it is not possible to escape the conclusion that, had the
Council properly engaged with and heeded Natural England’s advice
and had the Council properly involved itself in a constructive
discussion with neighbouring authorities about both the impacts of
the plan and the ability to help in meeting Eastbourne’s unmet
housing need, the overarching development strategy of the submitted
LP – the planned quantum and distribution of development, and
whether the Council considers itself to be in a position to be able
to take any of Eastbourne’s unmet housing needs – could have
different. As has been shown, the Council chose not to accept the
advice ofNatural England in respect of emissions modelling but
selected a model which failed to take into account known factors
influencing future emissions. This approach, by overstating future
emissions and hence likely effects on the Ashdown Forest and
potentially other SACs, has had the potential to magnify
constraints, constrain development potential and so inappropriately
influence possible development scenarios. The Council has not been
transparent when presenting these constraints to Eastbourne Council
and other authorities. It has not actively shared its evidence base
and addressed key cross-boundary issues with other authorities in a
timely manner (including contributing meaningfully to SoCGs) and
has not worked collaboratively in jointly addressing the
implicationsof the reduction of its plan period and has not engaged
in constructive discussion in respect of the distribution of
development and the accommodation of Eastbourne’s unmet

What it should have done is simple

  1. Work proactively with Eastbourne to identify sites that met
    their unmet need
  2. Consulted on them
  3. Tested them with Appropriate Assessment
  4. Taken Natural England’s advice
  5. Then decided at submission, based on that advice, whether or
    not their inclusion would breach the Habitats Direction.

After all scientif opionion can vary and change, and exclusion
of sites because of HD reasons can only really be taken at the last
step before submission. By stating something as a scientific fact
when it was disputed Wealden took a foolhardy line. By the way the
head of policy at Weladen is a scientist.

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