BASE HEADER

Other

ID sylw: 106597

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

Site ref ID: 58
We strongly agree with the result for the sites to be Further Assessed, however, we do consider the sites should have been scored lower in the HELAA results, for the reasons set out below.
We would also request clarity as to the application of the harm and mitigation weighting factors, which is not sufficiently provided in the HELAA methodology. Whilst paragraphs 3.9 to 3.11 do provide a brief background, we are unclear whether a consistent approach has been applied to the weighting factor in respect of all criteria.
We disagree with the approach taken in relation to the Spatial Growth Strategy Priority Areas, as set out in paragraph 3.8, whereby the highest weighing factors are reserved for these areas. Whilst we appreciate the importance of these sites, this places all other sites, including new settlements at an unjust advantage in the assessment as it results in a lower score, particularly in consideration of paragraph 3.12 of the methodology, which confirms that scores closest to zero are more favourable.
The approach fails to consider the potential for mitigation in these areas, as set out in Table 3b of the methodology, placing them at a disadvantage in comparison to other sites. This does not represent a consistent approach and does not allow the true comparison of the suitability of sites. It also seems to be a counter-intuitive approach; the Spatial Growth Strategy Priority Areas are deemed to be
fundamental to the success of the SWLP yet they score higher and less favourably than any other site.
We would request full transparency and explanation as to the application of the weighted scores.