Object

Representation ID: 55337

Received: 28/07/2013

Respondent: Graham Parker

The process used in the RDS for identifying the priorities for the location of development, insofar as it relates to the District's villages, gives undue priority to locations in Green Belt before the potential for non green belt locations has been fully explored, indeed in some cases the priority has actually been reversed (see point 3.7 below).

The effect of this is that over 50 % of the development allocated to the villages is intended to take place in Green Belt, even before the further evaluation process set out in paragraph 4.3.16 of the RDS has begun:

The process by which the strategy reaches the conclusions about the allocation of development to settlements is contained in the Draft Settlement Hierarchy Report 2013 which, contrary to para 4.3.13 of the RDS is neither robust nor justifiable.

Whilst supporting the previous process that led to the identification of Category 1 and 2 villages in the 2012 Preferred Option Report as robust and justifiable, the process set out in the settlement report is a mixture of objective statistical analysis overlain with subjective (and often preconceived) conclusions.

As a result of objections from a number of organisations complaining about the consequences of this process for development in the various villages, the process has
been "adapted" based on the Blaby Model. The effect is to change the classification to that now found in RDS5,1 in which Barford, in particular has arbitrarily been changed in classification, even though, in Test 2, it is a mere 2 'points' different from Bishop's Tachbrook.

In contrast, the village of Cubbington has actually been upgraded in classification despite being entirely washed over by Greenbelt. The 'switch' of classification of these two example villages is counter-intuitive to NPPF policy as set out above.

This is unjustified and materially unsound for a number of reasons, as set out below.

1-there are mathematical discrepancies in adapting the Blaby Model (Test 1) to Warwick's model (Test 2)

2-the introduction of subjective views into what is essentially a mathematical model is completely unjustified. In order to be robust, the process of adapting Test 1 to Test 2 results should be separated and explained in clear detail. Otherwise, the Test 2 results have no validity. The two greatest inputs of subjectivity are the introduction of Parish Council etc comments and SHLAA evaluations into the Model.

3-the process ignores completely the greatest policy impediment to development around many of the villages. This is, of course the Green Belt designation.

Many of the settlements have been designated as 'washed over' villages in the Green Belt and this is the default position unless 'exceptional circumstances' are identified to warrant amendment of Green Belt Boundaries. Thus, the starting position for Village Categorisation Model must be that the Green Belt villages are not available for development.

The local planning authority must:
* Either demonstrate that the required exceptional circumstances exist before including these villages in the Model; or

* Include a factor in the Model that - in accordance with the NPPF - favours non-Green Belt locations over Green Belt villages. (It may be said that the 'Environmental Impact' element in the Test 1 - Test 2 conversion includes this, but this appears not to have been applied consistently or rationally).

Conclusion:
Until the classification is demonstrated to be objective, robust and justified, the Strategy is unsound as set out in the NPPF as:

* It has not been demonstrated to be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not, therefore, 'justified'.

* It does not enable the delivery of sustainable development in accordance with the policies in the Framework - in this case, specifically, sustainable development and Green Belt policies. It is not, therefore, consistent with national policy.

* On the basis of the object to the classification set out in RDS5.

In order to be made sound in accordance with the NPPF, one of three things should happen:

* Revert to the original Structure Plan based classification as set out in the Preferred Options Report; or

* Use the Blaby Model as it was designed to be used - as a statistical model, or If subjective elements are to be incorporated, expose them separately, along with the weighting and reasoning. This must incorporate a heavily weighted element in favour of non-Green Belt locations, and appropriate re-classification of the villages.