Response from Mr & Mrs Edward Craker (Individual)
1. Mr & Mrs Edward Craker (Individual) : 5 Oct 2012 16:50:00
Please add your response below: (Limit 3000 words)
SLDC LDF 2nd October, 2012.
SUBMISSION TO THE INSPECTOR
OVERARCHING MATTERS
Matter 1 – Basis for the overall approach.
Issue 1.6
Submission by E.W.Craker.
The inspector has asked SLDC to respond to the questions he raises in paragraph 1.6, and by email dated 18th September, SLDC have invited submissions on their response.
Referring to SLDC’s response:-
Para 1.6.14 lists the criteria against which each site is addressed.
That list of some 21 points does not include practicability of highway access.
I submit that it is a fundamental requirement of any development that it is able to be accessed in a proper, safe and sustainable way.
Para 1.6.31 under the heading of “Approach to Site Selection for Emerging Options” it is stated that “----a thorough assessment of all sites on a settlement by settlement basis was carried out”.
I submit that this was not done.
For example, sites M683sMod and EN40-Mod have not had a realistic assessment of highway access requirements but have been included, yet R111 and R115 have been ruled out without a thorough assessment – they certainly did not have any kind of highway access assessment.
Diagram 2 Site Assessment Process, in box 7 ASSESSMENT AGAINST SUITABILITY CRITERIA (fourth bullet point) lists Access as a criteria.
Again, I make the point that for the examples I quote above (and I suspect others also) access has not been assessed, or not thoroughly assessed.
Para 1.6.33 states that “All sites were assessed through this approach on a consistent basis----“.
As I have demonstrated above, this has not been done.
I submit that in spite of what SLDC have stated in their response to the Inspectors comments, the DPD is not based on a sound process of sustainability appraisal and testing of reasonable alternatives.
Indeed, in an enclosure to an email to me of 21st February, 2012, SLDC admit as much.
In a paragraph dealing with access to M683sMod and EN40-Mod they say that
“---an assessment would have to be undertaken to assess financial feasibility---“
They also say:-“Ideally we’d have done it well before now but I imagine that could be said about many sites for one issue or another. The sooner the better I would think though as if it is unfeasible, then it shouldn’t really be in.”
By subsequent correspondence with SLDC I believe that by as late as 12th September, no such appraisal had been carried out.
Conclusion.
I therefore submit:-
The DPD has not been based on a sound process of sustainability appraisal and testing of reasonable alternatives, and thus it cannot be said that the options chosen represent the most appropriate strategy in the circumstances.
The site selection process has not been objective, nor has it been based on appropriate criteria.
There is not a clear audit trail.
If site selection criteria was used, it was not complete, and possibly was biased.
