BASE HEADER

No

ID sylw: 101896

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

It's unclear what status SGLs will have in developing future versions of the SWLP. The Southam SGL is a suitable, sustainable, deliverable opportunity for strategic-scale development. However, the parcel selection is illogical, which impacts assessment in the Sustainability Appraisal. Land at Welsh Road and Daventry Road, Southam was not included in the SGL despite better HELAA performance than other Southam sites to the west and north. The site is within the Spatial Growth Strategy Priority Area, while some sites included in the SGL are not. Inclusion of less sustainable sites skews Southam's outcomes.

A fairer, more robust approach would be to select the best-performing HELAA sites to test the merits of the SGLs. The SA methodology is too rigid and applied to large, unconnected areas of land without accounting for the proposed form of development or mitigation measures. The SA outputs have little value for plan-making. Of greater value are site-specific assessments through the HELAA combined with an understanding of the broad sustainability of places.

Specific comments on SA Objectives for SG12:

Climate Change
Agree all SGLs should have the same score. This should be "0" in the absence of any detailed analysis on the climate change impact of not meeting future growth needs.

Flood Risk
All sites should be assigned "0". Testing broad areas without regard to form, scale or mitigation is meaningless.

Biodiversity
Masterplanning measures could avoid or mitigate development impacts on protected habitats. The broad comparison is helpful so retain same scores.

Landscape
Particularly sensitive to site-selection. In Southam land to the west is considerably more sensitive than land to the east. If better-performing locations were selected as part of the SGL then lower impacts would have been assessed. Revise to '-'.

Cultural Heritage
Particularly sensitive to site selection. Selecting Land at Welsh Road and Daventry Road, Southam rather than more sensitive land to the West would reduce the impact of the SGL. Revise to '-'.

Pollution
Meaningless without clear understanding of the proposed form and type of development. Score should be same for each SGL but no rationale for this being negative.

Natural Resources
Land to the South and East of Southam is Grade 3 and 4 with no BMV. We suggest minor negative rather than major negative. Currently 23 of 24 SGLs are scored equally against this objective despite national Planning Policy prioritising use of non-BMV land.

Waste
Agree SGLs should score equally but not major negative. New homes are needed and no reason to assume the SGLs are worse than alternatives.

Housing
Score agreed.

Health
Meaningful assessment impossible without further details on proposals. Consistent minor negative not unreasonable.

Accessibility
Agree with a consistent score. Strategic sites would enhance public transport and active travel. Measuring performance without understanding opportunities for enhancement through development would be incomplete.

Education
Consistent neutral score is the only option until a more in-depth analysis is carried out of existing provision and opportunities to enhance through growth.

Economy
Support consistent positive score as all residential-led SGLs will have a positive impact.