Object

Publication Plan November 2022

Representation ID: 4213

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objective 1: the SA is wrong to record GHG emissions as uncertain, both in respect of the number of dwellings on the site and because of the lack of differentiation for undeveloped/greenfield sites. The SA fails to meet the SEA directive requiring integration of environmental considerations with a view to promoting sustainable development. Objective 2: SA fails to explain how post-mitigation scenario has changed from major negative to positive. Objective 3: Assessments of impact on LNR and habitats fail to have regard to evidence submitted by ecologists in 2021 consultation and Staffordshire Wildlife Trust. Objective 12: Appraisal notes that residents at the proposed site would have ‘unreasonable’ sustainable access to employment. This is contrary to local plan aim to locate development in more sustainable locations making the plan unsound. Inaccuracies are also present in the Appendix H site selection reasons and this section is at odds with the objectives of the Sustainability Appraisal

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