Comment

Representation ID: 9369

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Non statutory consultation under Regulation 18 contradictory. Seeks to pre-determine spatial strategy via settlement categorisation/site selection matrix.
SCI indicates Review should be subject to formal Regulation 18 consultation, which should be next stage, not Regulation 19. SEA process fails to comply with guidance/regulations. Addressing HMA shortfall likely to result in further alternatives that need to be appraised which could have implications for spatial strategy and SA should be undertaken as part of Stage B/Regulation 18.
Formal SA Report should have been prepared/consulted on at this stage. Further deficiencies relating to lack of consideration of alternatives to Local Housing Need, reasonable site options not assessed, deficiencies at DLP stage not addressed, fails to evaluate significance of impacts against appropriate evidence, cumulative effects/mitigation not considered, green belt land not considered, no flood risk sequential test of proposed allocations, no explanation for selection/rejection of options or overall conclusions of sustainability of different alternatives. no explanation how SA informed SDLP in integrated way, fails to show how representations from statutory consultees/neighbouring authorities taken into account. Fails to assess 75 sites of which 15 identified as green and 9 as amber sites. SA fails to appraise all reasonable alternatives, demonstrate that strategy is appropriate or take into account alternatives. Appendix 1 attached as additional supporting information in connection with this site undertakes a review of the SEA process.