Draft Thanet Local Plan - 2031 - Pre-Submission Publication, Regulation 19

Comment ID 8
Document Section Sustainability Appraisal (no name) [View all comments on this section]
Respondent Richard Agnew - Gladman [View all comments by this respondent]
Response Date 19 Oct 2018
Comment

     Sustainability Appraisal

  • Under section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA). Incorporating the requirement of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable
  • The Council needs to ensure that the results of the SA process clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been Undertaking a comparative and equal assessment of each reasonable alternative, the Council’s decision making and scoring should be robust, justified and transparent.
  • Gladman reminds the Council that there have now been a number of instances where the failure to undertake a satisfactory SA has resulted in Plans failing the test of legal compliance at Examination or being subjected to legal challenge
  • The Sustainability Appraisal underpinning the Local Plan is concerning, especially the reliance on a ‘no policy’ option as the reasonable alternatives to the policy We would suggest that a ‘no policy’ option is not a reasonable alternative to the proposed housing provision. Having considered the evidence before us regarding the level of affordable housing need in the district we would expect an increased housing requirement to deliver additional affordable housing to have been considered. It is disappointing that there has not been a more thorough assessment of delivering varying levels of additional housing needs.
Attachments
Officer's Response Not yet available.
Proposed Change
Notes