Page 151 - MJC submissions

Paragraph 4
Objectively Assessed Need

1.18 Concealment of Missing OAN
12. Paragraph 6.1 of the town planning report of Mr Frank Taylor (Folio 2) obscures the
absence of a justifying OAN for the planned development by rolling the need into a total
for Category 3 habitations as follows:

“So far as the EDF site is concerned, it is included in the modified MSDC's settlement
category no. 3 for which the "minimum requirement" has been set at 2,200 units”.

This ambiguous wording was not challenged by MSDC. There is no need for over-
development of the WH sites.

SUPPORTING REPORTS AND CONSULATIONS

1. If either the current application or the integrated development is referred for Judicial
Review or for action under human rights or other laws – which appears increasingly likely
- many of the expert and consultation reports will come under fire. The transport
submissions and offset calculations are particularly worrying.
1.19 The Transport Statement
2. A Transport Statement (Folio 30) was commissioned by AHL and published in April 2018.
It states that the proposed development would reduce traffic flows onto the A22 from the
“existing” EDF site by 38%. This is nonsense: for reasons explained in paragraph 7.5 of
my submission to MSDC.

3. On 28 June 2018, Jamie Brown wrote an incredible consultation response (Folio 60) in
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which he (or she) enthusiastically supports the development. He (or she) did not visit the
site until 4 July 2018.
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4. The report states:

• “The EDF site is currently occupied as an office building”. FACT: It is unoccupied with
a zero-traffic flow;

• Access will be via the existing access arrangements--- which benefits from a Right Turn
Lane . FACT: For reasons explained in paragraph 7.4 of my submission the right turn
lane is already extremely dangerous and congested;

• There are no visibility issues from the existing site access. FACT: Not correct;

• There have been no recorded injury accidents near the site access. FACT: Not correct;
• There is no suggestion that that the proposed development would exacerbate an
existing safety concern. FACT: The report indicates that here is no “existing safety
concern”:
• An internal footpath is provided within the current site. This should be 1.8 metres in
width. FACT: There is no indication in the Design and Access Statement of any
internal footpaths;

• Parking provision is stated as meeting the requirements of the WSCC Parking Demand
Calculator—the car parking provision is anticipated to satisfy the likely demands’.
FACT: The WSCC Parking Demand Calculator has questionable authority because it
relies on MSDC’s Local Policy 2004 (T4) which was inoperative. The prevailing
parking specification derives from AWNP Policy 21 which requires two spaces per
dwelling. The application development is at least 50 parking spaces short;

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