Southbourne Allocation DPD Reg 18 Interim Sustainability Appraisal

Comment

Representation ID: 6941

Received: 18/12/2024

Respondent: Wates Developments

Agent: Turley

4. Interim Sustainability Assessment
This section of the representations presents the outcomes of a review of the Sustainability Appraisal (SA) Document supporting the Southbourne Allocation Development Plan Document (DPD).

It is acknowledged that this is a Regulation 18 version and so is still evolving, however Wates Developments consider the SA process and the current SA documents to be extremely important parts of the plan making process in that the SA provides crucial evidence to guide the plan making process to the most sustainable policy option.

4.3 Wates Developments have reviewed the SA document and have a number of
comments and suggestions to make which we hope will be incorporated into the Regulation 19 version of the plan and which will result in the selection or the most sustainable ‘reasonable alternatives’ (policy option).

4.4 The function of the SA document is to appraise the three reasonable alternative policy
options for development within the Broad Location for Development (BLD). Our comments on the quantum of development assessed have been provided separately and as such are not repeated here. The three options (referred to as scenarios in the wider consultation documentation) are:
• Option 1: Land to the West of Southbourne village
• Option 2: Land to the East of Southbourne village
• Option 3: Mixed Scenario (combining areas of land to the west and to the east of
Southbourne village)

4.5 As stated earlier in these representations, Wates Developments consider Option 2 to
be the most suitable Scenario. Our clients also consider Scenario 3 to also potentially be a suitable scenario, subject to further consideration on the delivery of infrastructure and how this could be equalised across the parties.

The Methodology Deployed by the SA
4.6 With respect to the methodology deployed by the SA to appraise the development
Options, Wates Developments are broadly supportive of that deployed but do request that the Regulation 19 version of the plan and specifically its supporting SA incorporate these representations and any additional evidence submitted to ensure the assessment is as accurate and robust as possible.

Appraisal of the growth scenarios
4.7 Section 3 of the SA presents the results of the appraisal of the three growth options
against the SA Framework with a summary of the results presented in Table 3.1. Wates Developments have reviewed the appraisal and consider that there are areas where the scores can be updated to reflect more accurate information available publicly or provided in these representations by the design team. Our comments are provided below.

Air / Environmental Quality
4.8 The SA identifies that Option 1 is the most sustainable followed by Option 2 and 3. Wates Developments note that the SA considers that Option 2 could utilise the ‘existing multi-modal crossing across the railway line via Inlands Road and provides a multi-modal bridge and a pedestrian / cycle bridge. However it is recognised that the existing crossing is considered unsafe by Network Rail, and access off the end of South Lane could be constrained due to the character and nature of this historic lane’.

4.9 i-Transport have provided representations to this consultation which summarises the potential access solutions for Option 2. Paragraphs 1.7, 1.12 -1.13 note that Option 2 is closer to the services and facilities in Southbourne and therefore likely to promote more cycling and walking. Furthermore it notes that Option 2 could deliver a higher quantum of development without the need for a bridge due to it having more land for housing south of the railway line (most development traffic will route south to the A259) and due to it having the potential for access via Inlands Road, thereby avoiding the Stein Road crossing .

4.10 We are unaware of any evidence to support the contention that South Lane is a ‘historic lane’ and would request any evidence is shared so this can be appropriately assessed.

4.11 Wates Developments believe that this additional evidence further supports the scoring identified by the SA for the Air / Environmental Quality SA objective and that it should be converted from an ‘Uncertain’ significant effect to a ‘Positive’ effect in relation to Scenario 2.

Biodiversity
4.12 Wates Developments fully support the scoring within the SA which confirms that Option 2 is the most sustainable followed by Option 1 and 3. The SA notes that all options should comply with the 10% Biodiversity Net Gain (BNG) as a minimum but that this can only be confirmed during the design phase of development.

4.13 Wates Development are pleased to confirm that the Option 2 and indeed the Wates controlled part of Option 3 will indeed meet the 10% BNG as a minimum and will target improvements above this where viable. We consider that this justifies the SA scoring but also that the effects should be converted to a ‘Positive’ from ‘Uncertain’ for all three development Options.

Climate Change Adaptation
4.14 The SA notes that Option 2 is considered the least sustainable with a score of 3, followed by Option 1 with Option 3 regarded as the most sustainable.

4.15 To justify this scoring the SA notes that ‘Options 1 and 2 are considered likely to lead to significant negative effects as they contain areas of high surface water flood risk in key locations with regard to access’.

4.16 Wates Developments acknowledge that Options 1 and 2 do contain potential areas of flooding however it is important to note that the representations from i-Transport confirm that there are different options for the provision of access into the site and that one such access point (South Lane) has already been agreed in principle with the local highways authority. If flooding were to restrict the construction of the bridge (Wates Developments consider all risks can be mitigated), then other access routes into the site are available that are not impacted by flooding thereby eliminating development risk on this specific issue.

4.17 Based on this evidence, Wates Developments conclude that Options 1 and 2 should receive the same score of ‘2’.

Climate Change Mitigation
4.18 The SA scores all of the development options as ‘highly sustainable’ on the basis that all three options will be constructed to the Future Homes Standard 2025 which will set very high levels of energy efficient and require the use of renewable energy technologies on each dwelling. Furthermore, it states that all three Options are close to Southbourne which has a range of services and facilities thereby reducing the need to travel by car.

4.19 Wates Development fully agree with the commitment to the FHS 2025, however with respect to the access to key services and facilities we would like to refer the Council to Table 3.1 of the i-Transport representations which demonstrate that Option 2 is significantly closer to a number of key services and facilities than Option 1 such as; Southbourne Village Hall, Tesco Express, Southbourne Social Club, Southbourne Junior and Infant School, Southbourne Surgery, the Railway Station and the Industrial Estate (for employment opportunities).

4.20 On this basis of this evidence, Wates Developments consider it reasonable to reduce the Option 1 score to a 2 and leave Options 2 and 3 at the most sustainable with a score of 1.

Communities and Health
4.21 Wates Developments fully support the scoring of the three options under this SA Objective. Whilst we note that each option has different characteristics and strengths, it is without doubt that each option will result in significant positive benefits to the local community.

4.22 It is also relevant to note that Scenario 2 benefits from easier access to the existing doctors surgery and greater footpath / cycleway connections to services and facilities thus contributing to a healthier lifestyle. The Scenario will also benefit from the future delivery of a new children’s nursery as part of the consented Metis scrapyard scheme.

Economy and Employment
4.23 Wates Developments note that the SA scores all three options as ‘highly sustainable’ with respect to this SA objective. To support this the SA notes that ‘Option 1 would facilitate the greatest number of new homes within proximity to local employment opportunities’ which are identified as the nearby industrial village. Given the scale of the sites in question, different parts of each site will be located in closer proximity to the employment opportunities than other. It is therefore considered all Options should be scored a 1.

4.24 Table 3.1 of the representations from i-Transport confirms that Option 2 is c 500m closer to the Southbourne Industrial Estate than Option 1 thereby providing a greater benefit in terms of access to employment opportunities. With this evidence, Wates Developments consider that the score for Option 1 should be reduced to a ‘2’ with Options 2 and 3 remaining as a ‘1’.

Historic Environment
4.25 Wates Developments acknowledge that there are listed buildings within all three development Options with Options 2 and 3 close to buildings on Inlands Road and Priors Leaze Lane respectively.

4.26 Wates Developments do not believe that these heritage assets will be barrier to development and consider that suitable mitigation can be incorporated into the detailed design to ensure that development can proceed. On that basis we consider that the score for Option 3 should be reduced to a ‘2’ from a ‘3’.

Housing
4.27 Wates Developments acknowledge that all three options are intended to deliver up to 800 new affordable and private dwellings which supports the SA scoring all three Options with a significant positive effect. As stated earlier in these representations however, Wates Developments consider that Option 2 has the potential to deliver higher numbers on site.

4.28 At this stage of the assessment however, Wates Developments agree that all options should score the same high score.

Land, Soils and Resources
4.29 Wates Developments acknowledge that all three options will result in the loss of greenfield land some of which is classed as the best and most versatile (BMV) agricultural land. This impact is unfortunately necessary given the lack of brownfield land and the need for affordable and private housing. It is important to note however that the Landscape Technical Note (TN) confirms that there is more high value agricultural land to the west where as to the east it is a mix of 1, 2 and 3.

4.30 As with heritage assets, any loss of BMV land can be mitigated through good design such as locating green infrastructure upon this asset to ensure it is protected and preserved. Wates Development considers that the evidence above suggests that Option 1 will have a greater impact than Option 2 and 3 with respect to the loss of BMV agricultural land. We consider it appropriate to amend the scoring with Option 1 scoring a ‘2’ and Options 2 and 3 a ‘1’ and ‘2’ respectively.

Landscape
4.31 These representations are supported by representations and a Landscape Technical Note (TN) from SLR Consulting. This note provides evidence which demonstrates that:

• The conclusion that ‘Development to the east and west of Southbourne would
lead to a one-sided growth of the village’ is incorrect and that development towards the east of Southbourne would be the most appropriate and in keeping with the existing growth. The TN states that Option 2 would ‘in fact form a balanced and cohesive spatial growth structure which aligns with the current growth pattern of the settlement’.

• Development toward the west of Southbourne would ‘be breaking out into
open, agricultural land which would fundamentally change the form of the
settlement, whereas development to the east would be within existing lowdensity recent development.’

• The SA states that ‘a preliminary Landscape and Visual Impact Assessment
undertaken by the site promoter [Wates Developments] has identified a
potential moderate impact on the National Park and moderate / minor impact
on the National Landscape’. The TN states that ‘the scale of change in views from
the SDNP is generally slight or negligible, and consequently the overall visual
effects are likely to be moderate at most and often minor. In fact, the availability
of open and unobstructed views are generally very restricted’. It is noted that no
such assessment has seemingly been undertaken in respect of Options 1 and 3.

4.32 Wates Developments are of the opinion that, with the evidence presented in the TN, Option 2 should score a ‘1’ with Option 1 being the least favourable at a ‘3’. Option 3 should score a ‘2’.

Transport and Accessibility
4.33 Wates Developments note that the SA currently scores Option 2 as the least favourable with a ‘3’ followed by Option 3 and Option 1 as the most favourable. The justification for this score for Option 2 is:

• Option 2 is considered to perform least favourably as access off the end of South
Lane could be constrained due to the character and nature of this historic lane,
which would likely need to be widened to accommodate increased traffic.
However, the option performs well by utilising the existing multi-modal crossing
over the railway line via Inlands Road and providing both a multi-modal bridge
and a pedestrian / cycle bridge. Nevertheless, the significant deliverability and
viability concerns regarding the multi-modal bridge are recognised.

4.34 Representations by i-Transport confirm the following:
• Scenario 2 could provide an alternative access north of the railway line (via
Inlands Road) and a larger amount of land south of the railway. This means that
Scenario 2 is less reliant on the bridge than Scenario 1 (para 4.13).

• Vehicular access from South Lane (via a realignment of the lane into the site and
minor improvements within highway land) has been agreed in principle with
WSCC with proposals well advanced.

• Eight potential points of entry for pedestrians and cyclists have been identified
within Option 2 which all use land within the allocation and/ or public highway.

• Option 2 is less reliant of a bridge than Option 1. • Improvements to the cycling infrastructure on Cooks Lane can be delivered.

• Land is safeguarded in Option 2 for the footing of a footbridge.

4.35 With respect to Option 1 the i-Transport representations note that there is considerable uncertainty with respect to the deliverability of the bridge and footpath connection due to multiple landowners and the potential requirement for a ‘land swap’. This uncertainty has the potential to severely undermine the access strategy for Scenario 1 because, without a bridge, there will be no alternative pedestrian route across the railway line to footpath 231, demands for which will increase significantly with 800 homes. i-Transport’s experience is that Network Rail can object (and have done so before) to proposals that will increase demands on uncontrolled pedestrian level crossings. A grade separated pedestrian route across the railway line must be delivered. Further details are provided in i-Transport’s representations, with a supporting example.

4.36 With this evidence, Wates Developments considers it unreasonable to identify Option 2 as the ‘least favourable’ option and Option 1 as the most favourable. We consider that there is sufficient evidence to recognise Option 2 as the most favourable and Option 1 as the least favourable with respect to Transport and Accessibility.

Water
4.37 Wates Developments support the scoring identified in the SA against this SA Objective. We do not believe that either Option 2 or 3 will result in a significant negative effect with respect to water supply or quality.

Summary
4.38 Table 3.1 of the SA summarises the scoring of the three development Options and which cumulatively result in the following scores:

• Option 1 = 21;
• Option 2 = 19; and
• Option 3 = 18.

4.39 Following the information presented in these representations, Wates Developments believe that the cumulative scores should be amended as follows:

• Option 1 = 25;
• Option 2 = 14; and
• Option 3 = 17.

4.40 The revised scoring confirms that Option 2 is the most favourable development Option followed by Option 3 with Option 1 being the least favourable.

[See attached document for full submission]