Publication Draft Local Plan: Focused Consultation

Object

Representation ID: 67243

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: 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.