The Sustainability Appraisal does not address the point I raised in the examination that when it became apparent, as a result of the initial examination sessions, that further sites needed to be allocated (in June 2015) then the site at Loes Farm (SHLAA ref W28) should have been fully reconsidered as a site allocation.

I made the point in the Matter 4 session that it would appear that Loes Farm had not been considered as a reasonable alternative by the Council in their proposed modifications in 2016. EXAM 60 was produced to address these concerns and I participated in the discussions over this document in the Matter 7a session. I made the point then and I remain concerned that EXAM 60 only seems to confirm the fact that the Council did not properly consider the site as a reasonable alternative at the 2016 modifications stage. The 2016 modifications were a mandate to the Council to allocate further sites for housing, involving release of land from the Green Belt. Loes Farm had been a site allocation in an early draft Local Plan, with one of the reasons for the allocation being dropped being a lack of exceptional circumstances for Green Belt release. By the time of the 2016 modifications stage those exceptional circumstances had arisen and also at that stage there was a significant piece of new evidence in the Joint Green Belt Review (LA07PM). In terms of contribution to the purposes of the Green Belt, Loes Farm (parcel WA05 in the Joint Green Belt Review) is the lowest value parcel of land around the edges of Warwick and Leamington. I submit that, in light of these changed circumstances, the Council should have reconsidered Loes Farm in the 2016 modifications as a potential site allocation. This consideration should have been explained in a site selection paper and it should have taken in to account Green Belt value alongside other environmental factors.

The lack of consideration of Loes Farm as a reasonable alternative to the chosen allocations undermines the Sustainability Appraisal. It cannot be ascertained from the evidence of the site selection process that the proposals in the plan are the most appropriate given the reasonable alternatives. It is therefore considered that the Sustainability Appraisal does not meet the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, and the Main Modifications Sustainability Appraisal does nothing to remedy this.