Object

Representation ID: 98

Received: 11/10/2019

Respondent: Nottinghamshire Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

NWT do not consider this policy to be sound because of the inherent contradiction between the Plan-led approach whilst simultaneously making specific provision for development on non-allocated sites within Policy MP7. If the plan-making process has been robust and based on good data, then there should be no need for development on non-allocated sites. A robust plan review progress at fixed intervals may identify the need to bring new sites forward for further allocations in a proper manner, where the need has changed, in which case they can be compared to other potential sites in a rigorous way. It is not a rigorous process for a single operator’s proposal to be brought forward at a particular point in time, and therefore not be subject to a proper comparative test against others prospective sites, including an SA.

By undermining the plan-led approach, it is possible that this policy could inadvertently breach the requirements of the NPPF and so may not be legally compliant.

In addition, NWT object to this Policy because we do not agree MP7c Bantycock Quarry South should be allocated as currently shown on the Plan, as the proposed site boundary includes an LWS and another lies immediately adjacent, which could be subject to damaging indirect impacts. This is recognised in the SA and is a significant reason for the -7, -1 score. Were the LWS to be removed from the proposed site allocation and the boundary moved further away from the adjacent LWS, then NWT could support this allocation.