Stage C Evidence Base

Comment

Representation ID: 23183

Received: 16/03/2020

Respondent: Barton Willmore

The full draft SA review can be found starting at p185 of the first attachment.

Review Summary
2.4 No areas of major deficiency were identified in the SA.
2.5 The following areas of the SA would potentially benefit from additional consideration:
• Existing environment (Habitats Regulations Assessment (HRA)) – A HRA has been
completed for the Regulation 18 Draft Plan and should be referenced in the Regulation 18 (C) SA Report. Briefly outlining the conclusions of the HRA would give more meaning to the assessment of ecological effects, particularly when assessing the sites and the decisions
made and would make the argument that the findings have been incorporated into the SA more robust. There is no evidence that cumulative effects have been assessed in relation to European sites, which would have been the case for in-combination effects in the HRA, for legal compliance. Given the need for assessments to be coordinat ed, it would be helpful to have more information within the Regulation 18 (C) SA Report on the HRA undertaken for the Local Plan to date.
• Relevant Policies, Plans and Programmes - The Regulation 18 (C) SA Report does not adequately reference the Cambridge Norwich Growth Corridor, SHMA Core Area or the NPA.
• Likely significant effects on the environment (cumulative effects) – A definition for short, medium and long-term effects, permanent and temporary effects, positive and
negative effects, and secondary, cumulative and synergistic effects is not provided and would be helpful for clarity. Cumulative effects are only mentioned in relation to major North East Wymondham Review of SA
21389/A5/SA March 2020 negative scores and there is no explanation of how these are considered within each topic. The approach to the assessment of cumulative effects is not well outlined and seems inconsistent between topics. SA Objectives 3 and 14 are the only Objectives that specifically mention cumulative effects in the assumptions and methodologies. In addition, there is no consideration of how each of the SA Objectives might interact with one another.
• Reasonable alternatives – Additional information on the site selection process would be helpful, for example more justification where sites have been excluded or options narrowed down. This should be reflected in the iterations of the SA and would make the process more robust and transparent.
• Reasonable alternatives – The assessment conclusions within Section 5 suggest that all sites/policies would have mixed effects with regards to sustainability and that it is not possible to identify a best performing option. The appraisal of the site in Bunwell against SA Objective 1 – Air Quality and Noise has been based on the number of new dwellings proposed (seven) and the site is awarded a negligible score. The sites within the Wymondham cluster have been awarded minor negative/major negative scores, even though some sites propose similar numbers of new dwellings (e.g. ten). It does not appear
to have been taken into account within the explanatory text that the sites in Wymondham are located within close proximity to local facilities, public transport, leisure and employment opportunities, which would help to reduce the need for travel by car, thereby reducing emissions and impacts on air quality. The site in Bunwell is located approximately 5.5km away from the nearest train station (Spooner Row, which does not have frequent
services compared to the larger stations in Wymondham) and approximately 7.8km away from the nearest town (Attleborough), and would therefore likely require all new residents to use cars to access these facilities, rather than more sustainable modes of transport, which would worsen impacts on air quality. Therefore, the objectivity and parity of the assessment when assigning scores could be questioned.
• Reasonable alternatives – The 2017 SA Scoping Report includes Appendix 2 ‘Demonstrating Compliance with SEA Directive’ – and states that this table will be completed and incorporated in subsequent SA reports to show how the SA has met legislative requirements. This table exercise has not been undertaken and included with the Regulation 18 (C) SA Report as set out in the Scoping Report. It would be helpful to set this out for
the next Consultation.
• Monitoring – The suggested monitoring targets are very vague and there are still some gaps to be identified. Additional information could be included by using local/national targets, and further details on how the effects will be monitored, over what period, frequency etc would increase robustness in the next Consultation.
• Non-Technical Summary – There is no Non-Technical Summary (NTS) within the supporting documents. Whilst the GNLP is at the Regulation 18 Consultation stage, it is
North East Wymondham Review of SA 21389/A5/SA March 2020 good practice to have an NTS for each revis ion of the SA, so that it is clear how the SA has evolved through the iterations. This should be rectified at the Regulation 19 Consultation.
2.6 Despite the improvements suggested above, the SA is not considered deficient and provides a comprehensive discussion around the likely effects of policy and site options as evidence supporting the GNLP as a reasonable strategy. Section 6 of the 2018 Interim SA Report and Section 2.7 of the Regulation 18 (C) SA Report sets out the uncertainties and difficulties of
predicting effects including assumptions made about secondary data, the accuracy of publicly available information and subjective judgement. Section 2.9 describes the assumptions made for the specific topics of the SA Objectives Assessments, which is helpful, for example where up to date ecological surveys and/or landscape and visual impact assessments have not been
available and have limited the assessment of sites.
2.7 Additional information to address the points summarised above at the Regulation 19 Consultation stage would increase further the robustness of the SA and assist in achieving the right outcome at Examination.

4.0 Conclusion
4.1 There are some areas of the SA which would potentially benefit from additional consideration at the Regulation 19 Consultation stage which would increase further the robustness of the SA and assist in achieving the right outcome at Examination.
4.2 The potential development site Land North East of Wymondham should be selected for inclusion within any proposed site allocations within the GNLP based on its location, opportunities and performance against the SA Objectives, to aid sustainable development in this urban extension area. The Regulation 18 (C) SA Report does not adequately reference the Cambridge Norwich Growth Corridor, SHMA Core Area or the NPA, when it is clear from this review that the GNLP should focus development here.
4.3 The twelve site assessments in the Wymondham cluster (Section B.51 within Appendix B of the
Regulation 18 (C) SA Report) show that Wymondham has been robustly and fairly assessed using appropriate methodology and justifiably represents a strategic location for growth. However, is clear that where some of the twelve Wymondham sites are awarded negative
scores in the SA, this is due to a lack of integrated mitigation, for example standard best practice mitigation usually implemented on such sites, a lack of s urvey information to properly assess potential impacts or a lack of knowledge of site design/masterplan commitments.
Therefore, it could be argued that these scores are not realistic. Including site assessments undertaken post mitigation would likely result in more positive sustainable scores than those awarded.
4.4 Wymondham represents a sustainable location for development in Greater Norwich and decision making and the GNLP should prioritise development along the Cambridge Norwich Growth Corridor, within the SHMA Core Area and the NPA.