Sustainability Appraisal, Main Mods 2017
3.0 SA FINDINGS
SA Issues raised at Resumed Examination (2016)Site Allocation Options at Westwood Heath:
3.1 Appendix II details the new and refreshed SA of the two site allocation options - H42 (previously C13) & S1 (previously part of C31) raised at the Examination Hearings in September to December 2016 in relation to site options at Westwood Heath. The SA found similar effects for both site options: positive effects for sustainability objectives on housing, economy, communities, health & well-being & social inclusivity; neutral effects for biodiversity, historic environment, air & water quality, flood risk and crime; uncertainty/neutral effects for the built environment as all development will have to comply with other Plan Policies including BE1-3 for quality of the built environment.
3.2 Minor negative effects were indicated for both options with regard to transport objectives and the likely additional car usage on nearby congested roads. However, there are nearby bus services, both options are adjacent to the existing urban area of Westwood Heath, and there are footpaths across both site areas such that sustainable transport can be promoted with minor positive effects for reducing the need to travel. These effects will be synergistic and cumulative in the longer term.
3.3 Development at both site options will lead to loss of greenfield and Green Belt land with major negative effects for sustainability objectives on the prudent use of land. Development at both sites would have an impact on landscape quality. Mitigation measures have been identified through the updated landscape studies (February 2016) that indicate opportunities for development in this area without substantial adverse impacts to the wider landscape setting or Green Belt function. Further mitigation measures may be available at the detailed project design level but some uncertainty remains at this level of assessment. Both options will result in the loss of the best and most versatile agricultural land with negative effects that will be cumulative in the longer-term.
3.4 There are no international, national or local nature conservation designations on the site options although The Pools, a local wildlife site, is adjacent to the south of option S1, and Bockendon Grange Pond & Black Waste Wood are potential Sites of Importance for Nature Conservation (SINCs) nearby to the south of option H42. However, other Plan Policies are in place as mitigation measures to guide development and protect locally important biodiversity with neutral effects. There may be opportunities for biodiversity enhancements, particularly through an agreed Green Infrastructure strategy, for both options but uncertainty of such potential positive effects at this stage.
3.5 Neither option is within an area of high flood risk and there are no known important historic assets, so neutral effects for these SA Objectives.
3.6 Overall, the SA found similar effects for the two site allocation options. However, it should be noted that the SA findings are not the sole source of evidence to inform decision-making and other factors, including consultation representations, other technical information, and political reasons may inform the development of the Local Plan. It is understood that the reason for progressing site allocation H42 at this time is because development is limited to 425 new homes to ensure that the wider area issues for transport capacity are not adversely affected; the reason for not allocating S1 at this time is that it is safeguarded for future development when the required transport infrastructure is established to accommodate higher numbers of new housing.
Screening of Main Modifications for SA Significance
3.7 Most of the main modification amendments, deletions, additions or corrections were made to provide clarification and enhance guidance for development. These main modifications are not significant with regard to the SA. Other main modifications include provision of new/amended wording and removal/addition of sites and policies – and these may have significance with regard to sustainable development and consequently implications for the SA. Appendix I of this report details the findings of the screening of relevant Main Modifications and any likely significant effects for the SA.
3.8 The screening for SA significance identified that most Main Modifications (MMs) do not significantly affect the findings of the previous SA Reports (Submission, February 2015; Addendum February/June 2016), nor do they give rise to significant environmental effects. Many of the MMs had been considered and reported in the SA Addendum (February 2016) and responses provided to representations made through the public consultation and reported (June 2016). The requirement for refreshed or new sustainability appraisal of some MMs was identified and the findings are summarised in the following paragraphs.
New & Refreshed Sustainability Appraisal of Sites & Policies
3.9 The Appendix details the screening of the Main Modifications to the Local Plan for their significance with regard to the SA process and the potential for any significant effects, as required by the SEA Regulations. Most of the MMs are not significant with regard to the SA process as they provide correction, clarification or updating as a result of the Examination Hearings. Some MMs provide clarity with regard to development requirements and this confirms implementation of mitigation measures thus removing any uncertainty from the SA findings.
3.10 Other clarifications and updating may enhance positive or negative effects. Generally, any increase in housing numbers is likely to enhance the positive effects on housing and communities but may increase likely negative effects on sensitive environmental factors – and conversely with any decrease in housing numbers. These changes are not significant to the findings of the previous SA and are reported where relevant as a narrative in the Appendix. Summaries of the SA screening findings for key MMs are provided in the following paragraphs:
3.11 MM4 & MM7 Policy DS7 & DS10 Meeting the Housing Requirement: The categories are updated & the key change in the finalised figures is the updating of sites allocated in the Plan from 9,369 (Proposed Modifications February 2016) to 6,454 and the overall total of housing from 17,577 (Proposed Modifications 2016) to 17,139 homes. This takes account of sites completed and those with outstanding planning permissions during 2016, and the allowance for windfall sites. It should be noted that in comparison with the Submitted Local Plan, the housing numbers have increased from 12,964 dwellings to 17,139. However, the effects of this uplift has been appraised and reported in the February 2016 SA Addendum.
3.12 The number of sites allocated in the Plan since the Proposed Modifications (February 2016) reverts to a number of sites/homes (6,454) similar to that considered by the SA in the Submission Plan (6,188) and published in the SA Report (February 2015). This reflects the updating of evidence, particularly with many sites having been granted planning permission, and has potential implications for the SA. However, each component site option & allocated site has been subject to individual SA and the findings of the previous appraisals have been reported (February 2015 & February 2016).
3.13 Overall, the uplift in housing allocations from 6,188 to 6,454 new homes and the overall total housing change from 17,577 to 17,139 homes is not considered to be significant with regard to the previous overall findings of the SA (February 2015 & Table 4.1 2016).
3.14 MM8 Policy DS11 Allocated Housing Sites: The significant change from the individual sites assessed as part of the Submission and Proposed Modifications and as reported in the SA Addendum (February & June 2016) is the deletion of 6 site allocations: H04, H44, H47, H50, H52, & H53 – as a result of discussions at the resumed Examination September – December 2016. This has potential implications for each affected settlement/area, particularly with regard to cumulative effects. The removal of sites H44, H47, H50, H52, & H53 from the Modifications means that the SA findings revert to those reported in the Submission SA (January 2015) as any changes arising from Proposed Modifications are longer relevant.
3.15 One site allocation Red House Farm (HO4 for 250 dwellings) that had been in the Submission Plan was deleted from the Policy as a result of the Examination. The previous SA found positive effects for housing & communities; potential negative effects for loss of soil/greenfield, & SA Objectives associated with transport/car travel, and landscape. However, it was considered that there were sufficient mitigation measures through other Plan Policies to at least neutralise potential negative effects on landscape. The deletion of this one allocation will reduce the cumulative positive effects and may reduce the positive effects on poverty/social inclusion as the site is adjacent to Lillington, the most deprived neighbourhood in the District, introducing some uncertainty for this SA Objective. However, it will also reduce the potential negative effects associated with transport and loss of greenfield/soil resource. Overall, no significant changes to the SA findings.
3.16 MM34 Policy H1 Directing New Housing: The additional text, particularly in Policy Clause (d) provides clear mitigation measures for potential effects of small scale development on settlements, capacity of infrastructure & services, sustainable transport, and environmental factors. Generally, this will confirm the likely positive effects identified from previous SAs and remove any uncertainties by confirming mitigation for potential negative effects – both for individual settlements and cumulatively for the whole District.
3.17 MM45 Policy HNEW1 Custom & Self-Build Housing Provision: The new policy encourages developers to consider including dwellings for sale as self-build, custom-build or self-finish opportunities. The policy and new supporting text set the parameters for this requirement, and the justification for the inclusion of these opportunities, in line with the Self-Build and Custom Housebuilding Act 2015. The new policy was subject to SA and the findings presented in the SA Addendum Report (February 2016). The new policy will increase the mix of housing types within the District and expand opportunities for residents in choosing a home that is best suited to them. This also allows for development to cater for specialist needs (e.g. adaptable accommodation for the elderly and disabled) with the potential for major positive effects on housing, communities and health.
3.18 A key change from Proposed Modifications to Main Modifications is the removal of reference to sites over 100 dwellings – this will confirm the likely cumulative positive effects identified in the SA Addendum (February 2016) by not limiting possibilities to large developments. The further significant change is that proposals are now "encouraged" rather than "required" to consider custom & self-build which may introduce some uncertainty into the previous SA findings. However, overall, it is considered that the potential for positive effects remains – and this will be cumulative for the District in the longer term.
SA of Main Modifications to the Local Plan
3.19 The likely effects of the implementation of the proposed Main Modifications to the Local Plan remain similar to those reported in the SA Addendum Report (February & June 2016). Table 4.1 describes the likely changes arising from the initial proposed Modifications, most notably the uplift in housing numbers. The uplift in housing allocations from 6,188 to 6,454 new homes and the overall total housing change from 17,577 to 17,139 homes is not considered to be significant with regard to the previous overall findings of the SA.
3.20 Various modifications have provided clarity and further guidance and/or requirements for new development and this is likely to confirm positive effects. These modifications are also likely to confirm mitigation measures and this will reduce negative effects and any uncertainties that had been previously reported in the SA. These are unlikely to be significant individually but overall will improve the positive cumulative effects of the Local Plan; however, the cumulative negative effects on landscape and loss of greenfield remain – particularly for the urban extensions on the edge of Coventry.