Object
Draft Local Plan - Supplementary Consultation
Representation ID: 9150
Received: 15/03/2019
Respondent: CPRE Warwickshire Branch
No, because there are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The analysis of sustainability does not meet the standards as set out in the NPPF2 Para. 3.32.
The Council should consider reviewing their Sustainability Appraisal in line with the Government's sustainability scorecard. When applied to Site 4 at Dickens Heath, this site only scored a 30% sustainability rating which puts it in the 'red' not 'green' category. There are other sites that are inconsistent with Option G of the Spatial Strategy.
It is not possible to understand how some of the sites fall into the green category. If an updated sustainability scoring was used the results on site selection would be different. Without this, the credibility and robustness of the process is undermined. It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. The Plan's strategy continues to focus only on large scale Green Belt releases. This is not consistent with government advice in the NPPF that a mix of sites should be encouraged. Many of the small sites which have not been accepted as allocations in the Plan need to be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character, and whether they are more readily deliverable.
2. Do you agree with the methodology of the site selection process; if not, why not and what alternative/ amendment would you suggest?
No, because there are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The analysis of sustainability does not meet the standards as set out in the NPPF2 Para. 3.32.
The Council should consider reviewing their Sustainability Appraisal in line with the criteria as set out in the Government's sustainability scorecard, see:- www.thescorecard.org.uk For example, when this analysis was applied to Site 4 at Dickens Heath, this site only scored a 30% sustainability rating which outs that proposed housing site in the 'red' not 'green' category. Just looking beyond that example, there are other sites that are inconsistent with Option G of the Spatial Strategy.
It is not possible to understand how some of the sites fall into the green category. The criteria for 'green'status is that "they have no or relatively low impact on relevant considerations; or that severe impacts can be mitigated". But some clearly have a high impact. Again, if an updated sustainability scoring was produced in line with recent Government Policy, the results on site selection would be different. Without this, the credibility and robustness of the process is undermined.
It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. As noted in the response to Question 1, regarding the 'Small Sites' section of the Consultation document (para 56-57), the Plan's strategy continues to focus only on large scale Green Belt releases. This is not consistent with government advice in the NPPF that a mix of sites should be encouraged. Many of the small sites advanced by owners or prospective developers which have not been accepted as allocations in the Plan need to be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character, and whether they are more readily deliverable.