Sustainability Appraisal Report for the Stroud District Local Plan Review – Pre-Submission Draft Plan
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Sustainability Appraisal Report for the Stroud District Local Plan Review – Pre-submission Draft Plan Appendices Prepared by LUC April 2021 Project Title: Sustainability Appraisal of the Stroud District Local Plan Review – Pre-submission Draft Plan Client: Stroud District Council Version Date Version Details Prepared by Checked by Approved by 1 27/04/2021 WORKING DRAFT for Full Council Meeting Sustainability Appraisal Report for the Stroud District Local Plan Review – Pre-submission Draft Plan Appendices Prepared by LUC April 2021 Planning & EIA LUC BRISTOL Offices also in: Land Use Consultants Ltd th Registered in England Design 12 Floor Colston Tower Edinburgh Registered number: 2549296 Landscape Planning Colston Street Bristol Glasgow Registered Office: Landscape Management BS1 4XE Lancaster 43 Chalton Street Ecology T +44 (0)117 929 1997 London London NW1 1JD FS 566056 EMS 566057 LUC uses 100% recycled paper GIS & Visualisation [email protected] Manchester Contents Appendix 1 1 Consultation Comments on SA Scoping Report and SA Reports for the Emerging Strategy Paper, Draft Plan and Additional Housing Options paper 1 Appendix 2 119 Baseline Information 119 Geography 120 Population 121 Housing 121 Social Inclusion and Deprivation 123 Health 124 Culture, Leisure and Recreation 124 Education 125 Crime 126 Landscape, Biodiversity and Geodiversity 126 Historic Environment 129 Air and Water 131 Flood Risk 132 Energy and Climate Change 134 Soils 136 Resource Use/Waste and Recycling 136 Employment and Economic Activity 137 Transport 140 Tourism 142 Appendix 3 153 SA findings for Policy Options considered at the Issues and Options stage (2017) 153 Introduction 154 Chapter 1: Key Issues 154 Chapter 2: Needs 154 Chapter 3: Future Growth Strategy 157 Chapter 4: Background Studies 161 Appendix 4 162 Assumptions Informing the Appraisal of Site Options 162 Appendix 5 202 Detailed SA Matrices for all of the Site Options considered to date 202 Summary of Sustainability Appraisal findings for all of the Reasonable Site Options considered to date 203 Residential site options 230 Site options considered following the Emerging Strategy Paper (prior to consultation on the Draft Plan) 585 Sites options considered following the Draft Plan (November 2019) including those considered as part of the Additional Housing Options consultation (October 2020) 643 Appendix 6 677 Summary of SA effects identified for the Emerging Strategy Paper 677 Appendix 7 685 Detailed SA Matrices for site allocations in the Draft Plan and the Pre-submission Draft Plan 685 Sites Allocations in the Draft Local Plan and the Pre-submission Draft Plan 686 Appendix 8 814 Summary of SA Findings for the Strategic Growth Options 814 Appendix 9 820 Audit Trail of Policy and Site Options 820 Appendix 1 Consultation Comments on SA Scoping Report and SA Reports for the Emerging Strategy Paper, Draft Plan and Additional Housing Options paper 1 Table A1.1: Consultation responses to comments on the Emerging Strategy Paper SA Report Consultee Representation Comment SA Team Response relating to Natural SA rep 1 – Natural England welcomed the thorough approach taken Comment noted. England consideration of to preparation of the SA. The loss of greenfield land and impacts on higher value biodiversity and Comments relating to the emerging growth strategy are agricultural soils have been considered as part of SA objective 13 geodiversity; included specifically with regards to the themes of as set out in Table 2.2: SA framework for the Stroud District landscape and biodiversity and geodiversity (SA objective 7), landscape Local Plan Review. The emerging growth strategy (as presented townscape; and and townscape (SA objective 8) and efficient land use in the Emerging Growth Strategy Paper) has been appraised as efficient land use (including soils and best most and versatile land) (SA having significant negative effects in terms of both loss of objective 13): greenfield land and higher value agricultural soils. The full effects have been described in Appendix 6 and the summary is • Table 6.4 Summary of SA effects for emerging growth presented in paragraph 6.40 of the main body of the SA report strategy’ allocates a ‘- -?’ (Significant adverse) score for the Emerging Growth Strategy Paper. The summary of these for SA7 Biodiversity. This is the only SA objective to effects is presented in Appendix 6 of this report. The overall attract such a score, highlighting the juxtaposition of effect has been recorded as mixed minor positive and significant the proposed new settlement immediately adjacent to negative given that the strategy would also prioritise the use of the estuary with its multiple nature conservation brownfield sites across the district. designations and potential ‘functionally linked land’. The consultee states that scale of this development The SA report has drawn on information that is available and also requires consideration of loss of ‘best and most proportionate to its strategic nature. Should further landscape versatile land’. Natural England is to continue to sensitivity assessment work become available it will be used to advise the LPA in relation to this allocation. inform the findings of the forthcoming iterations of the report. • The general trend towards avoiding those sites The findings of the HRA in relation to land and waterways which requiring development within the Cotswolds AONB, may be functionally linked to the Severn Estuary designations consistent with this designated landscape’s level of will be used to inform forthcoming iterations of the SA report, in protection is welcomed by the consultee. The SA the appraisal of the Local Plan in relation to SA objective 7: Report describes partial coverage of the district using biodiversity and geodiversity. Landscape Sensitivity Analysis (LSA) and makes a case for further evidence base work to address this shortfall. The consultee states that subsequent stages of the local plan’s development should take account of any gaps in LSA where these represent a material gap in the evidence base. • The consultee also highlights the commentary of the SA Report at paragraph 6.47 which states that most 2 Consultee Representation Comment SA Team Response relating to significant infrastructure improvements would not come forward in close proximity to any national or international biodiversity designations and that there may be a need to identify reserve sites for housing if potential sites for development do not come forward. This commentary of the SA report has been related to comments on the HRA with regards to the need for further work to understand the distribution, extent and sensitivities of land and waterways functionally linked to the Severn Estuary designations. Environment SA rep 2 - The consultee notes that their previous recommendations Comment noted. Agency consideration of have been included within the sub objectives for SA 12. In relation to the residential site options, while paragraph 5.9 of flood risk (SA The consultee does not concur with the statement made the SA Report for Emerging Strategy Paper refers to impacts of objective 12) in the section of the report which relates to the residential developing greenfield or brownfield land on flood risk it also site options (from paragraph 5.9 of the SA Report for states “if any of those sites (within flood zone 3) are to be Emerging Strategy Paper) because too much weight is allocated in the Local Plan Review it will be necessary to direct being given to the issue of surface water runoff in relation built development to those areas of the sites that are outside of to other sources of flood risk. The consultee states that flood zone 3 and incorporate appropriate mitigation measures fluvial flooding may have a greater impact, or at such as Sustainable Drainage Systems (SuDS)”. All sites have minimum equate to potential impacts from greenfield been appraised based on the area of the site that is within Flood sites. Zone 3a and 3b. The assumptions which have been used to achieve a consistent approach to the appraisal of site options are The consultee considers that too much emphasis seems presented in Appendix 4 of the SA Report for Emerging Strategy to have been placed on potential flood risk from surface Paper and this report. The appraisal of SA objective 12 therefore water than other risk sources when appraising the takes into account land that is located within these higher risk potential sites for allocation. The consultee states that flood areas as well as whether it is greenfield or brownfield land. assumptions for the appraisal of sites should be updated As such fluvial flood risk has been considered as part of the SA. as follows (SA objective 12): The above points considered the SA assumptions have been • Sites that are entirely or mainly (i.e. >50%) on updated in this iteration of the SA Report to better reflect the greenfield land that is within flood zones 3a or 3b or consultee’s comment. Changes to the SA assumptions are mainly on brownfield within flood zones 3a or 3b are shown in underlined text. The appraisal of all sites has been likely to have a significant negative (--) effect. updated in line with the change to this SA assumption. • Sites that are either entirely or mainly on greenfield outside of flood zones 3a and 3b, or that are entirely 3 Consultee Representation Comment SA Team Response relating to or mainly on brownfield outside flood zones 3a or 3b This SA report is reflective of the potential green infrastructure are likely to have a minor negative (-) effect. to be incorporated as part of sustainable layouts through an • Sites that are on brownfield land outside of flood appropriate approach where it is included in the Local Plan zones 3a and 3b are likely to have a negligible (0) document. The mini-vision for Stroud Valleys was appraised in effect. the SA Report for the Emerging Strategy Paper as it has been In relation to the Stroud Valleys the consultee states that presented in the Emerging Strategy Paper which does not provision of appropriate sustainable layouts has the contain explicit reference to sustainable layouts or green potential to deliver benefits for green infrastructure in this infrastructure for this area.