BASE HEADER

No

ID sylw: 108334

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

As part of the SA process, a SA at Preferred Options stage should identify and assess ‘reasonable alternatives’ to the ‘preferred option’ in order to ‘sense check’ and justify the pursuing of the preferred strategy.

There are two issues with this approach used. The first is that the Councils have determined the reasonable alternatives themselves based upon their preferred strategy, rather than the reasonable alternatives being driven by the iterative process of the SA.

The second is that the above ‘reasonable alternatives’ are in fact the preferred development plan options that the Councils are consulting on within the SWLP; there are no alternative to the above strategies. The SA itself is clear that the SA should assess ‘development plan options
and reasonable alternatives’ [emphasis added].

For example, whilst there is no prescribed formula or procedure about which aspects of a local plan require reasonable alternatives, the Councils have not evidenced or justified how they came to the decision to pursue a two-part plan. A reasonable alternative would have been to
consider the sustainability implications of an all-encompassing local plan, inclusive of identifying
non-strategic development allocations, which has simply not been considered or assessed.

The SA suggests that ‘small settlement locations’ inclusive of developments between 50-500 dwellings were considered in the Issues and Options SA, but no explanation is provided within this SA as to why this approach was discounted.

Similarly, in respect of growth options, the Councils have only tested the prevailing standard method at the time of writing (2,188 dwellings or 54,700 dwellings across the Plan period) versus the HEDNA originally produced in 2022. The purpose of both of these methods is to determine the local housing need (LHN) for the Plan area. The SA has not tested the implications of providing growth in excess of this figure, either to boost economic growth or the delivery of affordable housing. This is despite the SA including a sequencing flowchart from the Royal Town
Planning Institute at Figure 3.1, which includes an illustration of alternative amounts of housing to be provided, such as LHN plus a 5% or 10% uplift.

This is a fundamental failing of the SA arising from the pre-determined nature of the Councils’ preferred development strategy.