built to be 'future proof', and is capable of a far higher vehicular capacity than is currently being proposed/operated. This has been reinforced in the Highways Access report, which has found that trip generations from the proposed development would have no material impact on the operation of the highway network.

The Highways Capacity Assessment Report that has been produced as part of the evidence base of the DaSA has identified that scope to increase road capacity within Bexhill is limited, and therefore further development within the existing urban area, through densification or other means, will lead to additional pressure on the road networks. Development on a well screened area that is in a sustainable location with good access to public transport networks would therefore make best use of existing land and help to accommodate an identified and much needed community facility.

It has already been highlighted as being available and developable within the first five years of the Plan period, and would utilise the newly constructed the NBAR as its means of access.

A precedent for development to the north of the NBAR has already been set, as Outline Application RR/2017/2181/P for uses B1 and B2 includes development to the north of the NBAR close to the junction of Combe Valley Way in a well screened location. The allocation of land to the north of the NBAR as detailed in these representations would also be in a well screened location with a strong natural boundary.

The Bexhill development boundary does not go far enough. It does not include the land to the north of the NBAR which was submitted to the Local Plan and representations made in support of at the regulation 18 round of consultation.

Accordingly the proposed Bexhill settlement boundary should be revised to include the land to the north of the NBAR. This amendment would enable the provision of an additional 25 dwellings that will further ensure that the plan is robust against any increase in housebuilding and enable the provision of a new cricket pitch for Sidley Cricket Club.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policy DHG 3 states that the Council adopts the Government's nationally described space standard, and that all new dwellings should provide adequate minimum internal space in line with the standard.

This policy is objected to, as there has not been an appropriate evidence base provided to properly set out why this is necessary. Planning Practice Guidance Paragraph: 020 Reference ID: 56-020-20150327 sets out what is required of a local authority in order to adopt internal space standards.

"Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:
* need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.
* viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.
* timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions."

The DaSA and its associated evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. The Space Standards Background Paper (October 2018) identifies the PPG paragraph set out above, but then does not appropriately consider any potential impact upon meeting demand for starter homes. The report also sets out clearly in paragraph 4.1 that "The Council does not collect and record data on internal floorspace as there has not previously been any adopted space standard within the District", and that in order to make an assessment of space standards an audit on 19 housing schemes within the "District was undertaken to identify the average unit sizes of new-build properties using Energy Performance Certificates (EPC)".

Based upon this methodology, the report states that "Overall compliance with the internal configuration within the Nationally Described Space Standards (NDSS) fares poorly" however paragraph 5.5 states that "Whilst the headline indicates that the overall compliance against the NDSS appears to be poor, Figure 5 shows that the average amount that non-compliant dwellings actually fail by is relatively small. Generally, compliance against the other requirements of the NDSS is 2 m or 2sq.m or less, meaning that minor internal changes to the layouts would likely result in compliance with the standards."

The evidence base therefore shows that in the very small survey sample taken, it is by only an extremely small amount that the space standards are not met, and that this can be addressed simply through internal reconfiguration. There is therefore no indication that houses are being constructed of a size that is fundamentally too small and a need for the implementation of the NDSS exists. Given that the 'research' takes no account of existing and historic compliance and does not provide a complete picture of the current situation across Rother, the adoption of the NDSS as policy is not sufficiently supported by the evidence base and is fundamentally flawed.

Therefore, until such time as a suitable and accurate evidence base has been researched and developed, the inclusion of the space standards as policy should not form part of the plan.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policy DHG4: Accessible and Adaptable Homes (Objection)

Policy DHG4 states that "the Council adopts the Optional Buildings Regulations for Accessible and Adaptable Homes" and that "All dwellings are required to meet M4(2): Category 2 - Accessible and Adaptable Dwellings." "Only in circumstances where it can be robustly demonstrated by the applicant that it is not practicable or financially viable to deliver the provisions above or where the requirements are clearly incompatible with conserving and enhancing historic character, will new development be exempt from either or both of these policy requirements."

This policy is objected to. The DaSA and its associated evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. Planning Practice Guidance Paragraph: 007 Reference ID: 56-007-20150327 sets out that the need for M4(2) and M4(3) must be demonstrated, as these are optional standards above the mandatory M4(1).

"There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:

the likely future need for housing for older and disabled people (including wheelchair user dwellings).

Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).

the accessibility and adaptability of existing housing stock.

how needs vary across different housing tenures.

the overall impact on viability.

An "Accessible and Adaptable Housing" Background Paper has been prepared by Rather District Council as part of the evidence base seeking to support the application of this policy. It provides evidence from a number of sources, including census data. Local Authority Housing Statistics, and household projection figures. However, the conclusions drawn from the supplied evidence amount to nothing more than conjecture.

The evidence provided shows an indication that the population across Rother will be an ageing one across the plan period, replicating the national trend. However, the implementation of the optional standards above and beyond the mandatory standard is an excessive step that does not account for the many older people who will find the higher accessibility standard that is detailed in M4(1) to be perfectly accommodative of their needs.

It is recognised that an assessment on the viability of the proposals has been conducted as part of the sustainability appraisal produced assessing the DaSA. However, there is a lack of supporting evidence, most notably a lack of evidence with regard to the existing housing stock and needs within different tenures that supports the other criteria set out in the PPG.

Therefore given the current supporting evidence base, policy requiring all new homes to be built to the requirements of M4(2) and 5% at M4(3) are insufficiently supported by the provided evidence. Therefore the Policy should be considered unsound and the requirement removed from policy.

Please see attached full representation for further information.

Policy DHG6: Self-build and Custom Housebuilding (Objection)

Policy DHG6 sets out that the Council will "support Self and Custom Housebuilding projects subject to compliance with other relevant Local Plan policies" and that "On sites of 20 or more dwellings, provision for 5-10% of the total number of dwellings to be provided should be made available as serviced plots for self and custom housebuilders."

This policy is objected to, as the provision of 5-10% of the number of dwellings on a development site to be provided as plots for self and custom housebuilders is contrary to national policy. National Planning Policy Guidance Paragraph: 025 Reference ID: 57-025-201760728 provides guidance on how Local Authorities can increase planning permissions for self-build and custom housebuilding. This states that local authorities should look to use their own land, engage with landowners who own sites (encouraging them to consider self-build and custom housebuilding), and working with custom build developers to maximise opportunities. It is acknowledged that the PPG states that increasing the proportion of self-build plots through policy is also noted as a suitable avenue to pursue, but It would be contrary to the guidance as a whole to enforce a percentage of plots to be brought forward as self-build housing, when guidance encourages a more co-operative process of engagement as opposed to imposition.

Irrespective of the contradictions with National Guidance, the policy is fundamentally unsound as there is insufficient evidence provided to supports the provision of such a level of plots for self-build. If the Council believes that there is a level of unmet need and that policy must be implemented in order for it to be addressed, then there needs to be sufficient evidence to support both the provision of plots but also evidence that such a provision will be taken up by those seeking to self-build.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policy DHG7: External Residential Areas (Objection)

Policy DHG7 "External Residential Areas" seeks to provide policy guidance on private external space, car parking and storage, waste and recycling. The section of policy that causes the most concern is part (i) Private External Space. This sets out that for dwellings, private rear garden spaces of at least 10 metres in length will normally be required.

Whilst it is acknowledged that there are good intentions behind this policy through ensuring the 20-22m gap between habitable rooms is readily maintained, and it is agreed that a suitable amount of amenity space should be included for private dwellings, the policy fails to recognise the variations in homes, sites, and the fact that not all homes can accommodate a 10m length garden.

Therefore this policy would best be amended to utilise a figure of area (such as 30sqm), which would be more suitable, and would allow developers more flexibility to deliver sufficient outdoor amenity space in line with policy.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policy DIM2 (Support in principle, amendment required)

Draft policy DIM2: Development Boundaries sets out that development shall be focused within defined settlement boundaries. These representations support the approach of development within the settlement boundary, with particular support given to the amendment of the settlement boundary of Bexhill to include site BEX3c. However, this representation seeks a technical amendment, as the extension does not go far enough.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policy DRM3: Energy Requirements (Objection, requires technical amendment)

Policy DRM3 states that the extent to which a proposal incorporates renewable and low carbon energy technologies will be a factor weighing in the favour of a proposed development", and that "Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floorspace should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement."

This policy is considered to be an onerous and unnecessary obligation. The commitment to seeing a low carbon and renewable energy contribution is acknowledged as being well-intended, but in practice can lead to the dismissing of best practice energy efficiency techniques. Elements such as robust details, triple glazing, or efficient heating and ventilation systems are all more in keeping with the principles of sustainability as set out in the NPPF and are proven to be readily effective, but are often dismissed as not being not renewable or low carbon.

Therefore, policy DRM3 would benefit from additional wording along the lines of "The extent to which a proposal incorporates renewable and low carbon energy technologies alongside best practice efficiency techniques will be a factor weighing in the favour of a proposed development."

The supporting text for Policy DRM3 also identifies that Core Strategy Policy SRM 1 already promotes renewable energy through its requirements for an energy strategy on residential developments of 10 or more units, and that these thresholds should be reviewed as the requirements for an energy strategy can be onerous. These requirements as set out in SRM1 are onerous, and would greatly benefit from a prompt review.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Policies Map (Support in principle, amendment required)

It is proposed to update the Policies Map to amend the settlement boundaries and account for the new proposed allocations across the District. Accordingly these representations support the amended settlement boundary that includes site BEX3c as shown on the Policies Map, however this representation seeks to have the boundary amended further to include land to the north of the NBAR. For clarity an OS extract is included below showing the proposed boundary of this additional allocation

Please see attached full representation for further information.

Policy DRM3: Energy Requirements (Objection, requires technical amendment)

Policy DRM3 states that the extent to which a proposal incorporates renewable and low carbon energy technologies will be a factor weighing in the favour of a proposed development", and that "Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floorspace should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement."

This policy is considered to be an onerous and unnecessary obligation. The commitment to seeing a low carbon and renewable energy contribution is acknowledged as being well-intended, but in practice can lead to the dismissing of best practice energy efficiency techniques. Elements such as robust details, triple glazing, or efficient heating and ventilation systems are all more in keeping with the principles of sustainability as set out in the NPPF and are proven to be readily effective, but are often dismissed as not being not renewable or low carbon.

Therefore, policy DRM3 would benefit from additional wording along the lines of "The extent to which a proposal incorporates renewable and low carbon energy technologies alongside best practice efficiency techniques will be a factor weighing in the favour of a proposed development."

The supporting text for Policy DRM3 also identifies that Core Strategy Policy SRM 1 already promotes renewable energy through its requirements for an energy strategy on residential developments of 10 or more units, and that these thresholds should be reviewed as the requirements for an energy strategy can be onerous. These requirements as set out in SRM1 are onerous, and would greatly benefit from a prompt review.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

Appendix 4 of the Sustainability Appraisal sets out the assessment of the site allocation options, the sections below review the SA of the North Bexhill site.

In the sustainability appraisal, land to the north of Bexhill was considered as one site with a variety of development options. The consideration of the site as one entity is in keeping with how the site has been viewed in the SHLAA, however it does not allow for a clear independent assessment of the land to the north and south of the NBAR, as the sites are considered in conjunction with others.

Page 70 sets out how the broader north Bexhill site has been examined, with the various connotations and combinations that have been explored. The areas relevant to this representation are to the east of the wider site, and fall within parcels 'A' and 'D'. Page 78 sets out how the various site options were considered and shows the scores that they achieved.

The land to the south of the NBAR is identified as part of a conglomeration of 3 sites in the policy options plan, all termed as Area 'A'. Area 'A' appears in every option provided, and each option is identified as having at least 7 positive scores and two 'no effect' scores of the 16 elements assessed.

The most relevant Option considered is Option 4, which considers solely the Area 'A' sites. Whilst this does not examine the site that has been identified in the DaSA as BEX3c on its own, it does provide an examination that is not affected by the other defined Areas. Option 4 identifies seven positive scores, three 'no effect' scores and six negative scores. Of the six negative scores, all are deemed to only have 'minor adverse effects'.

Given the inclusion of land to the south of the NBAR within the DaSA as a site allocation, it is therefore interpreted that receiving similar scores would also justify sites with a similar score being included as draft allocations.

The site to the north of the NBAR is identified as being Area 'D' in the policy options plan. It is only included in three options - Option 2, Option 3 and Option 5. In Options 2 and 3, business development on Area 'D' is proposed, whilst in Option 5, residential development is proposed.

Given that the proposed masterplan for the site includes residential development to the north of the NBAR, it is prudent to examine the outcomes of Option 5 of the sustainability Appraisal. Option 5 includes both Area 'A' and Area 'D', and assesses the sustainability of these two areas together. As with the assessment of Option 4, Option 5 shows a positive score against seven of the sustainability criteria with three criteria being deemed to be of 'no effect'. Of the six negative scores, five are deemed to have only 'minor adverse effects'. Sustainability Objective 15 (to protect and enhance the high quality natural built environment) is deemed to register a score of 'potentially significant adverse effects' when Area 'D' is included in Option 5.

This inclusion of this 'potentially significant adverse effect' appears erroneous. When considering SA Objective 15 specifically, (Protect and enhance the high quality natural and built environment) the SA finds that with Option 2 (which includes Areas 'A', 'B', 'C', and 'D)', there may be minor adverse effects, however when Areas 'B' and 'C' are removed, and only Areas 'A' and 'D' considered under Option 5, this rises to potential significant effects. For less development to fail to protect and enhance the high quality of the natural and built environment appears to therefore be an erroneous score. Option 5 should therefore register the same score when considered against the sustainability appraisal and result in a score that matches that achieved by Option 4.

It is acknowledged that development on greenfield land will result in a negative impact on the natural environment, however, had the inclusion of Area 'D' under Option 5 been scored correctly, It can be seen that the inclusion of Area 'D' for development has not had a materially harming impact when considered alongside the development of Area 'A'.

In light of this, the inclusion of Area 'D' for development would not register any more of a material impact on the natural environment than the inclusion of land that has already been given a draft allocation in the DaSA under BEX3a, BEX3b, or BEX3c. Accordingly the land assessed under Area 'D' should be taken forward as an allocation in accordance with the comments made in section 7 of this representation.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

7.12. Policy OVE1 states that:

Housing sites sufficient to meet the Core Strategy requirement of at least 5,700 net additional homes over the period to 2028 will be met by allocations and other provisions in this Plan and Neighbourhood Plans.

No phasing restrictions will be imposed on development allocations, other than for site-specific, normally infrastructure, reasons.

Until such time as a Neighbourhood Plan for the relevant settlement with an outstanding Core Strategy housing requirement is in force, planning applications will be favourably considered for development proposals in those settlements where

i. they contribute to meeting the housing target for that settlement and accord with the relevant spatial strategy; and

ii. the site and development proposals are otherwise suitable having regard to other relevant policies of the Core Strategy, including the considerations in OSS2 and OSS3, and of this Plan.

7.13. Whilst the motive underpinning policy OVE1 is understood, it is considered that to plan for a shortfall against the Core Strategy requirements will not result in a plan which is positively prepared, justified, effective or consistent with National Policy, and will create a degree of uncertainty as to whether the housing requirements will actually be met. This is particularly relevant given the historic undersupply of housing in Rother District against the Core Strategy requirements, highlighted by RDC's current five year housing land supply of just 3.44 years' as set out in the April 2018 AMR.

7.14. RDC should therefore be mindful of this and seek to plan for the full Core Strategy requirements for the District, with a sufficient overprovision to account for the documented historic undersupply within the District and for sites that do not come forward, or that are developed for a lower amount of units than initially envisaged, as per the requirements of the NPPF (2012).

7.15. The ethos behind this policy is supported, in that it seeks to ensure the allocation of a number of sites which will help to address the identified need within the District. However technical amendments to the policy are sought, as it would be pertinent for the Council to take the opportunity to meet the residual Core Strategy requirement through the allocation of further sites in the DaSA and not to rely on other provisions in the Plan.

7.16. It is in this context that this representation has been prepared, with specific regard to Site BEX3c, which has been included in the draft Site allocations shown in the DaSA