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Dear Mr. Owens,

I object to the re-designation of any Green Belt land as part of the CWaC local plan.

“The draft local development plan is unsound because:”

1)            There is no justification for re-designating Green Belt land for housing. The assessment of the number of new homes required is deeply flawed and is ‘dwelling-led’ rather than based on evidenced needs. The result is a housing target of more than twice that determined by the Dept of Communities and Local Government‘s projected increase in households..  It is not based on ‘proportionate’ evidence.

2)            There is no justification for the “ambitious”  growth targets which do not enjoy public support. The results of what little consultation there has been with the public have been ignored. They are well above any historical or natural levels and are not deliverable.

3)            There is no justification because the plans are disproportionate to the need.  The Strategic Land Availability Assessment (SHLAA) shows that there is no shortage of land availability over the 20 year period. The Green Belt should not be dismembered for a ‘perceived’ shortage over the very short term.

4)            It is not positively prepared as there is no evidence of co-operation (as required in the planning guidance) with neighbouring authorities.

5)            It is not effective as there is no evidence of joint working on cross boundary strategic priorities.

6)            It is not consistent with the NPPF and national planning guidelines in its lack of use of secondary nationally produced data.

7)            It is not positively prepared in that it fails to address the issues of waste treatment capacity, traffic congestion, water supply etc with neighbouring authorities.

8)            The plan is not effective as it has not been demonstrated that the plan can be delivered.  It is simply not a credible plan given recorded past delivery levels and the latest demographic changes recorded by the ONS indicate.

The case for re-designating any Green-Belt has not been made.  We cannot understand why this Authority is encouraging the development of Green-Belt land and countryside, against the wishes of the community rather than primarily utilising all available Brownfield land as demanded by the National Planning Framework      …who are they representing ? 

 

Sign & Date

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spatialplanning@cheshirewestandchester.gov.uk

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Spatial Planning, The Forum Offices, Chester CH12HS