Ancillary Development on Employment Sites

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Consultation Draft (February 2017)

Representation ID: 6138

Received: 06/04/2017

Respondent: Gareth Barber


Objections to proposed developments around Callywhite Lane. Reasons given for objections: increase in traffic, congest from difficult to navigate roads and proximity to secondary school, safety of pedestrians from no crossing point on the lane, would be more beneficial to the community being residential land as the employment type would not be beneficial to local residents.

Full text:

RE: Removal of greenbelt land in and around Dronfield
I wish to make you aware of a number of strong objections that we have with regard to the
proposed development of an additional property on in Dronfield, that, we are of the view
that the proposed development will have a serious impact on living and health standards.
Our specific objections are as follows:
I vehemently object to the proposals in the Local Plan to redesignate the areas of Green Belt
marked DR1, DR2, DR3, DR4 and DR5 on the map below.
Your proposals to redesignate areas of Green Belt are not in tandem with central
government's approach. Housing Minister Gavin Barwell stated in February 2017 that the
government intended to focus, as a government, on developing brownfield land, specifically
in those parts of the country where additional homes are required. He talked about new
measures to help councils identify locations for development, and in all but exceptional
circumstances, that will exclude the Green Belt.
Your proposals to redesignate areas of Green Belt do not adhere to the guidelines issued
from the Department of Communities & Local Government, which state that "... local
councils should be looking to brownfield first and foremost, and be in line with government
policy of protecting Green Belt."
Your proposals to redesignate areas of Green Belt are contrary to Point 89 of The National
Planning Policy Framework, which states "A local planning authority should regard the
construction of new buildings as inappropriate in Green Belt."
Your proposals to redesignate areas of Green Belt fail to take account of the wishes of the
majority of residents. Policy S S9: North East Derbyshire Green Belt in The Plan states that
"...the majority of local residents want to maintain the Green Belt boundary ..."
Your proposals to redesignate areas of Green Belt, build 860 houses on Green Belt land, and
the adverse consequences of this, is in conflict with your Vision, which reflects your
responsibility as a local authority to act in a way which enhances the quality of life and wellbeing
of your residents: "By 2033 everyone in North East Derbyshire will enjoy a high quality of
life, with residents, businesses and visitors all benefiting from what the district has to offer." The
loss of Green Belt, and the resulting loss of recreation opportunities, coupled with the shift in
character of the nature of the town from rural to urban), will reduce the quality of life for
residents (especially when the recent studies on the benefits of nature to mental well-being
are taken into consideration), particularly for those whose homes border the proposed sites.

Your proposals to redesignate areas of Green Belt will reduce even further those areas of
recreation presently available to residents (we don't just look out onto our Green Belt - we
actively use it!). You recognise in 7.6 Sustainable Places that Dronfield already is "significantly
lacking in green space, outdoor sports and children's play space".
The effects of your proposals to redesignate areas of Green Belt around Dronfield will be
disproportionate in relation to similar measures around other settlements. The Strategic Green
Belt Functionality Study shows that that all proposed Dronfield development areas are in the
top 50% of Green Belt sections that would suffer most when measured against Green Belt
objectives; yet this is where you propose to build a large number of houses.
Your proposals to redesignate areas of Green Belt do not take into account the 731 properties which you have recorded as being Empty Homes across the whole of the NEDDC area, including 133 in Dronfield, Dronfield Woodhouse and Coal Aston, figures which I obtained from you as a result of a Freedom of Information request. Your response states that for the years of 2015 and 2016, you have assisted no owners in recycling those properties back into use as homes, the result being where those homes are now in full use; nor are you currently assisting owners to do same; nor have you taken formal enforcement measures against owners to bring about same. Your document, "Growth Strategy - Unlocking our Growth Potential" states, "if [empty homes were] brought back into use would contribute towards meeting housing needs and improve neighbourhoods".
Your proposals to redesignate areas of Green Belt is not "limited infilling" and therefore
"exceptional circumstances"; the proposed number of houses is significant in each location, each location is considerable in size, and in no way can be regarded as limited. The sheer size of each development would result in a huge impact on Dronfield, surrounding farmland, and the remaining Green Belt, and alter the character of the town and the area in which it sits, completely.
Therefore, I believe that you have not made the case for "exceptional circumstances" as a reason for your proposals to build on Dronfield's Green Belt. Unmet housing need is not "exceptional circumstances" for the redesignation of Green Belt. Nor do I believe that you have taken sufficient steps to consider alternatives to the redesignation of Green Belt; namely, bringing brownfield land back into use, consideration of other brownfield sites across the district as a whole and in neighbouring council areas, and the recycling of Empty Homes across the district. Redesignation of Green Belt should be the last resort, to be undertaken only when ALL other options have been fully exhausted.
1. What pro-active initiatives have you undertaken to identify brownfield sites?
2. Where is your evidence that you have considered all brownfield sites, including those which would support fewer than ten dwellings?
3. In the event that you have considered brownfield sites, but taken the decision not to situate any of the proposed 860 houses thereon, where is the analysis of each site?
4. What are the issues around the viability of delivering large numbers of sites in a relatively small area in the south, which you refer to in your leaflet, "Frequently Asked Questions for Dronfield"? What are the reasons that you do not consider these sites for development?
5. What incentives have you offered to property development companies to develop brownfield sites?
6. What incentives have you offered to businesses currently occupying brownfield sites in residential areas for those businesses to relocate to nearby business parks and industrial estates, which may prove more suitable for their needs and thus render the vacated brownfield sites available for house-building?
7. What pro-active initiatives have you undertaken to identify employment land which has been vacant or unviable for several years?
8. To what extent has the fact that Dronfield is an affluent area played a part in the decision to redesignate parts of its surrounding Green Belt land (is it due to pressure from property development companies? Their profit margins will be higher for providing the types of houses which predominate in Dronfield)?
9. How do you seek to adopt the new measures referred to by Housing Minister Gavin Barwell to help councils identify locations for development, in all but exceptional circumstances excluding the Green Belt?
10. Why the emphasis on redesignating Green Belt in the north, when there may be sufficient brownfield sites in the south?
11. What action do you propose to take in order to bring the 733 long-term empty properties across the district back into full-time use as homes?

The Plan does not follow government policy, which states that "The Local Plan should make
clear, for at least the first five years, what infrastructure is required, who is going to fund and
provide it, and how it relates to the anticipated rate and phasing of development." This information is not contained within The Plan. In failing to follow policy, you do not comply with the spirit of the principles supporting Local Plans, which are to provide a clear, coherent, long-term plan to avoid a piecemeal approach. I wish to raise the following concerns regarding infrastructure and potential consequences of the redesignation of the Green Belt:

1. You state in 9.12 Greenways & Multi-User Routes that public rights of way provide considerable opportunities for people to enjoy the countryside, and that it is important to ensure that development does not have an adverse impact upon the integrity of these routes. In 9.13, you state that you will support the use of all public rights of way ... and safeguard them against development likely to prejudice their integrity. The proposals to build housing at H and I do not support this. Nor do they support your statement in D11 Natural Assets, where you seek to "recognise the value of natural assets by protecting, enhancing and expanding North East Derbyshire's network of green and blue infrastructure including its distinctive landscape character, open spaces and nature conservation sites in part by supporting opportunities to improve countryside access." Area H is bordered by a public bridleway which bisects Hallowes Golf Course, and by Hill Top Road which, at this point, has the appearance of a single-carriageway tarmacked farm track with no pavement. Both connect with footpaths, which lead to open countryside. The public bridleway and the whole of Hill Top Road act as links from one part of the popular Dronfield Round Walk to another, and also to the Chesterfield Round Walk. Their key appeal is the quick and easy access they provide to the countryside. Development at H will compromise the integrity of this public bridleway, as the bridleway would border a housing development; its character will change entirely. Development at I, which would increase vehicular traffic from this site onto Hill Top Road (via which route? - the Plan fails to include details of proposed access to this site), will compromise the integrity of the Dronfield Round Walk and the Chesterfield Round Walk. You state in this section that residents identified tranquility, landscape quality and access to the countryside as key assets of living in the District. The setting of the bridlepaths, and the setting and nature of the whole of Hill Top Road, contributes significantly to this; residents feel connected with the landscape around them. Thus, the proposals fail to take into account
the wishes of residents.

2. You state in Policy ID3: Open Space, Sports and Recreation Facilities that the Council will seek to protect and enhance existing open spaces, sports and recreation facilities. You state in Sustainable Places Para 7.6 that Dronfield is "significantly lacking in green space, outdoor sports and children's play space." Your overall Vision in The Plan talks about "protecting and creating open spaces to provide accessible green infrastructure and biodiversity networks which promote healthy lifestyles..." Your proposals for the green belt land at H and J do not support Policy ID3: H is made up of part of Hallowes Golf Course, and J, sports facilities and the Moss Valley Conservation area. Your proposals for J do not support your policy at D11 Natural Assets owing to the presence of the Moss Valley Conservation Area. Nor do your proposals for H, I and J support your overall Vision.
Your proposals for the land at G, H and I contradict your statement in Sustainable Places Para 7.6, and also your overall Vision. Houses in the quantity you are proposing will change the nature of Hill Top Road and Salisbury Road from quiet safe roads where children play football and ride their bikes. In the event that access to G is created via Burns Drive (you do not give details of access to site G in your Plan), this would drastically change the nature of Burns Drive from a cul-de-sac with a small grassed area, thus highly attractive to local children, to that of a thoroughfare, removing this location as a pleasant play area. Additionally, your proposals fail to support central government's policy on reducing obesity. Department of Health Guidelines, "An Update on the Government's Approach to Tackling Obesity", state that "Local authorities will be instrumental in implementing plans that
encourage people to do more exercise." NEDDC does this well when promoting its sports and leisure centres, which people have to pay to access. Use of the bridle paths around the land at H and Hill Top Road is free, thereby providing inclusive exercise opportunities for people at all income levels.
The benefits of close proximity to nature have been upheld in the Institute for European Environmental Policy's March 2017 study, the most wide-ranging probe yet into the dynamics of health, nature and wellbeing.

3. Car Parking
Your justification of the presence of the railway station in Dronfield to build 860 houses in Dronfield is flawed. The station is served by one car park which is insufficient for passengers' needs. There is no
possibility of additional parking: the lease of the car park is to revert to the rail operator, which may consider introducing parking charges and may reduce the number of spaces. The majority of car park users are people undertaking short journeys; any disproportionate charge for parking could discourage them from using the train (source: Friends of Dronfield Station). Network Rail will not release the yard at the rear of the car park for additional parking. The development at Manor Farm will mean the loss of around 25 car parking spaces.
For electrification of the East Midland line to occur, the station may need to be moved out of the town - the two listed bridges at Dronfield prevent electrification. It is a two-mile round trip from four out of the five proposed housing sites to the railway station. There is a steep incline on the return journey for sites at H, I and J. All proposed sites are on the rural fringe of Dronfield and as far from the railway station as it is possible to get.
Therefore, is possible that rail passengers living on the new estates may not wish to make this journey on foot, and may use less-sustainable means of travel, compounding the existing parking and congestion problems.

4. Road Congestion
Your proposals to build 860 homes at sites G, H, I, J and K is contrary to Policy ID6: Sustainable Travel - "The Council will seek to maximise walking, cycling, and the use of public transport through the location and design of new development, with the aim of reducing congestion, and improving air quality and health." There is insufficient car parking at Dronfield Railway Station for additional rail users. When the car park is full, rail passengers tend to park their vehicles on neighbouring roads. This results in severe congestion, particularly on School Lane and Lea Road. Congestion is aggravated by cars picking up/dropping off pupils at Dronfield Infant School and Dronfield Junior School on School Lane. There are approx. 600 pupils at these schools.
Dronfield is served by shopping areas at the Civic Centre, Pentland Road, and Greendale Shops. The Civic Centre area offers a health centre, pharmacy, sports centre, library, shops, meeting places, and places of worship; it is a real "hub" for the town. Severe congestion and standing traffic occurs at the junction with Hallowes Lane/Chesterfield Road, and along Dronfield Bottom, including the entrance point to Callywhite Lane Industrial Estate, and on High Street. All are main routes from one part of Dronfield to another. Hallowes Lane is a main access route for residents living at Hallowes and Hill Top, where you propose to build 420 homes. Hallowes Lane is narrow to the point where it can be impossible for two vehicles to pass side-by-side.

5. Air Pollution
The Plan is likely to reinforce a commuter community, and therefore contribute to air pollution. You acknowledge in The Plan that "most people commute to other areas for work (Chesterfield or Sheffield) and that most commute by road." It is likely that the many of the house purchasers at all sites will follow suit. Should planning permission be granted to Ineos Upstream for exploratory drilling at Bramleymoor, the preferred route indicated by Ineos Upstream for vehicles to access the site is via Dyche Lane and Eckington Road. They have stated that there are likely to be 100 vehicles a day in the setting-up phase alone, and due to the nature of the operation, many of these vehicles will be heavy freight. In addition, Dyche Lane and Eckington Road are likely to be main access routes for visitors to St James Retail Park at Norton - a development that is likely to prove very attractive to Dronfield residents. Air pollution is likely to be compounded by the proposals for 180 houses at J, on the basis that individual households have at least one car.
The Environment Act 1995 requires all local authorities to review and assess air quality.
1. Given the increase in vehicular traffic which 860 new homes in Dronfield will bring, and the situation with the proposed plans for exploratory drilling at Bramleymoor, what steps does NEDDC intend to take to ensure that it complies with the Act?

6. Co-operation with Neighbouring Planning Authorities
The population of Chesterfield Borough is due to rise by 9100 by 2031. Sites in the Borough have been made available for an additional 7600 homes by 2013. Using the average of 2.5 people per household (NEDDC planners' figures), there is spare capacity here. Peak Resort is likely to provide employment for 1300 people. Given this fact, and the proximity of the resort to the areas of the disused Unstone Boat Yard, Lister's Car Sales, and the disused nursery, these sites are likely to prove attractive as a place to live; they directly border the NEDDC council area.
1. What steps have you taken to cross-reference your proposals and co-operate with neighbouring authorities, such as Chesterfield Borough Council and the Sheffield City Region, to meet the need for unmet housing need across neighbouring council areas?

7. Urban Sprawl
Your proposals to redesignate the Green Belt at G do not comply with government policy, which states that the fundamental aim of Green Belt is to keep land permanently open and prevent urban sprawl (NPFF, Section 9).
The Green Belt between Dronfield and Unstone is already very narrow. Land at G is actively farmed and provides access to the open countryside and the Dronfield Round Walk. Houses on this site will contribute to the urban sprawl of Dronfield, and this effect will be exacerbated by the new-build semi-detached homes on Chesterfield Road, and the proposed building of seven homes on the site of the Fleur de Lys public house. There will, therefore, be no discernable gap from Dronfield to Unstone.

8. Employment
Your proposals to build 860 homes in Dronfield are contrary to the National Planning Policy Framework, which aims to provide jobs where people live. The Plan fails to include a plan for employment provision in Dronfield for 860 new homes. You state in The Plan that there will be insufficient growth in local jobs to support 860 households.
You state in your leaflet, "Frequently Asked Questions for Dronfield" that you have "considered but dismissed [land at Callywhite Lane] due to their importance and suitability for employment and creating jobs." Callywhite Lane Industrial Estate contains long-standing empty units, vacant plots and derelict land. These have not attracted interest from businesses for some time and in their current state are unlikely to do so, particularly businesses which employ large numbers of people.
I note that Chesterfield Borough Council takes a different approach; their Local Plan identifies Ash Glen Nursery, and Lister's Car Sales as sites for residential development. The planning status of the latter two is "allocation employment".
1. What steps have you taken to bring sites at Callywhite Lane into use as sites for some of the 860 proposed homes?
2. What options have you explored with Sheffield City Region regarding employment opportunities, given that many Dronfield residents work in Sheffield?
3. What steps have you taken to identify suitable sites to the north of Dronfield, which owing to proximity are likely to prove more suitable for those working in Sheffield, and provide benefits in terms of air pollution due to the shorter distance travelled to work?

9. Access to Medical Services
There are four GPs surgeries in Dronfield; most, if not all, are already at capacity.
1. How do you intend to ensure that additional residents in Dronfield have access to a GP in the town?

10. Distribution of proposed dwellings
In the Plan, you focus on Dronfield for such a substantial increase in homes because it is the largest settlement in the north of the District. It could also be said that, owing to its size, it has the least room for expansion. You state in the leaflet, "Frequently Asked Questions for Dronfield" that detailed analysis found a high level of potential supply in the south of the District where there are issues
around the viability of delivering large numbers of sites in a relatively small area. Whereas in the North and West of the District, areas with particularly high demand, there is significant undersupply of housing land ..." You provide this as justification for the review of the Green Belt, yet unmet housing needs do not constitute exceptional circumstances for the redesignation of the Green Belt, as stated in the NPPF.
Information provided by the Coal Authority indicates that the sites at H, I and J are areas of high risk and contain potential hazards arising from former coal mining.
1. Why do you seek to make larger towns even larger without ensuring that those towns have the requisite infrastructure already in place?
2. Why have you not spread the extra housing required over more villages and towns?
3. Why did you not make provision for low-cost housing, suitable for older people, at Manor Farm? This central site, with excellent level access to shops, health centre, pharmacy, library, sports facilities and public transport, is being considered for family homes! I note the comment made by Cllr Baxter that the development is "To provide a significant financial surplus to support the Council and Rykneld's ongoing investment programme in new and refurbished publicly owned homes." This indicates that profit is the overall driver here, as opposed to a coherent approach to the
provision of homes across the whole of the town.
4. Have you commissioned the carrying-out of a survey regarding the suitability of this land for house building? If not, then why have these areas been included within The Plan, given that their suitability has not yet been determined?

11. Schooling Provision
Dronfield Henry Fanshawe School is the only secondary school in Dronfield and is oversubscribed. Space to extend the school on its Green Lane site is lacking. The majority of the primary schools in Dronfield are at capacity. Ironically, several schools in the district have closed and have been developed for housing (for example, Apperknowle Primary School). This suggests a piecemeal approach to school and housing provision. The overwhelming majority of children of secondary-school age living in Dronfield attend Dronfield Henry Fanshawe School; it is popular, successful, and highly-regarded by residents. This contributes significantly towards the strong sense of community in the town; it helps to bring the town together. Were some secondary-school students living in Dronfield forced to attend secondary school provision elsewhere, this sense of "one-ness" that many feel, living
in Dronfield, is likely to be eroded.
1. How do you intend to ensure that primary and secondary school provision is sufficient for Dronfield children, without resorting to new-school provision on Green Belt land?
12. Roads and Road Safety
Homes at H and I are likely to have adverse effects on Hallowes Lane and in the centre of Dronfield - areas which presently experience congestion and standing traffic. Homes at H and I are likely to significantly alter the character of Hill Top Road and Salisbury Road.

Hill Top Road
You have not demonstrated in The Plan that the highway network in Dronfield has sufficient capacity for this scale of development, nor that improvement works can be carried out. 190 homes at I are likely to change the character of Hill Top Road from that of a very quiet, residential road and farm track, to that of a main access road to the new houses and possible through-route.
In the event that the access route to I is via a new road through the car park of the Hyde Park, this would contribute to on-street parking within close proximity to a junction, and may reduce the attractiveness of this pub to potential customers - the pub is the sole amenity in this area.
The Hyde Park would then not be used by local folk, which has been the backbone of this pub's income for many a year, as it doesn't have any drive by customers, and therefore result in job loses when the pub closes. Hill Top Road is narrow. In part, it is a single-carriageway tarmacked farm track with no pavement. The parked vehicles of residents reduce part of the road to a single lane. The road is popular with joggers, children riding pedal cycles, and horse-riders - the road is a direct route to a farm. It is a link from one part of the Dronfield Round Walk to another, and also to the Chesterfield Round Walk. It provides direct access to footpaths through Monk Wood and towards Cowley Lane. Other than the Hyde Park public house, there are no amenities in this area of Dronfield. There is no direct access to I (DR3). The site is hemmed in by houses, a pub, and a pub car park.
The Plan does not state how access will be gained to this site. In the event that access is via Hill Top Road and Long Acre Road, this would mean that vehicles for a total of 420 houses would be using the road; assuming that the majority of households now have two vehicles, this would mean an additional 840 vehicles using these roads.
There are contradictions throughout the consultation process with overview and inaccuracies throughout that need urgent attention before any decision to remove green belt is made.
Take for example DR3 which is your reference for the parcel of land of Hill Top Road Taking into account your scoring mechanism (attached above)you state that DR3 scores a '1' in the 'to preserve the setting' category. It fails to mention that the field is surrounded and sits adjacent to properties dating back to 1880's, yet in other zone studies in your report, this fact of period properties attracts a much higher score! The same can be said for 'to assist in safeguarding' category. Therefore, I conclude that if these areas are wholly incorrect, and the report is fundamentally floored, and must be rereview, and a new report commissioned.

Hallowes Lane
Hallowes Lane, which is narrow, steep, and busy, is a main route for vehicles and pedestrians at Hallowes and Hill Top to access the rest of Dronfield and to leave the town in both a southerly and northerly direction. The road is reduced in part to one lane, owing to the presence of parked vehicles. The pavement is narrow - there is no pavement at all at the bottom of the road opposite The White Swan. Pedestrians walking on the pavement are in close proximity to moving vehicles; on bin collection day, pedestrians have no choice but to walk into the road in order to continue their journey, owing to wheelie bins blocking the pavement.
The vast majority of the pedestrians are students making their way to and from Dronfield Henry Fanshawe School, and parents with primary-school-aged children. Pedestrians are in large numbers at the beginning and end of the school day, a time when traffic is at its greatest because of commuters and school-run traffic. The junctions with Hollins Spring Avenue, Cemetery Road, Quoit Green and Chesterfield Road are busy. The junction with Lea Road is busy, has poor visibility, and there is no safe refuge for pedestrians. Any proposed access to H via Highfields Road, bisecting Salisbury Road, is likely to exacerbate existing traffic problems on Hallowes Lane.

High Street
High Street is a main route through the town; the road is already narrow and busy. There is no crossing point enabling easy pedestrian access from one part of the town centre to another - it is a "life in your hands" situation when trying to cross from the Sainsbury's side to the library side. The car park at the Civic Centre is often full.

Entrance to Callywhite Lane Industrial Estate
The extension to Callywhite Lane Industrial Estate is likely to result in an increase in heavy traffic. The present entrance to the Estate is in close proximity to Dronfield Henry Fanshawe School, from which almost 1800 students emerge every weekday afternoon. It is situated at the junction of three main routes through Dronfield. The area is busy. The road layout is complicated and does not facilitate easy passage for vehicles. There is no crossing point on Callywhite Lane, nor neighbouring Mill Lane. Both are hazardous for pedestrians who have no safe route across.
1. How do you intend to ensure that additional heavy traffic does not compound the existing traffic problems and the congestion at the present entrance to the Estate? What steps do you intend to take to ensure that pedestrians, and students en route to/from Dronfield Henry Fanshawe School, are kept safe?

I note that you refused an application in 2013 for the erection of 51 new residential dwellings on the former Padley and Venables Site, Callywhite Lane, and that refusal was stated (a) on the basis that the proposed development would result in a change of use of land protected for employment; (b) the proposed residential development land is adjacent to industrial units, and that this would introduce potential conflict for residents and businesses; (c) the application was considered unacceptable as it would lead to additional traffic movements from the proposed housing along Frithwood Drive, Shireoaks Road and Stonelow Road (d) a coal mining risk assessment and contaminated land assessment had not been submitted and there was insufficient evidence that the application site was safe, stable and suitable to accommodate the proposed development.
Callywhite Lane Industrial Estate has been poorly-maintained for a long time, and is unattractive to prospective businesses. Empty units are evidence of this. Unless the area is redeveloped, the situation is unlikely to change. Taking into account the high level of interest and objection that Dronfield residents have in The Plan, demonstrated in the very active "Dronfield Greenbelt" campaign, it is likely that future objections to applications for planning permission to build houses on the five sites
would far surpass those received in 2013 regarding the Padley and Venables site. I note that you have not carried out a coal-mining risk assessment for the three sites which are considered high risk development areas by the Coal Authority - sites H, I, and J. Yet you propose to build houses at these locations, and you refused permission for the 2013 application from Bloor Homes on the basis
that a coal-mining risk assessment had not been carried out.
1. Given the fact that the majority of Dronfield residents do not find their work in the town but commute to Chesterfield/Sheffield, and given the scarcity of suitable land for homes, is it now time to reconsider the use of this land and release it for the building of homes?
2. Close proximity to industrial units does not adversely affect the popularity of Cliffe Park, nor affect its visitors. Given the scarcity of suitable land for homes, would this area benefit from creative landscaping and appropriate measures to provide demarcation between residential and industrial areas?
3. Why is it that you required the Padley and Venables site to be so assessed, yet have not carried out assessments on sites H, I and J BEFORE considering them for housing? This can only be said to be double standards in action; I struggle to maintain faith in the planning system.

Therefore, I conclude that this consultation is wholly incorrect, and the reports within are fundamentally floored, and must be stopped with immediate effect, reviewed, and a new report commissioned.