Comment

Representation ID: 9364

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Step 2 process lacks transparency and robustness in way it draws matters for consideration together and balances them in the decision making process, with little explanation.

A number of concerns with the way site 313 has been assessed both in terms of the assessment process and judgements made within this document itself, and also the robustness of the evidence base used to underpin it.

Methodology is applied incorrectly to Site 313 Fulford Hall Farm and is flawed, as Step 1 priority should be 6 rather than 9,in respect of judgements made on green belt and landscape sensitivity. Accessibility study concludes the site has high accessibility therefore logically should be categorised as 6 and not 9 contrary to SMBC evidence base. In the greenbelt assessment the site is within broad area 1 with all broad areas given a score of 3 (highest rating). This is fundamentally flawed and unsound, lacking the detail of a district level assessment and artificially inflating the contribution of the Fulford Hall Farm to safeguarding of the countryside. In terms of landscape character the site is classified within LCA2 and its visual sensitivity is classified as high. Contest the methodology used to establish visual sensitivity which appears to be weakly justified with no explanation of how the classification criteria have been assessed or judged.
11 of proposed site allocations fall under Category 3 in SHELAA and are classed as not currently developable.