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on <strong>the</strong> air quality is adverse (RSF 16), whilst it also has a negative impact on <strong>the</strong> desire to<br />

conserve and enhance <strong>the</strong> region’s bio‐diversity (RSF 19).<br />

16.128 The preferred approach overall does not result in a significantly different (ei<strong>the</strong>r adverse or<br />

beneficial) impact to its alternatives and has <strong>the</strong>re<strong>for</strong>e been chosen.<br />

Location Policy 2 (LP02) – Housing Provision and Distribution<br />

16.129 The Council’s HRA considered three <strong>Local</strong> <strong>Plan</strong> policies – LP01, LP02 and LP08 and <strong>the</strong>ir ability<br />

alone or in combination with o<strong>the</strong>r plans or projects to adversely affect <strong>the</strong> integrity of two<br />

European site – Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC.<br />

Based on <strong>the</strong> in<strong>for</strong>mation available but against <strong>the</strong> advice of Natural England, <strong>the</strong> Council was<br />

able to ascertain that implementation of policies LP01, LP02 and LP03 would not alone or in<br />

combination with o<strong>the</strong>r plans or projects adversely affect <strong>the</strong> integrity of ei<strong>the</strong>r European<br />

site.<br />

16.130 Three core alternatives were considered. LP02‐ A1 145 units are identified representing an<br />

annual provision over 15 years of about 2000 units within <strong>the</strong> urban area. However, LP02<br />

and LP02‐A2 provides <strong>for</strong> 161 units p/a involving three additional sub‐divisions involving<br />

variously reserve site and green belt releases. LP02‐A3 (a)/(b) would also require ei<strong>the</strong>r<br />

higher density development in <strong>the</strong> urban area or additional land to be released from <strong>the</strong><br />

green belt to accommodate this scale of growth (550 units p/a).<br />

16.131 It is observed that LP03‐A3 (a)/(b) have a consistent trend towards a significant adverse<br />

impact and so <strong>the</strong>se were excluded in <strong>the</strong> first iteration. In <strong>the</strong> next iteration it is noted that<br />

<strong>the</strong> remaining alternatives mostly have an uncertain/adverse impacts on <strong>the</strong> environmental<br />

receptor’s impact pathways. However, <strong>for</strong> LP02‐A2(c) was assessed to have an adverse<br />

impact on ER06 but it per<strong>for</strong>med best on ER10. The Council concluded that all <strong>the</strong> remaining<br />

alternatives should remain in <strong>the</strong> second iteration as <strong>the</strong>y had varying degrees on impact with<br />

no overall alternative emerging as clear choice.<br />

16.132 As <strong>the</strong> aggregate appraisal concluded no clear preferred alternative with LP02, LP02‐A1 and<br />

LP02‐A2, it was appropriate to consider <strong>the</strong> wider perspective of <strong>the</strong> SA. This became an<br />

important part of <strong>the</strong> appraisal as <strong>the</strong> Council wished to ensure that <strong>the</strong> development desired<br />

by <strong>the</strong> local community was recognised. However, <strong>the</strong> overall conclusion of <strong>the</strong> SA was<br />

positive <strong>for</strong> all alternatives. With <strong>the</strong> background of not excluding <strong>the</strong> LP02, LP02‐A1 and<br />

LP02‐A2 alternatives <strong>the</strong> following final appraisal was undertaken.<br />

16.133 From <strong>the</strong> data in <strong>the</strong> SHLAA, <strong>the</strong> housing allocation in <strong>the</strong> previous plans has never acted as a<br />

constraint on development and each application is considered within <strong>the</strong> policy guidelines.<br />

Accordingly, whilst a locally set housing requirement should be viewed as guidance, <strong>for</strong> <strong>the</strong><br />

purposes of national guidance it is necessary to ensure an adequate land supply is available<br />

and this requires a <strong>for</strong>mal housing figure to be established.<br />

16.134 The Coalition Government wants to boost housing delivery, <strong>the</strong>re<strong>for</strong>e, LP02‐A1 which would<br />

reduce <strong>the</strong> annual housing target from 161 units to 145 units is not considered to be realistic<br />

or justified approach given this national guidance. Alternative 3 would set house building<br />

targets beyond those achieved in <strong>the</strong> Borough even in <strong>the</strong> boom times. This alternative was<br />

however eliminated through <strong>the</strong> SEA process. Alternative 2 emerged as <strong>the</strong> preferred<br />

alternative as being consistent with <strong>the</strong> evidence base in <strong>the</strong> South East <strong>Plan</strong><br />

16.135 From <strong>the</strong> perspective of <strong>the</strong> SEA/SA <strong>the</strong>re were 3 sub‐alternatives of LP02 A, A1 – A2 <strong>for</strong><br />

consideration. There was no definitive view as to which sub‐alternative emerged as <strong>the</strong><br />

preferred alternative. It would ei<strong>the</strong>r require <strong>the</strong> release of <strong>the</strong> DERA size site from <strong>the</strong> green<br />

belt, <strong>the</strong> release of reserve sites or <strong>the</strong> release of urban edge SHLAA green belt sites.<br />

16.136 <strong>Plan</strong>ning <strong>for</strong> future homes in Runnymede is a key function of this Strategy and a major<br />

component of <strong>the</strong> Sustainable Community Strategy (SCS). A range of housing is needed to<br />

meet <strong>the</strong> future needs of <strong>the</strong> population in <strong>the</strong> Borough; this includes homes <strong>for</strong> families and<br />

<strong>for</strong> first time buyers, and <strong>for</strong> <strong>the</strong> elderly, who are <strong>for</strong>ming a growing proportion of <strong>the</strong> total<br />

population. There is a particularly strong need to provide af<strong>for</strong>dable housing to meet <strong>the</strong><br />

needs of those who cannot af<strong>for</strong>d to buy or rent at market levels. Previous consultations on<br />

Page | 218 Runnymede BC FINAL <strong>Sustainability</strong> <strong>Appraisal</strong> <strong>Report</strong> – Feb 2013

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