Object

Representation ID: 21439

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Spatial development Option J which has been selected as the preferred basis for the BCP is reliant upon cross boundary provision being made. The sustainability appraisal of option J is not complete without understanding the sustainability and environmental implications of that cross boundary provision, which could be negative or positive.
The BCP reliance upon cross boundary provision for employment land to meet assessed needs is not currently assessed in the Sustainability Appraisal and Strategic Environmental Assessment (SASEA). The SASEA states at 1.4.4 that sites proposed through cross boundary provision will be subject to sustainability appraisal and strategic environmental assessment by those LPA that are making that provision.
We do not disagree that the LPA proposing to allocate land for the BCP needs should make such assessment. However, in the absence of certainty about where and even if such cross boundary provision will be made, it is necessary for the BCP SASEA to consider the options for meeting the needs. If the alternative to provision across boundary is additional release of land from Black Country green belt, then that option should be assessed. The various options that are being considered for cross boundary provision should also be assessed in the SASEA, to help inform which of those options is / are best suited to meeting the identified needs.
The completion of the SASEA will therefore require understanding of the options for delivering cross boundary provision to meet all of the identified need, and certainty that such provision will be made to deliver that land within the BCP period.