Sustainability Appraisal - Publication Draft

The Trust believes that there is insufficient evidence to justify the allocation of the sub-regional employment site near Coventry Airport (hereafter referred to as the Coventry Gateway scheme) in the Local Plan. We are concerned that:

a) There is limited up-to-date ecological information to determine the environmental impacts of the Coventry Gateway scheme and other alternatives within the Local Plan evidence base

b) The provisions of policy DS16 have not been assessed within the Habitat Regulations Assessment dated March 2014.

c) The Sustainability Appraisal report 2014 and its associated appendices omit a formal assessment of the Coventry Gateway scheme against the District's Sustainability Objectives and fails to conclude why the site is promoted in the plan over other reasonable alternatives.

1) Evidence Base
In our consultation response to the draft Local Plan 2012, Warwickshire Wildlife Trust recommended that:

'The evidence base for the natural environment will ... have to be reviewed and updated in order to inform the sustainability appraisal for this site and any other reasonable alternatives that come forward as part of [the] review process.'

However, according to the Habitat Biodiversity Audit data (HBA) for Warwickshire, Coventry and Solihull (2012-2013), much of the habitat data for the land allocated for the Coventry Gateway scheme in Warwick District dates from 1997/98, with only a few small areas updated in 2006. The Gateway scheme was not included in the Warwick District Habitat Assessment 2008 and was not updated as part of the Landscape Sensitivity and Ecological & Geological Study - Landscape Assessment Update April 2014.

A planning application for the Coventry Gateway scheme was submitted in 2012. The application was accompanied by a detailed Environmental Statement (ES) which included up-to-date data on habitats, species and statutory and non-statutory wildlife sites within the proposed allocation, with the exception of Rock Farm potential Local Wildlife Site. Whilst this data may go some way to providing a baseline for the Coventry Gateway scheme, it is not included or summarised within the local plan evidence base and has not been referred to when assessing site allocations in the Sustainability Appraisal report 2014.

In paragraph 2.73 of the Local Plan Submission draft, the local authority broadly outlines the reasons for supporting the Coventry Gateway Scheme. The local authority quotes studies that have been undertaken to support the location of the allocation but these studies are not referred to in the local plan and it is not made clear if such studies are included within the local plan evidence base. Nor is it clear that these studies contain any wider sustainability assessment of the proposal and alternatives given the apparent focus on the economic merits of the proposal at the expense of any reference to environmental constraints and opportunities.

The Local Authority has not proposed alternative sub-regional site allocations as part of the local plan process, nor gathered associated environmental evidence to review the wider sustainability merits and constraints of such options.

We accept that it is unreasonable to require Warwick District to identify a range of alternative sub-regional employment sites alone when the review area for these sites will extend beyond the boundary of a single local authority area. We do believe however, that the local authority has a duty, under the Localism Act 2011, to work collaboratively with other local authorities in the Coventry and Warwickshire Local Enterprise Partnership (LEP) area to collate evidence for other sub-regional options in order to ensure that the preferred option is justified in accordance with sustainability principles. As the responsible local authority for allocating the preferred sub-regional site, we believe it is necessary for the results of this cross-boundary assessment to be present in the evidence base of this local plan so that the Gateway allocation, as with all other proposed housing and employment sites in the plan, can be reviewed using the sustainability Appraisal process.

2) Habitat Regulations Assessment
The local authority has updated the Habitat Regulations Assessment of the local plan in accordance with article 6(3) and (4) of the Habitats Directive; the findings of which are presented in the Habitat Regulations Assessment- Screening Report 2014. The report screens the likelihood that policies in the plan could impact on Natura 2000 sites; however the policies reviewed in the report were those detailed within in the 2012 Preferred Option draft and not the current submission draft of the Local Plan.

Paragraph 3.3.1 of the Habitat Regulations Assessment - Screening report 2014 states that:

'As the local plan is in development, this assessment will report the Local Plan Preferred Options as of May 2012. A further addendum may need to be prepared should the local plan policies or site allocations be materially altered'

The Trust believes that since 2012, the provisions of policies surrounding the Gateway Scheme have materially changed from a generic 'exploration of the case for the proposal' in policy PO8 to a specific 'allocation of land' in policy DS16 of the 2014 submission draft. The implications of this change should therefore be subject to further screening and added as an addendum to the 2014 screening report.

3) Sustainability Appraisal
The Sustainability Appraisal Report 2014 does not assess the Coventry Gateway site allocation against Warwick District's Sustainability objectives nor does it provide any assessment of the proposal against reasonable alternatives.

Article 5.2 of the European Directive 2001/42/EC "on the assessment of the effects of certain plans and programmes on the environment" states that:

"The environmental report shall include information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, [and] its stage in the decision-making process"

The Coventry Gateway scheme is a specific site allocation identified within the plan and is promoted by policy DS16. However, unlike all other specific housing and employment allocations, it is not reviewed or assessed within the Sustainability Appraisal report 2014.

The Directive further states that the report should contain information on:

"the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects" (Annex I (f) and
footnote)

There appears to be no evidence about such effects within the local plan evidence base and no assessment of these effects against the District's sustainability objectives using the Sustainability Appraisal methodology employed for all other housing and employment allocations.

"an outline of the reasons for selecting the alternatives dealt with" (Annex I (h))

There are no alternatives identified for sub-regional employment sites in the Sustainability Appraisal and subsequently no supporting information for selecting the Gateway scheme in accordance with sustainability criteria.

"the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme" (Annex I (g))

Without an assessment of the Coventry Gateway scheme against the Sustainability objectives there is no option to consider any measures that may be required within the local plan to reduce and offset any adverse effects of the proposal.

In the absence of information for the above, the Trust firmly believes that the Sustainability Appraisal fails to provide the necessary justification for allocating land for the Coventry Gateway proposal within the local plan.