It is considered the location of allocated sites needs to be altered to include land at the rear of 114 - 118 Widney Manor Road. This site, which a previous appeal decision (APP/Q4625/A/10/2133554/NWF) found to be able to satisfactorily accommodate some 20 dwellings in respect of the relationship to juxtaposition of buildings, highway safety, and ecological impact does not appear as a specified site. There is documentation (page 332 of the SHELAA Appendix B) which indicates surrounding land which another promoter (Ms. Savage on behalf of Mr. Shield) submitted without agreement of my clients (the owners of 114 - 118 Widney Manor Road) which indicates that the land may have been erroneously omitted from the analysis of the chosen sites. There appears from the Sustainability Appraisal to be no systematic analysis of all potential sites to indicate whether the requirements of S39 (ii) of the Planning and Compulsory Purchase Act 2004 have been fulfilled. (Further analysis is given in objection related to Q3 Spatial Strategy) The absence of comprehensive analysis and compliance with statute and policy indicates a need to re-run the work underlying the sustainabability appraisal accompanying the draft plan if it is to meet legal requirements.

Notwithstanding the above the Green Belt analysis for the locality of 114 - 118 Widney Manor Road is considered to be wholly inappropriate. The land between Widney Manor Road and the Railway Line is an area of developed land at very low density and for analytical purposes it is embraced by parcel RP32 which is almost all open fields. It is submitted that this coarse granularity is unreasonable in the circumstances. The site tabled in the SHELAA (Number 134) is not one which contributes in any material degree to essential objective of Green Belt policy, and it is therefore considered to be (as has been previously submitted) a suitable candidate for release from the Green Belt.

Having regard to the foregoing the Council is invited to reconsider the process by which sites have been sieved and assessed for sustainability.