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North Warwickshire's Local Plan: Draft
Submission Version
Sustainability Appraisal Report: Appendices
Prepared by LUC
December 2017
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Project Title: Sustainability Appraisal of North Warwickshire‟s Local Plan
Client: North Warwickshire Borough Council
Version Date Version Details Prepared by Checked by Approved by
1 01/12/17 Draft SA Report for the
Draft Submission version of the Local Plan - Appendices
Kate Nicholls
Donald McArthur Josh Allen Steven Orr
Jeremy Owen Jeremy Owen
2 08/12/17 Final SA Report for the Draft Submission version of the Local Plan - Appendices
Kate Nicholls Donald McArthur Josh Allen Steven Orr
Jeremy Owen Jeremy Owen
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North Warwickshire's Local Plan: Draft
Submission Version
Sustainability Appraisal Report: Appendices
Prepared by LUC
December 2017
Planning & EIA Design Landscape Planning Landscape Management Ecology Mapping & Visualisation
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Contents
Appendix 1 1 Consultation responses received in relation to the SA Reports for the Pre-Submission Site
Allocations Plan (June 2014), the Draft Development Management Plan (September 2015) and the
Draft Local Plan (February 2017) 1
Appendix 2 31 Review of plans, policies and programmes 31
Appendix 3 62 Baseline information 62
Appendix 4 76 Audit trail of policy development for the Draft Local Plan 76
Appendix 5 88 Detailed SA matrices for the strategic policy options 88 SA Matrices for the Growth Options (prepared in June 2016) 89
Appendix 6 126 Assumptions used in the SA of site options 126
Appendix 7 166 Detailed SA matrices for reasonable alternative site options (both allocated and unallocated) 166 Residential and Mixed-Use Site Options 167 Atherstone and Mancetter Site Options 167 Polesworth and Dordon site options 223 Site options Adjacent to Neighbouring Local Authorities 314 Coleshill site options 324 Grendon and Baddesley Ensor site options 363 Hartshill with Ansley Common site options 426 Kingsbury site options 477 Water Orton site options 494 Ansley site options 505 Newton Regis site options 519 Shuttington site options 538 Warton site options 556 Wood End site options 598 Old and New Arley site options 632 Austrey site options 652 Curdworth site options 697 Fillongley site options 713 Hurley site options 729 Shustoke site options 742 Employment Site Options 746 Atherstone & Mancetter Site Options 746 Polesworth and Dordon site options 761 Curdworth site options 772 Old and New Arley site options 775 Sites Options Adjacent to Neighbouring Local Authorities 779
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Site options previously subject to SA but which are no longer reasonable alternatives (included for
reference) 786
Appendix 8 845 Audit trails of site options 845
Appendix 9 918 Detailed SA matrices for Draft Submission Local Plan policies 918 Chapter 6 – Sustainable Development 919 Chapter 7 – Spatial Strategy 922 Chapter 8 - Housing 935 Chapter 9 - Employment 945 Chapter 10 - Environment 953 Chapter 11 – Services and Facilities 969 Chapter 12 – Transport 979 Chapter 13 – Development Management 992 Chapter 15 - Allocations 1012
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SA of North Warwickshire‟s Draft Submission Local Plan -
Appendices
1 December 2017
Appendix 1
Consultation responses received in relation to the SA
Reports for the Pre-Submission Site Allocations Plan
(June 2014), the Draft Development Management Plan
(September 2015) and the Draft Local Plan (February
2017)
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 2 December 2017
Table A1.1: Consultation responses received in relation to the SA Report for the Pre-Submission Site Allocations Plan (June 2014)
Note that this table was originally presented in the SA Report for the Draft Local Plan (February 2017) and therefore references in the final column to „this SA
Report‟ and particular chapters/appendices refer to the February 2017 SA Report for the Draft Local Plan.
Consultee Comment Response/action
Tamworth Borough Council The dates used in the Sustainability Appraisal do not match the
dates for the plan period. If land is released for employment to increase the attractiveness of the Borough then surely the level of new housing should match this increase? Attracting new people to an area will not necessarily push the existing population out to
„make room‟ for them. An adequate level of housing should be provided which takes into account the natural population change and the desire to increase migration into the Borough.
Most of this comment does not relate directly to the
SA. The evidence behind the Council‟s housing figure takes into account social and economic considerations and is explained in the Draft Local Plan.
With regards to the dates used in the SA, this comment is superseded by the change to preparing a comprehensive new Local Plan. The dates referred to
in this SA report reflect the dates covered by the new Local Plan.
Tamworth Borough Council Para 1.13: The Scoping Report was carried out 7-8 years ago, surely this is now out of date and a new Scoping Report and consultation should have been done to support this Sustainability
Appraisal?
It is recognised that the original SA Scoping Report for the LDF was carried out some time ago; however elements of the Scoping work, such as the policy
review and baseline information, have been regularly updated during the preparation of various SA reports which have been subject to consultation.
Tamworth Borough Council Para 1.15: It is not clear from this paragraph if the Scoping Report has been updated or not? If it has been updated it should have been subject to a minimum 5 week consultation in line with the EU
SEA Directive requirements.
As above, the Scoping work has been regularly updated throughout the SA process for the Site Allocations Plan and other documents that now
comprise the Local Plan.
Tamworth Borough Council Para 1.19: The sites which were not considered to be reasonable alternatives – which sites are these and why have they been removed from the SA process? Has an assessment been carried out to support the removal?
Appendix 8 in this SA report lists all of the site options that have been considered at each stage of the SA process for the Site Allocations Plan and now the comprehensive Draft Local Plan and provides reasons
why certain sites are no longer considered to be reasonable alternatives. Where this is the case, the SEA Regulations do not require unreasonable site
options to be subject to any further appraisal work.
Tamworth Borough Council Table 2 – objective 4 should be to meet local needs and needs of Tamworth.
It is assumed that this comment relates to SA objective 4 in the SA framework. While the needs of
Tamworth are not explicitly referred to in the wording of the SA objective, relevant policies have been appraised in light of the identified need to provide housing for Tamworth and this is reflected in the scoring against SA objective 4 as appropriate.
DTZ on behalf of E.ON E.ON considers the Sustainability Assessment of the Site Allocations document in respect of Policy EMP10 to be unsound.
The Land at Hams Hall (site of the former Power Station B Site) has been appraised for potential
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 3 December 2017
Consultee Comment Response/action
Paragraph 6.16 of the SA states that „the site has not been appraised for other potential uses (e.g. housing) as the Council considers that the location of the site in the green belt means that the only reasonable option for the development of the site would
be the reinstatement of the power station for alternative power generating uses, which would have regional and national significance‟. The SA must consider alternative uses for the site, as it is entirely reasonable to do so. Specifically, Class B8 development is an entirely reasonable alternative use. An application for this use has
been recommended for approval, the site was initially identified
within the Core Strategy for Class B8 employment use, the most recent evidence base identifies the site should contribute towards a regional need. The Strategic Sites Study is once again considering the matter of logistics need in the region and it is understood that the report will be published late 2014 or early 2015. Given all these factors it is clearly unsound to not consider an alternative
use of the site.
employment uses – see the detailed appraisal matrices for site EM4 in Appendix 7 and summarised in Chapter 5. The site (approximately 20ha) has been allocated in the Draft Local Plan for removal from the Green Belt
and identified for employment purposes including B1, B2 and B8 uses appropriate to the location reflecting the proximity with, and sensitivity of, the BMW engine production facility adjoining the site. The Borough is keen to support the retention of
employment uses and sites in smaller sustainable
settlements, like Curdworth, to help maintain and sustain employment and economic opportunities in the rural areas. The Council does not consider the redevelopment of the site for residential development to be a reasonable
alternative due to the fact that the site is in current commercial use as an industrial estate. Furthermore, the site currently suffers from dislocation and separation from the main settlement due to the busy
A4097, which lacks controlled pedestrian links across to the village from the employment estate.
Barton Wilmore on behalf of Taylor Wimpey UK
Re: site POL6 In relation to the Sustainability Appraisal, we would ask the Council to note that the proposed development is to include an improvement to the existing bus service provision, by extending the route more fully into the eastern part of Polesworth. This is in our view a significant consideration in terms of the Site‟s sustainability credentials.
In relation to Sustainability Appraisal Objective 1 – Access to services, not only will this provide a sustainable connection for new
residents on site POL6, but it will also improve sustainable transport connections for existing residents who live in close proximity to the Site. Whilst we appreciate that the Council have focussed on walking
distances for this Objective 1, we would consider this to be an unnecessarily constrained method for assessing accessibility to services. In our view, the reassessment of the Site by considering the improved bus service provision, would also impact positively on Sustainability Objective 15 – Sustainable transport and
Noted; however the appraisal has been carried out in line with the assumptions as set out in the SA report in order to ensure consistency between the appraisal of all site options. It is not appropriate to take into account additional information about detailed proposals for certain sites, where the same information may not exist for other site options, as this could
result in the SA findings being skewed towards those site options where development proposals have been
worked up in more detail. POL6 is no longer considered to be a reasonable alternative option because it has since been
developed.
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 4 December 2017
Consultee Comment Response/action
Sustainability Appraisal Objective 19 – Employment opportunities.
Barton Wilmore on behalf of Crisps Farm Ltd. and the
Birmingham Diocesan Board of Finance
Re: site AUS14 In relation to the Sustainability Appraisal, we would ask the Council
to review the assessment for Sustainability Appraisal Objective 2 – Vibrant and active communities. In our view site AUS14 should score positively on this matter due to the proximity to the key community facilities in Austrey (the Church, Village Hall, the Village Shop, Post Office, Primary School and Public House) and also the positive impact that the proposals will have on this provision through the delivery of required car
parking facilities and a Village Green, which is expected to be used to complement these facilities. It is also not immediately apparent as to why all of the remaining sites in Austrey score „+‟ for Sustainability Appraisal Objective 15 – Sustainable transport, whilst Site AUS14 scores „+/-„. The Site is as well located in relation to public transport provision as other
sites, which score „+‟ and thus we would ask that this element of the Site assessment is reconsidered accordingly. We also note that the Historic Environment Assessment references several features of interest within Austrey. The landowners are aware of these matters and, subject to careful design and
appropriate mitigation, do not consider that they have a significant impact on the development potential of the Site.
Noted; however the appraisal has been carried out in line with the assumptions as set out in the SA report in
order to ensure consistency between the appraisal of all site options. It is not appropriate to take into account additional information about detailed proposals for certain sites, where the same information may not exist for other site options, as this could result in the SA findings being skewed towards those site options where development proposals have been
worked up in more detail.
Inland Waterways Association, Lichfield Branch
Re: sites ATH1, ATH2 and ATH6 (part) IWA considers that the Sustainability Appraisal Table 5.1 underestimates the negative impacts on the landscape character (7) and built environment including cultural heritage (8) of these sites adjacent to the Coventry Canal.
The Coventry Canal is a historic waterway and valuable amenity and recreational corridor providing leisure boating, walking, angling, cycling and nature conservation benefits to the area. Development of open land areas adjacent to the canal will diminish
its attractiveness to the detriment of its heritage, amenity, its users and the local economy. There should be no „uncertainty‟ about the negative impact on the built environment/cultural
heritage score for ATH1 and ATH2. ATH2 also provides attractive views from the canal towards the Merevale Estate including its historic boundary wall which has „significant‟ landscape character and cultural heritage. The area of ATH6 (western part) should exclude the canal marina and boatyard at Baddesley Basin which is not available for redevelopment.
Noted. In line with the assumptions that were set out in the SA report for the Draft Local Plan, the score for all site options in relation to impacts on the built and historic environment were uncertain as it was not possible to assess with certainty the nature of impacts
until detailed proposals for each site option are known at the planning application stage. As described in Chapter 2 of this updated SA report, all of the site scores for SA objective 8 have been updated to reflect
the revised assumption which draws on the more detailed heritage assessment that has now been undertaken.
Mrs Crockford It is our belief that this appraisal with respect to certain allocated The site options at Polesworth have been subject to SA
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 5 December 2017
Consultee Comment Response/action
sites in Polesworth is flawed. The summary spreadsheet is poorly organised with comments relating to the 20 key issues spread around the whole document. We can only comment based on our interpretation of the 20 points.
Looking at the Polesworth Allocations and alternatives particularly POL7 and Pol13 we would ask the following points to be considered: [Consultee goes on to comment on the specific scores for these two sites in relation to each SA objective and requests various changes to scores].
in line with the assumptions set out in the SA report.
Environment Agency We acknowledge that your Sustainability Appraisal considers the benefits of alternative sites, however we recommend that this is expanded to more clearly demonstrate how the requirements of the Sequential Test have been fulfilled.
The presence of flood zones 2 and 3 has informed the definition of reasonable alternatives for appraisal, including many of the sites allocated within the Draft Local Plan. The presence of significant areas of flood zones 2 and 3 within site boundaries has been used alongside other material considerations to mark site
options as unreasonable alternatives. In addition, site options containing areas classed as Flood Risk Zone 3 are considered likely to have a significant negative effect (--?) on SA objective 12 (Climate Change Adaptation). Site options that contain an area that is
classed as Flood Risk Zone 2 are recorded as likely to have minor negative effects (-?).
Environment Agency We have reviewed the supporting Sustainability Appraisal and welcome the comments in Appendix 3 that the SA will be updated once the findings of the Level 2 SFRA have been made available.
The findings of the Level 2 SFRA will be used to inform the appraisal of site options for the Submission (Reg. 19) Local Plan if available at that time. [Note that this was not able to be done as the Level 2 SFRA was not yet available].
Bloor Homes Re: site POL12 [Consultee disagrees with various information provided in the Local Plan in relation to this site and refers to additional site-level evidence studies which are provided as part of the consultation
response.] As such, and taking into account this new evidence, the
Sustainability Appraisal which accompanies this draft pre-submission document should also be revised. In its current form it states that proposed allocation POL12 would directly affect a Local Wildlife Site. It is requested that this statement be removed.
Noted; however the appraisal has been carried out in line with the assumptions as set out in the SA report in order to ensure consistency between the appraisal of all site options. It is not appropriate to take into
account additional information about detailed proposals for certain sites, where the same information
may not exist for other site options, as this could result in the SA findings being skewed towards those site options where development proposals have been worked up in more detail. However, overall the site is considered to be a sustainable location for development and has been
allocated within the New Local Plan. In addition, the
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 6 December 2017
Consultee Comment Response/action
draft Local Wildlife Site status has been removed.
Table A1.2: Consultation responses received in relation to the SA Report for the Draft Development Management Plan (September 2015)
Note that this table was originally presented in the SA Report for the Draft Local Plan (February 2017) and therefore references in the final column to „this SA
Report‟ and particular chapters/appendices refer to the February 2017 SA Report for the Draft Local Plan.
Consultee Comment Response/action
Environment Agency We have reviewed the LUC Sustainability Appraisal Report for this
plan, dated September 2015. Table 3.1 concludes that water quality problems in the borough will be addressed without any additional consideration in the form of Development Management Policies through NW10 and NE13.
However, as discussed [elsewhere in the consultee‟s response] we consider the adopted policy references to be too brief to be wholly effective on their own. The recommended policy additions to this plan will provide additional detail to address the water quality issues particularly pertinent to this borough and to provide detailed enough requirements to ensure that development meets the
required standards. Similarly the SA concludes that although flood risk is significant in the borough, existing policies in the Core Strategy coupled with the proposals contained within the emerging Site Allocations document (which currently includes sites as significant risk of flooding) will ensure these issues will be addressed satisfactorily. Closer
inspection of these policies however shows the existing policies only „manage the impacts of climate change‟ and ensure no increase in risk through „loss of floodplain capacity‟. In line with paragraph 100 of the NPPF development should not only seek to
meet these requirements but also to reduce flood risk where possible. The recommended additions to policy outlined [elsewhere in consultee‟s response] will not only provide more specific local
requirements, but should also work towards reducing the level of risk posed to the borough through deculverting rivers, providing a development easement for the unobstructed path of overland flows and to enable better access to watercourses for essential long-term flood defence maintenance. In light of this we advise that the above [elsewhere in consultee‟s response] changes are
incorporated into the plan in order to ensure the suite of policy
Some of these comments relate to the wording of
policies rather than the SA itself. Draft policy LP35: Water Management has been revised to incorporate the requirements outlined by the Environment Agency.
Table 3.1 in the SA report recognises that the issue of flood risk could be more effectively addressed through more detailed and up to date policies.
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 7 December 2017
Consultee Comment Response/action
requirements for development in the borough are specific to the locality, fully reflective of the evidence base and effective in their implementation.
Planning Prospects Ltd. on behalf of St Modwen Developments Ltd.
Disagrees with provisions of the Sustainability Appraisal in relation to the appraisal of policy DM12: The Meaningful Gap. Core Strategy policy NW19 seeks to maintain a meaningful gap between Polesworth and Dordon, and Tamworth. As noted elsewhere in these representations draft policy DM12 as proposed would make this more restrictive; indeed, even more restrictive
than Green Belt policy. In this context the assessment of draft policy DM12 cannot be the same as that for the „Reasonable Alternative‟ of „no policy‟ in relation to SA objective 4 (Providing decent and affordable housing to meet local needs). Draft policy DM12 is given a negative/question mark rating for this
objective. There should be no question mark here. The draft policy would have a negative impact in relation to this objective. It would restrict significantly the availability land in this area for housing development beyond the extent suggested by policy NW19, and hence impact negatively on the ability to provide
housing.
The RA is given the same, negative/question mark rating. However, excluding draft policy DM12 would create no negative impact in relation to this objective as the position would be unaltered from the current situation, whereby control is provided by policy NW19. The RA should therefore have a neutral rating in relation to this objective.
The same observation can be made in relation to SA objectives 18 (economy) and 19 (employment). Draft policy DM12 would have a
negative impact in relation to these objectives, restricting significantly the availability of land in this area for employment development, meeting the needs of business and creating local access to jobs. The RA should have a neutral rating in relation to
this objective, as the position would be unaltered from the current situation. A similar observation can be made in relation to SA objective 6 (recreation). Draft policy DM12 should be given a negative rating in this regard, not a positive one. It would prevent the
The detailed justification for the scores given to policy DM12 and the reasonable alternative option were set out in the SA matrix for these options in Appendix 3 of the SA report. As explained there, the uncertainty was included in the score as it was not yet certain what development proposals might come forward in the meaningful gap area that could be restricted by the
policy.
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 8 December 2017
Consultee Comment Response/action
development of infrastructure, buildings and other facilities which might otherwise be beneficial in supporting the recreational and cultural use of this area.
In relation to SA objective 7 (landscape) draft policy DM12 should again be given a negative rating. By imposing controls on this area which are even more restrictive than Green Belt policy, it would have the effect of creating development pressure elsewhere, including in areas which might have more value in terms of their natural environment and landscape character.
The Sustainability Appraisal should be amended to reflect these
observations.
Table A1.3: Consultation responses received in relation to the SA Report for the Draft Local Plan (February 2017)
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
DLP222 - David Brookes Concerns raised in relation to the loss of open countryside and
ecological habitat, including ancient trees, and the urbanisation and
intensification of growth around Polesworth and Dordon.
Traffic congestion and flood constraints in Polesworth highlighted.
Concerns raised in relation to the capacity of existing road
infrastructure, services and facilities to accommodate additional
growth.
Comments relate to sites POL/DOR1 and POL23.
These sites have been appraised using clearly defined
and consistently applied assumptions as set out in
Appendix 6 of the SA Report. These assumptions are
based upon an agreed SA Framework that has been
subject to consultation and is set out in Table 2.2 of
the SA Report. The assumptions draw on the most up-
to-date evidence.
Loss of greenfield land has been assessed via SA
objective 7 and impacts on biodiversity have been
assessed via SA objective 9.
Information about the capacity of services and facilities
is not available on a consistent basis across the
Borough to be used in the SA. It has therefore been
assumed that developments would contribute to
ensuring sufficient capacity is available to meet the
needs of the new communities, either through
investment in existing facilities or the development of
new services and facilities. This has been explained in
Chapter 2 of this updated SA report.
DLP234 - Fleur Fernando Concerns raised in relation to the capacity of existing
infrastructure, services and facilities to accommodate additional
Loss of greenfield land has been assessed via SA
objective 7 and impacts on biodiversity have been
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 9 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
growth.
Concerns raised in relation to the loss of open countryside and
ecological habitat.
assessed via SA objective 9.
Information on the capacity of services and facilities is
not available on a consistent basis across the Borough
to be used in the SA. It has therefore been assumed
that developments would contribute to ensuring
sufficient capacity is available to meet the needs of the
new communities, either through investment in
existing facilities or the development of new services
and facilities. This has been explained in Chapter 2 of
this updated SA report.
DLP242 - Paula Nichols Concerns raised in relation to the capacity of existing road
infrastructure, services and facilities to accommodate additional
growth.
Furthermore, the representation raises concern re: the potential for
reductions in air quality associated with increases in road
congestion.
Concerns raised in relation to the loss of open countryside and
ecological habitat.
North Warwickshire contains no Air Quality
Management Areas (AQMAs). AQMAs identify areas
which contain particularly poor air quality to justify
active management. Without AQMAs to help identify
spatial variations in the quality of the air in the
Borough, it is difficult to consistently and accurately
assess the implications of new development options on
local air quality (SA objective 11), including adverse
effects on people‟s health (SA objective 3). Air quality
monitoring in recent years has revealed that annual
mean levels of nitrogen dioxide (NO2), often
associated with traffic-related pollution, has been
declining. However, it is acknowledged that significant
growth within the Borough could reverse this trend.
SA objective 15 promotes increasing use of public
transport, cycling and walking to reduce the use of the
private car. In relation to this objective, the SA has
assessed the proximity of site options to town centres
and public transport links, i.e. the likelihood that new
residents and employees will travel via alternative
means to the private car. This is considered an
appropriate proxy for assessing the likelihood of
significant increases in traffic related air pollution. The
cumulative effects of the general growth proposed in
the Borough on traffic levels and air quality have been
assessed in the cumulative effects section in Chapter 6
of this SA Report.
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 10 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
Information about the capacity of services and facilities
is not available on a consistent basis across the
Borough to be used in the SA. It has therefore been
assumed that developments would contribute to
ensuring sufficient capacity is available to meet the
needs of the new communities, either through
investment in existing facilities or the development of
new services and facilities. This has been explained in
Chapter 2 of this updated SA report.
Loss of greenfield land and landscape impacts have
been assessed via SA objective 7 and impacts on
biodiversity have been assessed via SA objective 9.
DLP246 - Polesworth and
Dordon Parish Councils
Concerns raised regarding uplift in housing requirement from Core
Strategy and states this change is not justified or assessed in
sustainability terms. Alternatives for the housing distribution have
not been considered.
Concern raised in relation to various sustainability issues which
may result from the development of 2,000 new homes at land to
the east of Polesworth and Dordon, particularly in terms of
infrastructure capacity, landscape and wildlife. Consultee
highlights that the site performs negatively against five of the
twenty SA objectives with only one of the other 23 assessed sites
having more negative effects recorded. Other alternatives have
not been seriously considered despite the SA showing that other
options perform more favourably.
The Council‟s justification for the increased housing
requirement and the SA findings for the different
delivery options considered are presented in Chapter 4
of this SA report.
Each site option has been appraised using clearly
defined and consistently applied assumptions as set
out in Appendix 6 of the SA Report. These assumptions
are based upon an agreed SA Framework that has
been subject to consultation and is set out in Table 2.2
of the SA Report. Overall the representation seems to
agree with the SA. Reducing use of the private car,
which is likely to reduce traffic and congestion, is
assessed through SA objective 15. The effects of
development on landscape and wildlife are assessed
via SA objectives 7 and 9 respectively.
In accordance with the PPG, the SA has assessed all
options in the same level of detail. The Council‟s
reasons for selecting or not selecting site options are
presented in Appendix 8 of the SA Report.
DLP247 - Polesworth and
Dordon Parish Councils
Same as DLP246 above. See response to SLP246 above.
DLP266 - Pegasus Group on
behalf of the Richborough
Estates (this representation has
been presented across six
Concern raised that the SA has not informed the plan, given that
the Local Plan was produced in August 2016 and the SA was
produced in February 2017.
Concerns raised that the SA has not considered all reasonable
The Draft Local Plan was consulted on between 10th
November and 31st March 2017. While the SA was
prepared alongside the Draft Local Plan and influenced
its development, the SA Report was consulted upon in
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 11 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
document and addresses six
sites)
alternatives, particularly land West of Packington Lane, Land at
Barn End Road and Land North of Blythe Road Coleshill.
Land at Barn End Road has not been considered in its entirety (as
site WAR7 only contains part of the site) and that the reason for
discarding the site is not valid. Land south of Blythe Road,
Coleshill scores higher for many of the SA objectives than a
number of the sites taken forward at this stage. Only part of this
site has been considered through the appraisal of SLA59. The
representation also highlights the (++) recorded in the SA for
sustainable transport and challenges the (?-) recorded in terms of
biodiversity, as well as the scores recorded for cultural heritage,
economy and efficient use of land.
Queries findings of the SA in relation to land at Birmingham Road,
Water Orton for access to services and facilities and sustainable
transport and developing and supporting vibrant and active
communities as the site is located within 640m of a community
centre. The negative effects scores recorded for this site in the SA
Report relating to the natural environment, landscape and cultural
heritage are all queried in the representation. Effects relating to
the economy and efficient use of land and landscape (North of
Blythe Road only) have also been queried.
The allocation of West of Packington Lane could provide
opportunities for landscape improvements.
It is stated that that the explanation for not including land east of
Packington Lane (PS153) and land south of Blythe Road (SLA59) is
not site specific to the site (“Green Belt release not proposed for
Coleshill”) and has not taken into account the likely landscape and
visual effects.
early February up to the end of March. The
consultation period was extended until March 2017, to
allow consultees time to consider both documents
together. The delay in the publication of the SA
allowed time to reflect the content of the Draft Local
Plan as it was published for consultation.
Furthermore, Chapters 2 and 4 of the SA Report also
describe how previous iterations of the SA have fed
into the plan-making process.
Chapter 2 of the SA Report sets out how reasonable
alternatives were identified and notes that a number of
sites submitted to the Council were not deemed to be
reasonable for a number of reasons. Whilst the SA
Report explains how alternatives have been identified
and assessed, it is the role of the Council to identify
reasonable alternatives.
The reasons for each site being allocated or not in the
Local Plan are provided in Table A8.1 in Appendix 8 of
the SA Report. It states there that site WAR7 (land at
Barn End Road) is no longer considered to be a
reasonable alternative as part of the site has planning
permission. Land West of Packington Lane and Land
North of Blythe Road Coleshill are also featured in the
audit trail. There are multiple factors that influenced
the Council‟s decision-making, as reflected in the SA.
All sites have been assessed in line with the SA
framework, which was agreed to ensure consistency
across the SA assessments. Not all site options have
detailed surveys or development plans; therefore, in
order to ensure that all options have been appraised to
the same level of detail, all options have been
appraised at a high level based on an up-to-date
evidence base.
DLP267 - Turley on behalf of IM
Properties Development Ltd
The main body of the representation states:
A. That Table 4.4 of the SA leads one to think that a simple
consideration of whether the various options would involve
some impact on the Green Belt has strongly influenced the
In response to the comments related to the SA in the
main body of the representation:
A. Reference to the location of Green Belt has
been used to help describe the differences
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 12 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
decision-making in terms of the Growth Options exercise,
rather than a transparent assessment of which are the
most sustainable options for growth.
As set out above, local planning authorities have a
statutory duty to contribute to achieving sustainable
development when preparing local plans. In addition,
paragraph 84 of NPPF requires local planning authorities to
consider the consequences for sustainable development of
channelling development towards urban areas inside the
Green Belt boundary, towards towns and villages inset
within the Green Belt or towards locations beyond the
outer Green Belt boundary. There is no evidence provided
to demonstrate how the Council has taken this into
consideration when selecting the preferred spatial
strategy.
B. It is not clear how the Council has weighed the balance
between the most sustainable options for development
and Green Belt harm. There is also no reference within
the SA or supporting text within the Local Plan itself, as to
how the Council has used its own evidence base
documents on the Green Belt to inform its decisions on the
spatial strategy.
In Appendix 1 of the representation a number of other concerns
are raised in relation to the SA process:
1. A full revised SA Scoping report should have been
published presenting updated baseline information,
sustainability issues and SA Framework for consultation in
advance of the SA of the full draft Local Plan.
2. Consultation on the Growth Options Paper and supporting
SA was carried out after the selection of the preferred
spatial strategy.
3. Land at J9, M42 was not considered as a reasonable
alternative
4. Inaccurate baseline data within the SA, specifically:
a. Baseline section references the Biodiversity Action
Plans from 2006 and not the latest BAPs generated
between the ten Growth Options and the
potential loss of Green Belt has been
referenced in the appraisal of some of the
Growth Options. However, with regards to
the appraisal of significant effects generated
by the various Growth Options, reference to
Green Belt land loss has only been made in so
far as it is relevant to SA objective 8:
Landscape and SA objective 10: Efficient use
of land, i.e. effects on landscape and
greenfield land loss not effects of the Green
Belt. As referenced in paragraph 3.4 of
Appendix 1 of the representation, the SA
Framework and the associated assumptions
make no reference to Green Belt.
B. The Growth Options Paper was subject to SA
in June 2016 and it is the results of this SA
that were reflected in Chapter 4 of the SA
Report for the Draft Local Plan (and now
presented in Chapter 4 of this updated SA
report). A copy of the Growth Options SA can
be found online. The Growth Options were
assessed according to the methodology and
SA framework set out in this SA report. The
SA has assessed all options in the same level
of detail, which is proportionate to the scale of
the options considered. Table 4.4 in this SA
Report presents the Council‟s rationale for
selecting the growth options included in the
Local Plan and not selecting other options. It
is the role of the Council, not the SA, to select
the option deemed most appropriate. The SA
is an independent process, carried out by
external consultants and that a number of
factors may influence the Council‟s decision-
making, alongside SA.
In response to the concerns raised about the SA
process in Appendix 1 of the representation:
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by the WWT in 2012-2015.
b. Jobs and employment data are from 2008.
c. No reference to the Employment Land Review
Addendum 2013, published in 2016. Generally
contest the baseline‟s contention that there is an
oversupply of employment land but an
undersupply.
d. Baseline references a need for 70 hectares of
employment land while the Regulation 18 Plan
references a need for 91 hectares.
e. No reference to the confirmation of the HS2 route.
5. Concern raised that the SA has not informed the plan,
given that the Local Plan was produced in August 2016 and
the SA was produced in February 2017.
6. The SA Framework used to assess the sustainability
performance of employment parks is unable to accurately
assess and communicate the economic, social and
environmental benefits of employment land and does not
capture the full range of positive outcomes derived from
modern and well located employment parks. Furthermore,
the representation contends that large scale sites over 5ha
is size have the potential to generate more positive effects
the significance of which can only be determined once site
specific details are known.
Appendix 6 of the representation includes an assessment of the
promoted site against the SA framework. Paragraphs 49 and 116
of the assessment states that the use of a 600m buffer in relation
to access to services and facilities is inappropriate, citing the
Chartered Institute of Highways and Transport (CIHT) Guide
„Providing for Journeys on Foot‟ (2000) which includes a suggested
acceptable walking distance of 800m to town centres and 2km for
commuting. Furthermore, the assessment references the ability
for the site to include new services and facilities and sustainable
transport facilities and services.
1. It is recognised that the original SA Scoping
Report for the LDF was carried out some time
ago; however elements of the Scoping work,
such as the policy review and baseline
information, have been regularly updated
during the preparation of various SA reports
which have been subject to consultation.
2. Prior to the preparation of the Draft Local Plan,
a Growth Options Paper considered the issues
and challenges associated with providing for
additional housing (and potentially
employment land) over and above the level set
out in the Core Strategy, to respond to unmet
need from neighbouring Tamworth. In June
2016 SA work presenting the findings of the
appraisal of the ten growth options was
provided to NWBC to inform the preparation of
the Draft Local Plan. These SA findings were
published for consultation in Chapter 4 of the
SA Report that was published alongside the
preferred spatial strategy in the Regulation 18
consultation Draft Local Plan. Detailed SA
matrices for the growth options can be found
in Appendix 5 of this SA Report.
3. The SA presents the Council‟s reasons for
selection or rejection of sites and reasonable
alternatives in Appendix 8.
4. Since the original Scoping Report was
prepared, the baseline information informing
the SA of Draft Local Plan has been updated
during the preparation of various SA reports.
The references to inaccurate baseline data
consulted upon in the SA Report published
alongside the Draft Local Plan for Regulation
18 consultation have been reviewed as part of
the preparation of this updated SA Report for
the Draft Submission Local Plan.
5. The Draft Local Plan was consulted on between
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Thursday 10th November and Friday 31st
March 2017. While the SA was prepared
alongside the Draft Local Plan and influenced
its development, the SA Report was consulted
upon in early February up to the end of March.
The consultation period was extended until
March 2017, to allow consultees time to
consider both documents together. The delay
in the publication of the SA allowed time to
reflect the content of the Draft Local Plan
published for consultation. Furthermore,
chapters 2 and 4 of the SA Report also
describe how previous iterations of the SA
have fed into the plan-making process. The
SA will continue to influence future iterations
of the plan.
6. In response to the comments related to the
point 6 summarised in the adjacent column
from Appendix 1 of the representation and
elaborated upon in Appendix 6 of the
representation, all sites have been appraised
using clearly defined and consistently applied
assumptions set out in Appendix 6 of the SA
Report. These assumptions are based upon an
agreed SA Framework that has been subject to
consultation and is set out in Table 2.2 of the
SA Report. The assumptions draw on the most
up-to-date evidence. Mitigation is likely to
depend on developmental design and there is
no guarantee of possible mitigation measures
coming forward. In addition, details of
developmental design and proposed mitigation
are not available for all sites. In order to
ensure consistency and transparency in the SA
process a precautionary approach has been
taken in the SA, therefore potential mitigation
measures have not been taken into account in
the selection of sites for allocation. However,
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mitigation measures for the site allocation
policies set out in Chapter 14 of the Draft Local
were considered in the SA of the Draft Local
Plan in Chapter 6 of that SA Report.
In response to the detailed comments relating to the
SA Framework in Appendix 6 of the representation,
600m has been established as an appropriate easy
walking distance for the purposes of the SA. This
distance was defined based on the same guidance on
distances for walking published by the Institute of
Highways and Transportation and cited in this
representation. The Institute of Highways and
Transportation categorises distances depending upon
location and purpose of the trip, and „desirable‟,
„acceptable‟, and „preferred maximum‟. For the
purposes of the appraisal, distances in the appraisal
have been measured as the straight line distance from
the edge of the site option to existing services and
facilities, and therefore actual walking distances are
likely to be greater. Professional judgement has been
used when applying these distances to each site
option, for example to take account of significant
barriers to straight-line movement, such as railway
lines.
DLP288 - Natural England Natural England broadly supports the inclusion of SA Objective 7 in
the SA Framework, but recommends that geodiversity should also
be considered in this objective.
Natural England also recommend that SA objective 9 is
strengthened to show that negative effects on European sites and
SSSIs have been appropriately considered. There should be a
recommendation that any policies or proposals that do not
adequately protect SSSI or European sites should be removed or
modified. Impact on priority habitats should also be considered
using necessary inventories, maps and government policies.
Natural England welcome the fact that all significant effects
identified through the SA have monitoring proposed but state that
it is not clear how indicators will work in practice and if effects of
The SA objectives are broad, headline objectives.
Appendix 6 details how these have been addressed
through the assessment of sites.
Geodiversity is considered as part of SA Objective 9:
Valuing, enhancing and protective the biodiversity of
North Warwickshire (see Appendix 6 of this SA
Report).
References to „international‟ and „national‟ designated
conservation sites in Appendix 6 are sufficient to show
that effects on European sites and SSSIs have been
considered. This updated SA report for the Draft
Submission Local Plan has referred to the findings of
the HRA where relevant and the monitoring proposals
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the plan or wider changes are to be monitored. Examples of
approaches to monitoring are also included.
have also been reviewed in light of Natural England‟s
comments (see Chapter 7).
SA Objective 9 considers biodiversity in North
Warwickshire at a strategic level, which is considered
proportionate to the SA process. As explained in
paragraph 2.57 of the SA Report for the Draft Local
Plan, “the strategic nature of the SA meant that it was
not possible to investigate this potential for each site
and the score was based on designated sites only.
This approach was considered to be the best way of
ensuring consistency and a comparable level of detail
in each site appraisal. Where consultees (for example,
Natural England or the Wildlife Trust) have provided
specific information on the potential biodiversity value
of a site, this has been built into the assessment as far
as possible”.
Text has been added to Chapter 5 of this updated SA
report to explain that an analysis has now been
undertaken to identify the proportion of each site
option that is covered by local and national priority
habitats, and to show the findings of this exercise.
DLP298 - Rita Poulsen Concern raised re: the need to plan for green space and recreation
facilities to meet the needs of the growing population.
The SA has assessed green space and recreation via
SA objective 3 (health) and SA objective 6
(recreation).
DLP304 - Course and Shelton
on behalf of residents of
Hartshill and Ansley Common
area
The representation objects to the residential development for the
Hartshill and Ansley Common area. It is stated that much of the
information in the SA Report is misleading e.g. the library referred
to in the assessment for site HAR3 is within a Church, which would
have priority over the use as a library if conflict of need was to
arise. One of the two surgeries referred to lies outside of the
Borough.
The SA Report has highlighted that all of the proposed sites at
Ansley Common preform negatively against all environmental
objectives and worse than the non-preferred sites. Table 5.7 of the
SA report is incorrect, particularly because Ansley Common has
limited services and facilities. Also states that the open space at
Brett Hal Estate is not used and considered unsafe.
All sites have been assessed in line with the SA
framework, which was agreed to ensure consistency
across the SA assessments. The assumptions used in
scoring each option are detailed in Appendix 6 of the
SA report. SA is a strategic, high-level process and it
would not be proportionate to consider issues such as
a potential future conflict of use between the church
and library.
The SA has considered GP surgeries both within and
outside the borough, where they are within the
distance thresholds used) as residents could visit
either.
Appendix 7 of the SA Report presents detailed SA
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Considered misleading to refer to services and facilities outside of
the Borough as these are outside of the scope of the LPA. Further
concerns are raised in relation to the lack of cycle paths which
would reinforce car dependency and current employment
opportunities in the area. Concerns raised regarding the limited
range and capacity of local services and facilities and lack of
frequent public transport links.
States that ANSCOMM is not within 600m of shops, as the distance
from Nursery Hill Primary School to local shops at Chapel is 0.9
miles. Also noted that the site is within an MSA, on greenfield land
and lies within an area of medium sensitivity with regards to
historic environment. Concerns that there may be capacity issues
at Nuneaton Severn Trent Water, an increase in greenhouse gas
emisisons and adverse effects on biodiversity, particularly at
Moorwood Lane Local Wildlife Site and Hartshill Hayes Country
Park.
ANSCOMM/HAR1: 450 m is a considerable distance to travel for the
elderly or less mobile. It is misleading that the site is within 600m
of a Town Centre.
ANSCOMM/HAR2: Site is considerable more than 300m from
Hartshill Hayes. No healthcare services within Ansley Common.
PAS139 (PS139?): Liberal Club has selective access. Chapel End
Social Club and Chase Public House have ceased trading. Concern
about loss of allotments and loss of greenfield land and sensitivity
of the historic environment.
matrices for site options. This presents the reasoning
behind the scores presented in Table 5.7 of the main
report. Community facilities considered in the SA
include schools, GP surgeries and village halls.
The strategic nature of SA means that presence and
proximity of features are used to assess effects,
whereas issues such as current use and perceived
safety of existing facilities should be considered
through other means.
Sustainable modes of transport, such as cycling and
public transport are assessed via SA objective 15.
Measurements in the SA have been taken from the
closest point, which is made clear in the next iteration
of SA. These are measured in straight-line distances
as walking distance depends on the layout of
development. Nursery Hill Primary School is one of
the furthest points of the site. The SA has been
reviewed to reflect the fact that the Liberal Club has
selective access and the Chapel End Social Club and
Chase Public House have now closed.
Presence of MSAs has been assessed through SA
objective 14. Historic environment assessments have
been based on the HEA are assessed via SA objective
8. Water quality, including consideration of sewage
treatment works where capacity issues are known to
exist, are assessed via SA objective 11. Biodiversity is
assessed via SA objective 9.
The 600m threshold for walking distance was drawn
from The Institution of Highways and Transport
document. The data limitations section of the SA
Report has been updated to give a full account of the
reasoning.
Town centres were defined by NWBC and utilised in
this SA. Distance to services include services in
adjoining settlements, providing they are within the
distance thresholds set out in the assessment
assumptions (Appendix 6).
Site PS139 is not believed to include the allotments,
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comment in this updated SA Report
therefore these will not be lost to development.
DLP307 - Savills UK on behalf
of Cathedral Agriculture
Partnership and White Family
Focussing in particular on the area of Polesworth and Dordon, it is
unclear from the main (SA) report why the sites on the west of the
large allocation have been identified as „not preferred‟ other than
being over 5ha in size.
We consider that some of the criteria which mean that they
perform less well than those which are „preferred‟ such as master
planning to protect and enhance biodiversity.
Further clarification is therefore sought for what this means for the
allocation.
This comment appears to relate to sites POL11, POL10
and PS158. Table A8.1 in Appendix 8 of the SA Report
gives the Council‟s reasons for selecting each
residential site options or otherwise and Table 8.2 in
Appendix 8 gives the Council‟s reasons for selecting
each employment site options or otherwise.
Each option has been appraised using clearly defined
and consistently applied assumptions as set out in
Appendix 6 of the SA Report. These assumptions are
based upon an agreed SA Framework that has been
subject to consultation and is set out in Table 2.2 of
the SA Report. The assumptions draw on the most up-
to-date evidence. Not all site options have detailed
development plans; therefore in order to ensure that
all options have been appraised to the same level of
detail, all options have been appraised at a high level
based on an up-to-date evidence base.
DLP311 - Alan Wilson Concerns raised in relation to the loss of character in the town.
Concerns raised in relation to the capacity of existing
infrastructure, services and facilities to accommodate additional
growth.
The potential impact of new development in North
Warwickshire (specifically policies and site allocations
included in the Draft Local Plan) on the quality and
distinctiveness of the built environment (including the
cultural heritage) are considered by the SA Report
through SA objective 8 while impacts on landscape are
considered through SA objective 7 in Appendix 6. As
explained in Appendix 6 of the SA Report, the
appraisal of individual site options in relation to SA
objective 8 has been informed by a baseline heritage
assessment of all site options. The scoring of SA
objective 7 has considered the potential loss of
greenfield land in the Borough with larger greenfield
sites scoring less favourably than smaller greenfield
sites and brownfield sites. The SA framework has
been agreed to ensure consistency across the SA
Report in relation to the sites and policies of the Local
Plan and reasonable alternatives which have been
considered.
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Issues relating to existing infrastructure have also
been addressed in the SA Report through the appraisal
of options against SA objectives 1, 2, 3, 6, 15 and 20
which collectively consider the accessibility of new site
options to existing infrastructure and services and
facilities, specifically community, health, recreational
and culture, sustainable transport and education.
Information on the capacity of services and facilities is
not available on a consistent basis across the Borough
to be used in the SA. It has therefore been assumed
that developments would contribute to ensuring
sufficient capacity is available to meet the needs of the
new communities, either through investment in
existing facilities or the development of new services
and facilities. This has been explained in Chapter 2 of
this updated SA report.
DLP325 - Peter Bateman
(Framptons Town Planning) on
behalf of KNG Developments
The representation supports the methodology of the SA Report
however the appraisal of site SLA40 (Part) is queried. In relation
SLA40 the scores relating to health, landscape, built environment,
biodiversity, efficient land and waste are all suggested to be
amended. These updated scores are presented in comparison with
other sites considered as part of the SA.
Each option has been appraised using clearly defined
and consistently applied assumptions set out in
Appendix 6 of the SA Report. These assumptions are
based upon an agreed SA Framework that has been
subject to consultation and is set out in Table 2.2 of
the SA Report. This ensures that all sites are assessed
in the same way, as required by the PPG.
Developmental design is uncertain at this stage, as
allocation of a site in the Local Plan does not mean
that the design put forward by the promoter at this
stage will be realised. In addition, site-specific
surveys, details of developmental design and proposed
mitigation are not available for all sites. In order to
ensure consistency and transparency in the SA process
a precautionary approach has been taken in the SA,
therefore developmental design, detailed survey
results and potential mitigation measures have not
been taken into account.
Har1
- Neil Cowley (Castlewood
Property Ventures)
Consultee is promoting Land South of Birmingham Road, which
includes site SLA116 along with a field to the west of this and one
to the north of that.
The information included in the Scoping Report formed
the basis of the SA Report and has been updated at
each stage of the SA process. An updated review of
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comment in this updated SA Report
Concerns raised that the SA Report is not based on an updated
scoping report. The requirement for growth at land adjacent to
settlements is only briefly analysed in the SA Report but this
provides only a weak evidential base for the creation of a new
settlement category.
It is stated that Table 4.4 of the SA Report suggests that the
proposed spatial strategy has been guided by the need to protect
the Green Belt rather than a consideration for the most sustainable
strategy to deliver growth and option OUT2 (which would provide
housing at settlements nearest where shortfalls lie) was discounted
inappropriately.
Concerns raised that as the Growth Options Paper was not
consulted upon and pre-determined the conclusions of the Draft
Local Plan SA the process was not transparent. Concerns that the
blanket approach of preventing development in the Green Belt
prejudices the SA Report and does not accord with the NPPF
approach to Green Belt at paragraphs 83 and 84 of that document
as well as failing to promote sustainable development.
Concerns that the SA Report does not detail how the Green Belt
evidence available has informed the spatial strategy or site
selection.
plans, policies and programmes is presented in
Appendix 2 of the SA Report and updated baseline
information is presented in Appendix 3.
The SA of all growth options considered by the Council
is presented in Chapter 4. This was assessed
according to the methodology and SA framework set
out in the SA report. The SA has assessed all options
in the same level of detail, which is proportionate to
the scale of the options considered. Table 4.4
presents the Council‟s rationale for selecting the
growth options included in the Local Plan and not
selecting other options. It is the role of the Council,
not the SA, to select the option deemed most
appropriate and this may include factors other than
the SA.
The Growth Options Paper was subject to SA in June
2016 and it is the results of this SA work that were
presented in the SA Report for the Draft Local Plan.
Note that the SA is an independent process, carried
out by external consultants and that a number of
factors may influence the Council‟s decision-making,
alongside SA.
The SA presents the Council‟s reasons for selection or
non-selection of sites in Appendix 8.
DLP327 - Mathieu Evans
(Gladman)
States that the SA process should clearly justify policy choices. It
should be clear from results of the SA why some policy options
have been progressed and others rejected.
Concerns raised that the SA was produced after the completion of
the plan and therefore did not inform the options chosen in the
plan. Concerns that no consideration was made for the overall
quantum of development, particularly to include the remaining
unmet needs of Coventry, Birmingham and Tamworth.
It is stated that site PS187 is a sustainable option and that many of
the issues raised through the SA (particularly access to services,
natural environment, heritage, biodiversity, efficient use of land
and waste) and SHLAA might be mitigated or are issues which face
all greenfield sites.
The SA report represents a record of the SA of all
options considered for inclusion in the Local Plan,
which informs decision-making along with a number of
other factors. It is often not possible to „rank‟ options
in terms of sustainability and the Council may not
choose to proceed with the option perceived as most
sustainable if there are other, overriding factors.
Appendix 8 of the SA Report explains the Council‟s
reasoning for selecting or not selecting site options.
The Draft Local Plan was consulted on between
Thursday 10th November and Friday 31st March 2017.
While the SA was prepared alongside the Draft Local
Plan and influenced its development, the SA Report
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was consulted upon in early February up to the end of
March. The consultation period was extended until
March 2017, to allow consultees time to consider both
documents. The delay in the publication of the SA
allowed time to reflect the content of the Draft Local
Plan published for consultation. Furthermore, chapters
2 and 4 of the SA Report also describe how previous
iterations of the SA have fed into the plan-making
process. The SA will continue to influence future
iterations of the plan.
The Council‟s justification for the housing requirement
and SA of the different delivery options considered are
presented in Chapter 4 of the SA report.
The SA has been reviewed to take account of nearby
bus stops highlighted in the representation.
All sites have been assessed in line with the SA
framework, which was agreed to ensure consistency
across the SA assessments. The assumptions used in
scoring each option are detailed in Appendix 6 of the
SA report.
Mitigation is likely to depend on developmental design
and there is no guarantee of possible mitigation
measures coming forward. In addition, details of
developmental design and proposed mitigation are not
available for all sites. In order to ensure consistency
and transparency in the SA process a precautionary
approach has been taken in the SA, therefore potential
mitigation measures have not been taken into account
in the selection of sites for allocation.
However, mitigation measures for the site allocation
policies set out in Chapter 14 of the Draft Local were
considered in the SA of the Draft Local Plan in Chapter
6 of the SA Report.
DLP341 - Spawforths on behalf
of the Harworth Group
The representation objects to Policies LP2: Settlement Hierarchy
and LP39: Housing Allocations, specifically demanding that the
spatial distribution of development in the Borough be reconsidered,
moving development away from the A5 and disseminating it more
Table 4.4 of the SA Report presents the Council‟s
justification for taking forward the selected growth
option and not selecting alternatives to this. Table
A4.1 in Appendix 4 of the SA Report details how
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comment in this updated SA Report
evenly between the Borough‟s Category 3 „Local Service Centres‟ to
provide a more balanced settlement hierarchy and to meet the
development needs of the wider Borough and alleviate the highway
capacity issues on the A5…Rather the Draft Local Plan has
prioritised Green Belt over…the need to promote sustainable
patterns of development.
Objection to policies LP12: Employment Areas, LP39: Housing
Allocations and LP40: Employment Site – The former Daw Mill
Colliery Site has key locational characteristics that make the
opportunity afforded by the existing rail connections significant.
Objection to Policy LP40: Employment Allocations as the „Land at
MIRA‟ employment allocation should be reallocated from a
„Category 2 – Adjacent adjoin settlement‟ site to a new Category 5
site as the site does not sit adjacent to an adjoin settlement.
policies in the Local Plan have developed. Decision
making was influenced by the results of the SA, as well
as other considerations such as the need to
accommodate growth from neighbouring authorities
and other evidence base documents. Reducing use of
the private car, which is likely to reduce traffic and
congestion, is assessed through SA objective 15.
The Former Daw Mill Colliery Site has been included in
the site audit trail table in Appendix 8 which explains
why this site is not considered a reasonable alternative
option.
The heading „Adjacent Adjoining Settlements‟ in the SA
Report has been reworded to „Sites Adjacent to
Neighbouring Local Authorities‟
DLP349 - Tim Plagerson (RPS)
on behalf of St Modwen
Development
It is stated that the SA Report does not consider sites which are
included in the updated SHLAA and therefore does not assess all
reasonable alternatives. The representation relates to site Dairy
House Farm which has not been included in the SA Report although
it was submitted for consideration as part of the SHLAA. The
consultee has undertaken an appraisal of the site in question in line
with the SA methodology and this is presented in the
representation document. It is suggested by the consultee that the
scoring compares favourably with the proposed allocations in the
emerging Local Plan. Site GRE4 which was appraised in the SA
Report contains land at Dairy House Farm. This site is the same
distance from services and facilities as site GRE1 and GRE2 and
therefore the same score should be recorded for these sites in
relation to SA objective 1 (services and facilities) and SA objective
2 (vibrant communities).
The Dairy House Farm site is appraised as two
separate options as the site is effectively two sites,
phases 2 and 3. Phase 2 is known as site DLP319
(allocated in the Plan as site H18) and Phase 3 is
known as site DLP349 (allocated in the Plan as site
RH1). Table A8.1 in Appendix 8 of the SA Report gives
the Council‟s reasons for selecting each residential site
option or otherwise and Table 8.2 in Appendix 8 gives
the Council‟s reasons for selecting each employment
site options or otherwise. Whilst the SA details the
reasonable alternatives considered and assesses these,
it is the role of the Council to identify reasonable
alternatives.
For GRE4, the findings in relation to SA objectives 1
and 2 have been reviewed based on the facilities
mentioned for GRE1 and GRE2 (i.e. Grendon Village
Hall).
DLP350 - Tim Plagerson (RPS)
on behalf of St Modwen
Development
Concerns raised that the site at Dairy House Farm (which the
consultee wishes to see allocated for 1,000 new homes) has not
been appraised. The site adjoins the settlement boundary and
would score well against the SA objectives thereby meaning it
should be considered as a reasonable alternative.
The Dairy House Farm site is appraised as two
separate options as the site is effectively two sites,
phases 2 and 3. Phase 2 is known as site DLP319
(allocated in the Plan as site H18) and Phase 3 is
known as site DLP349 (allocated in the Plan as site
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 23 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
RH1). Table A8.1 in Appendix 8 of the SA Report sets
out the reasoning for why each site option considered
was deemed to be reasonable.
Chapter 2 of the SA Report sets out how reasonable
alternatives were identified and notes that a number of
sites submitted to the Council were not deemed to be
reasonable for a number of reasons. Whilst the SA
Report explains how alternatives have been identified
and assessed, it is the role of the Council to identify
reasonable alternatives.
DLP354 - William Gallagher
Town Planning Solutions on
behalf of Holiday Extras and
Airparks Services Ltd
It is contested that Policy LP36 which addresses airport parking in
the Borough is too restrictive. The representation states that the
SA Report has not considered the airport parking policy wording
appropriately and has not been tested against reasonable
alternatives.
The appraisal of all policies has been undertaken in
line with the agreed SA Framework that has been
subject to consultation and is set out in Table 2.2 of
the SA Report.
DLP364 - Warwickshire Wildlife
Trust
Concerns that as the SA has scored all sites negatively in relation
to biodiversity it is very difficult to differentiate the findings
presented. It is stated that mitigation and avoidance might be
adopted at some sites and that the SA should be updated to reflect
this.
WWT has provided commentary on each site assessment
individually and suggested changes to assessment results and
scores in some cases.
SA is a strategic process, which focuses on identifying
significant effects. Mitigation is likely to depend on
developmental design and there is no guarantee of
possible mitigation measures coming forward,
therefore a precautionary approach has been taken in
the SA. The exception to this is where other Local Plan
policies are likely to mitigate potentially negative
effects, which has been assessed in the Cumulative
Effects section of Chapter 6.
All sites are assessed in line with the assumptions set
out in Appendix 6, which were subject to consultation
in earlier iterations of the SA. This ensures that all
sites are assessed in the same way, as required by the
PPG.
Assessments of sites ATH14 and ATH20 have been
reviewed to address inaccuracies identified by WWT.
Other specific comments suggesting a change of score
to site appraisals have been acknowledged in the SA
assessment matrices (except those that only suggest a
score change if policies are updated).
Text has been added to Chapter 5 of this updated SA
report to explain that an analysis has now been
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 24 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
undertaken to identify the proportion of each site
option that is covered by local and national priority
habitats, and to show the findings of this exercise.
DLP371 - Ruth Ellis Concerns raised in relation to the potential for adverse effects on
the natural and historical assets within close proximity to site
POL/DOR1.
Each option has been appraised using clearly defined
and consistently applied assumptions set out in
Appendix 6 of the SA Report. These assumptions are
based upon an agreed SA Framework that has been
subject to consultation and is set out in Table 2.2 of
the SA Report. The assumptions draw on the most up-
to-date evidence. The full appraisal matrix for this site
is presented in Appendix 7.
The Council‟s Historic Environment Assessment (HEA)
was used to inform the appraisal of sites in relation to
potential impacts on the historic environment (SA
objective 8). However, this site option was not
covered in the HEA. Therefore an uncertain effect was
recorded for SA objective 8. This data limitation was
acknowledged in Chapter 2 of the SA Report.
However, as explained in Chapter 2 of this updated SA
report, the SA findings for all site options in relation to
SA objective 8 have now been updated to reflect the
findings of the baseline heritage assessment that has
now been carried out for all site options.
The site has been recorded as having a significant
negative effect on SA objective 9 (biodiversity) given
that the site sits within an area of ancient woodland
and a Site of Importance for Nature Conservation
(SINC).
DLP375 - Tom Shakespeare Concerns that health and education facilities are over-subscribed,
the Council are unable to maintain green spaces and sport and
recreation facilities are very poor and neglected.
Road links are strained and development would increase congestion
on the A5. Concerns that a new through road to the A5 will
increase demand on the A5 between Dordon and Grendon and
encourage more traffic through Grendon Road, Polesworth.
States that rail links to Polesworth are „almost non-existent‟.
Suggests reinstating a police station in Atherstone.
Information on the capacity of services and facilities is
not available on a consistent basis across the Borough
to be used in the SA. It has therefore been assumed
that developments would contribute to ensuring
sufficient capacity is available to meet the needs of the
new communities, either through investment in
existing facilities or the development of new services
and facilities. This has been explained in Chapter 2 of
this updated SA report.
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SA of North Warwickshire‟s Draft Submission Local Plan - Appendices 25 December 2017
Consultee Consultation comments – summarised where appropriate Response/action taken to address consultation
comment in this updated SA Report
Suggestions that Polesworth and Dordon have “a good range of
existing local services and facilities” comparable to Atherstone and
Coleshill are mistaken.
Reducing use of the private car, which is likely to
reduce traffic and congestion, is assessed through SA
objective 15. SA is a strategic, high-level process,
which assesses all options in the same level of detail.
The general growth proposed in the Borough on traffic
levels and air quality have been assessed in the
cumulative effects section in Chapter 6 of the SA
Report.
All sites have been assessed in line with the SA
framework, which was agreed to ensure consistency
across the SA assessments. Assumptions on how this
was applied to assessments are presented in Appendix
6 of the SA.
Consideration of existing services and facilities
considers each in its own right, rather than in
comparative terms. As explained above, information
on the quality and capacity of facilities is not
consistently available, therefore the SA, as a strategic
process, can only account for the presence of facilities.
DLP379 - Stella Doggett Concerns regarding the significant positive effect recorded in
relation to health for the site at Dordon and Polesworth. The
proposed new distributor road which will create more pollution and
that the proximity of a health centre to the site should not be used
as an indicator of the potential benefits of locating new housing at
this location. There will be less space for walking and exercise due
to the development.
Concerns raised that sustainability criteria are inappropriate and do
not take account of the reality of the changes development would
bring. Concerns that the consultation process is no more than a
„tick box exercise‟ relating this to the loss of greenfield land which
development would result in.
Comments include reference to a lack of infrastructure to
accommodate the number of houses proposed, stating that
Poleswroth and Dordon have been „artificially‟ designated as
market towns and questioning why the Council is not pursuing a
policy of allowing for more incremental growth at the villages in
North Warwickshire.
All sites have been assessed in line with the SA
framework, which was agreed to ensure consistency
across the SA assessments. The assumptions used in
scoring each option are detailed in Appendix 6 of the
SA Report. The site does not consist of open space,
nor is it open access land. It has been assumed that
the footpaths running through the site will be
protected, in line with national legislation.
Information on the capacity of services and facilities is
not available on a consistent basis across the Borough
to be used in the SA. It has therefore been assumed
that developments would contribute to ensuring
sufficient capacity is available to meet the needs of the
new communities, either through investment in
existing facilities or the development of new services
and facilities. This has been explained in Chapter 2 of
this updated SA report.
It is not clear why the consultee believes the
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SA of North Warwickshire‟s Draft Submission Lo