Sustainability Appraisal and Habitats Regulation Assessment

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Comment

Sustainability Appraisal and Habitats Regulation Assessment

Sustainability Appraisal - January 2023

Representation ID: 4891

Received: 17/03/2023

Respondent: Gleeson Land

Representation Summary:

The basis of the reasonable alternatives tested within the SA have been infected by a fundamentally flawed starting point conclusion that there is capacity for no more than 535 dpa within the southern planning area. The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited as this too has been infected by the factually incorrect SA.

Full text:

The basis of the reasonable alternatives tested within the SA have been infected by a fundamentally flawed starting point conclusion that there is capacity for no more than 535 dpa within the southern planning area. The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited as this too has been infected by the factually incorrect SA.


Our response:

A housing requirement figure significantly above the LHN has previously been considered (as set out in the SA report published at the time of the Preferred Approach Local Plan) but it was concluded that there would be significant negative effects.

The justification for not meeting the housing needs in full is set out in the Housing Need (July 2024) and Transport (July 2024) Background Papers. It is on this basis the Regulation 19 SA references it being unreasonable to consider an above LHN figure.

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