4.3.9 is unsound with regard to provision of local centres / retail - there is no current requirement at the site location for additional retail facilities. The proposed development would compete with existing convenience stores and may result in existing Residents in Fearnhead suffering a net loss of facilities

10.4.2 is unsound. The community does not meet the definition of 'sustainable'. As was amply demonstrated during the 2018 and 2020 Public Inquiries, the site is landlocked, the homes which are planned would only be accessible by car and cycling beyond the site would be at negligible levels - as Satnam's traffic survey showed to be the case currently

10.4.4 is unsound and demonstrably inaccurate. See notes for 10..2 above

10.4.6 requires clarification. Please state unequivocally the transport measures which would be put in place. At the Public Inquiries in 2018 and 2020 there were no reasonable measures proposed by the developer to mitigate the very significant transport challenges generated by the development

MD 4.3 - several areas of concern:

1. The 30% affordable homes target - this has been allowed to be breached many times in the past by WBC. This statement is not sufficiently detailed to ensure compliance
2. Sports facilities - an agreement has been reached with the developer that the taxpayer will fund the ongoing maintenance of the sports facilities. I believe this to be not Legally Compliant, as the decision did not involve any public consultation
3. Local shops are likely to displace existing shops which serve Fearnhead, resulting in loss of local amenity for existing citizens
4. Public transport services to the site are negligible in the developer's proposals. This site will overwhelmingly be served by car, which means that it fails the test of sustainability
5. MD 4.3 paragraph 24 states "Development should not introduce a level of vehicular activity into the existing
surrounding neighbourhoods which would change the character of these established
Residential areas." This is not possible given the existing road network and the access and egress points shown on the map. There would be significant change to the character of established neighbourhoods
6. Air quality mitigations fail to include impact on the A49 AQMA. I believe this omission to be not legally sound, given the Council's responsibilities to its citizens
7. Noise barrier mitigations are not covered adequately. The developer claims that their noise barrier will satisfy the relevant thresholds. The Local Plan should require the noise barrier to be constructed in full, and its effectiveness independently assessed, before any building works take place
8. Flood protection. The mitigations are welcomed but are not sufficiently stringent. The risk to local Residents from flooding should also be covered by a bond provided by the developer, to cover a fixed number of years from the start of development

10.4.8 I do not accept that the site performs well against the Local Plan's Sustainability Appraisal. As noted earlier, this is a 1980s style development which is dependent on the car

10.4.9 - not a sustainable site, hence unsound
10.4.12 These facilities would displace existing businesses