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Publication Draft Local Plan: Focused Consultation

ID sylw: 67287

Derbyniwyd: 12/12/2014

Ymatebydd: CPRE WARWICKSHIRE

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Dyletswydd i gydweithredu? Heb nodi

Crynodeb o'r Gynrychiolaeth:

The Sustainability Appraisal has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014. This is a further representation on the Sustainability Appraisal following publication of new information by the District Council.

The SA has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014.

This SA Addendum recognises that the proposed sub-regional employment site ('Gateway') development could have a significant adverse impact on the Green Belt and its environment ("Ultimately development could result in loss of Green Belt and Greenfield land, and has the potential to significantly affect the landscape character, biodiversity and wetland features..."). The SA assesses the environmental impact as negative to highly negative (especially prudent use of land and natural resources); we consider that this under-estimates the damage that is likely to be caused by such a development.

The SA assesses the impact on the economy as highly positive; consequently, it assesses the impact on poverty, social exclusion, health and well-being as positive. For the reasons we have outlined in the sections above, the SA's assessment is based on flawed analyses and circular arguments.

The SA's assessment on housing and local communities is also erroneous. The 'Gateway' is claimed to support upwards of 10,000 new jobs but the site is located outside urban areas. As we have already shown, the site is not close to the areas of greatest socio-economic need (in the north of the CWLEP area). If many thousand new jobs were created as claimed, it would add great pressure on Warwick District to provide even more homes than the very high figure already proposed. The 'Gateway' site is in the Green Belt and surrounded by Green Belt, exacerbating the challenge of providing suitable housing in a sustainable way. We assess this impact as negative on housing and highly negative both on the local community and on reducing the need to travel.

Even though the SA recognises that the huge scale of the proposed 'Gateway' development could lead to potential large impacts, it assesses the effect on climate change as potentially positive as well as negative. We submit that the non-urban location, increased need to travel, lack of existing sustainable transport and huge scale of built form in the countryside would all lead to adverse impact on climate change.

Overall, the SA greatly over-estimates positive impact of the 'Gateway' and under-estimates the impact on the environment. The 'Gateway' site is an unsustainable location for development of large-scale employment facilities. Even if a sub-regional employment site were justified, there is no evidence that the proposed 'Gateway' site is the most sustainable location - there is no evidence of a methodical sustainability assessment process that compared alternative sites and selected the most sustainable location.

Conclusion

The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.

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