Sustainability Appraisal

Object

Representation ID: 67254

Received: 12/12/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

The consultation document does not clearly justify the proposed major amendments and the evidence to support them is unclear. For example no composite SA document has been published. Therefore there are concerns about compliance with the SEA regulations.

Object

Representation ID: 67281

Received: 14/11/2014

Respondent: Mrs Katherine Booty

Legally compliant? No

Sound? No

Duty to co-operate? No

Para 6.2 accepts significant cumulative long term negative effects but suggests these can be addressed by careful planning and the SA recommends strong policies to protect air quality. However argues that there are none and the proposed mitigation will make problems in the town centre worse. There is no way to alleviate the problem of poor air quality, to offer cycle paths elsewhere does not solve the problem.

Object

Representation ID: 67287

Received: 12/12/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Sustainability Appraisal has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014. This is a further representation on the Sustainability Appraisal following publication of new information by the District Council.

The SA has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014.

This SA Addendum recognises that the proposed sub-regional employment site ('Gateway') development could have a significant adverse impact on the Green Belt and its environment ("Ultimately development could result in loss of Green Belt and Greenfield land, and has the potential to significantly affect the landscape character, biodiversity and wetland features..."). The SA assesses the environmental impact as negative to highly negative (especially prudent use of land and natural resources); we consider that this under-estimates the damage that is likely to be caused by such a development.

The SA assesses the impact on the economy as highly positive; consequently, it assesses the impact on poverty, social exclusion, health and well-being as positive. For the reasons we have outlined in the sections above, the SA's assessment is based on flawed analyses and circular arguments.

The SA's assessment on housing and local communities is also erroneous. The 'Gateway' is claimed to support upwards of 10,000 new jobs but the site is located outside urban areas. As we have already shown, the site is not close to the areas of greatest socio-economic need (in the north of the CWLEP area). If many thousand new jobs were created as claimed, it would add great pressure on Warwick District to provide even more homes than the very high figure already proposed. The 'Gateway' site is in the Green Belt and surrounded by Green Belt, exacerbating the challenge of providing suitable housing in a sustainable way. We assess this impact as negative on housing and highly negative both on the local community and on reducing the need to travel.

Even though the SA recognises that the huge scale of the proposed 'Gateway' development could lead to potential large impacts, it assesses the effect on climate change as potentially positive as well as negative. We submit that the non-urban location, increased need to travel, lack of existing sustainable transport and huge scale of built form in the countryside would all lead to adverse impact on climate change.

Overall, the SA greatly over-estimates positive impact of the 'Gateway' and under-estimates the impact on the environment. The 'Gateway' site is an unsustainable location for development of large-scale employment facilities. Even if a sub-regional employment site were justified, there is no evidence that the proposed 'Gateway' site is the most sustainable location - there is no evidence of a methodical sustainability assessment process that compared alternative sites and selected the most sustainable location.

Conclusion

The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.

Object

Representation ID: 67345

Received: 12/12/2014

Respondent: Mrs Joyce Knight

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Several objectives in the sustainability assessment remain questionable

Object

Representation ID: 67424

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA objective 1 - The conversion of any 760 acre green belt site would make money for developers and a short term boost for the building industry and be able to claim a positive impact on the economy. The likelihood of the proposal being viable is not discussed. The NPPF states on achieving sustainable development there should be sufficient land of the right type in the right places. Paragraph 88 confirms that there must be very special circumstances for development in the green belt. The SA report fails to report on these important requirements.

Object

Representation ID: 67425

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? Not specified

Duty to co-operate? No

SA Objective 2 - The claim of a minor positive impact is untrue, there is currently not a good public transport service to Baginton village and the SA cannot guarantee that future developers can provide one. The lack of a rail connection for sustainable freight movement is not mentioned. the incorporation of the Gateway site in the Local Plan would fail this objective.

Object

Representation ID: 67429

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 3 - The SA fails to address the problem of inserting a major employment area for 10,000 workers in a rural site distant from the residential area it claims to benefit. Unemployed Nuneaton workers would have a 32 mile round trip. The only true answer to this objective is that if approved the Gateway proposal would significantly increase the need to travel.

Object

Representation ID: 67432

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 4 - Report ignores the problem of removing toxic waste deposited in the sludge lagoons and ignores the developers proposal to bury this waste in the earth bunds surrounding the site. The leaching of toxic water from the bunds into the River Avon is not considered.

Object

Representation ID: 67434

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 5 - This is not considered in the SA report. Zone B requires extensive earth movement which would be avoided with more prudent site selection for new development.

Object

Representation ID: 67435

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA objective 6 - This is not an objective assessment, building over the ancient Dunsmore plateau and installing earth bunds can only destroy the natural landscape producing major negative effects. English Heritage description of the earth bunds was 'alien land forms'.

Object

Representation ID: 67436

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA objective 7 - No assessment has been made on how the villages of Baginton and Bubbenhall will be affected by this level of development.

Object

Representation ID: 67437

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 8 - does not assess scheme but instead hopes damage to the historic environment will not occur. No consideration is given to the historic significance of the Dunsmore plateau.

Object

Representation ID: 67438

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 9 - Serious environmental problems are misrepresented as a minor negative effect. The government is now legally required to reduce air pollution and the Gateway is in opposition to this obligation.

Object

Representation ID: 67439

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 10 - It is unsupported that the development will lead to long term minor positive impacts on climate change. It ignores the impact of traffic to the site and the very excessive earth moving which will result in excessive CO2 generation.

Object

Representation ID: 67440

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 11 - The report acknowledges that the Avon below Zone A is a medium to high flood risk area but does not assess whether the proposed measures are adequate. The report does not include any hydrology calculation to assess whether large scale development will add to flooding problems.

Object

Representation ID: 67441

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 12 - The neutral impact against this objective acknowledges that the development is not sustainable development as set out in the NPPF. It is an area of speculative industrial development in a small village which would result in an unbalanced community. It would result in extensive commuting.

Object

Representation ID: 67442

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 13 - This is not considered in the SA report. The NPPF expects that sustainable development should create a high quality built environment with accessible local services.

Object

Representation ID: 67443

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 14 - The assessment is seriously deficient as it fails to consider the effects of 1,000 diesel vehicles travelling close to housing on the northern edge of Baginton. The seriousness of diesel particulate pollution on human health is well documented

Object

Representation ID: 67444

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

SA Objective 15 - The admission that the development will only have an indirect minor positive effect on this objective should be taken into consideration by Warwick District Council and the Inspector of the Local Plan as it undermines the claim of very special circumstances.

Object

Representation ID: 67445

Received: 15/12/2014

Respondent: Hazel and Robin Fryer

Legally compliant? No

Sound? No

Duty to co-operate? No

The SA is inadequate as it fails to analyse the serious sustainability problems inherent in the proposed Gateway site. In view of the number of omissions and lack of objective analysis the report should not be accepted as a valid SA of the site.

Object

Representation ID: 67497

Received: 12/12/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

The Council has not responded proactively to the SELS, which should have included a strategy for supporting sustainable growth in the Coventry and Warwickshire area. As required under Article 5(i) of the Strategic Environmental Assessment Directive (SEA Directive), where an environmental report is prepared, the responsible body should undertake an assessment of the likely significant effects, accounting for reasonable alternatives.
In response to the 2014 SHLAA additional evidence was submitted detailing the suitability of Land south of Baginton relating to landscape impact, and air and noise pollution. The Council have not responded to this in updating the SHLAA or revised assessment of the deliverability of the site. It has therefore not been in the public domain as a reasonable alternative. The SHLAA and SA should be iterative documents responding to new evidence. Land at South Baginton should have been considered as an appropriate Sustainable Urban Extension to
support the arising need for housing in Warwick District and the need arising from the Coventry Gateway site. The Council has made a number of major amendments to the Draft Local Plan, which includes the redistribution of housing and employment sites. RPS considers that there are a number of changes which have not been subject to the SA process and therefore have not been drafted in line with the SEA Directive. In addition to including new employment sites, the Council has deleted three from the Draft Local Plan and included provision for additional housing on two previously identified sites. The Council is right to appraise the recently included sites within the plan, however the Council should also have appraised the likely sustainability impacts of removing sites for employment and adjustments made to housing sites. The development of the Local Plan should, at every stage of development, be complemented by a SA. This Focussed Consultation is not adequately supported by an SA of these changes. To date, the Council's SA is incomplete and legally noncompliant. The Local Plan cannot therefore be adopted until these changes are made. In the Focussed Consultation the Council have decided to remove three potential employment allocations, totalling 19.7 hectares to be replaced by an allocation for 11.7 hectares.it is unclear why the Council have responded to the shortfall of employment land set out in the SELS by removing additional employment land from the Draft Local Plan.
The Gateway site has been subject to an SA which recorded a number of negative scores against the Council's SA Objectives. RPS does not believe that this assessment fairly reflects the cumulative impacts of development, which could enhance a number of scores in the appraisal. Slight negative scores have been recorded against SA Objectives relating to sustainable transport and the reduction in the need to travel. The Council justify this in terms of the walking distance to the site from Coventry Railway Station, 3.5 miles from the site. This is an unreasonable indicator, which does not consider where the likely workforce will be coming from. Page 69/70 of the SELS acknowledges that there is a high level of worklessness within 3km of Zone B of the CG site. Not only is the development expected to increase the levels of employment in the area but it can facilitate sustainable forms of transport, as 3km is considered an acceptable distance to travel to work by either walking or cycling. RPS also considers that the appraisal should be undertaken in the context of strategic housing allocations. Land South of Baginton as a sustainable housing site on the edge of Coventry, which would complement the proposed development at CG. This would provide housing along with local community facilities in a prime location, within easy access of a range of employment types. Considered together, this would support increases to the SA scores, creating positive outcomes for sustainable transport, the reduction in the need to travel and access to services. There is strong support for the CG site to proceed and Warwick District need to look seriously at suitable locations to support the employment growth at the Sub-Regional site.Land south of Baginton has been never been considered as a potential strategic allocation by the Council. As RPS have identified, the site is suitable, available and achievable for development and therefore constitutes a reasonable alternative site. The Council are mandated under the SEA Directive to consider all potential reasonable alternative sites in the development of the Local Plan.

Object

Representation ID: 67542

Received: 12/12/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

These representations must be read in conjunction with those submitted by HOW Planning in response to the Warwick Local Plan 2011-2029 Publication Draft consultation,
submitted in June 2014.
The objections raised in June, which demonstrate that the Plan is unsound, still stand and as detailed in the accompanying representation forms relate specifically to draft policies DS4, DS6, DS7, DS10, DS11, DS19 and DS20.
These representations have been prepared to specifically respond to the publication of the Coventry and Warwickshire Strategic Employment Land Study (ELS) October 2014, which is a key part of the Council's evidence base underpinning the emerging Plan. It is understood that the Council in the preparation of the Publication version used the emerging ELS (March 2014) to inform the Plan, however presumably at the time the ELS had not been finalised and certainly it was not publically available.
Barwood appointed specialist consultancy Peter Brett Associates (PBA) to carry out an independent assessment of the Study, in order to establish the key implications for the housing market area.
A report by PBA is attached, however in summary it is clear that if the local authorities accept the findings and recommendations of the ELS, then a significantly increased
amount of housing will need to be delivered over and above the Strategic Housing Market Areas demographic scenarios if the economic strategy is to be delivered. There would
need to be compelling reasons to justify why the recommendations of the report might not be followed.
The ELS and in particular its recommendations have implications which go to the heart of the emerging Local Plan and have a specific bearing on draft policy DS6: Level of Housing Growth and DS20: Accommodating Housing Need Arising from Outside the District.
Previous work undertaken by PBA, presented in Barwood's June representations, highlighted that the Council had underestimated its proposed level of housing growth and
therefore that draft policy DS6 is unsound. The recommendations of the ELS only serve to support PBA's findings.
Draft policy DS20 sets out that in the event that unmet housing need arising outside the District needs to be met within the District, then a review of the Plan will be carried out.
Barwood's previous representations highlighted the shortcomings of this policy, but the Council's approach is undermined further with the recommendations of the ELS clearly pointing towards the need for additional housing across the HMA. The likelihood therefore of additional housing being needed in the District is increased by the ELS
recommendations and there can be no assurance that the Council's approach will translate to the HMA's unmet housing requirements being provided for.
In summary, as set out in the attached representation forms, it continues to be Barwood's firm opinion that the Council's new Local Plan cannot be considered sound
unless fundamental amendments are made as detailed in these representations and those submitted in June.

Support

Representation ID: 67561

Received: 12/12/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

DS1, 2. 3, 15, H0, H1, TR5 sound