These representations have been submitted by Pegasus Group on behalf of L&Q Estates.

The Draft Sustainability Appraisal (dated June 2021) includes the sustainability appraisal framework in Appendix 1. This includes a series of assessment questions for each sustainability appraisal objective which is used to assess local plans policies and proposals.

The Sustainability Appraisal Framework should include quantifiable assessment questions in order for the SA to be able to assess the plan equally and fairly. For example, accessibility should be quantified in order to assess the SA objectives of air quality, climate change and transport. Without the specific quantifiable framework criteria, SA is at risk of being ambiguous in its assessment.

The health and wellbeing appraisal objection seeks to assess sites on whether they are close to open space and sports facilities. The appraisal objective should also promote active travel and other lifestyle changes in order to assess this objective.

In order to assess SA objective 11, minimise flood risk, the site assessment question should include the flood zone designation so that the SA can equally and fairly assess the Plan.

In order to assess SA objective13, the ability of sites to provide a cultural or social activity on site or whether it is possible to access a cultural or social activity by walk, cycling, bus or train should be considered.

In order to assess SA objective 14, promoting social cohesion, the ability of a site to design out crime and encourage social cohesion should be assessed

The transport sustainability appraisal objective is focused on reducing the need to travel and promote sustainable modes of transport. The site assessment questions do not adequately reflect the objective particularly as they include whether sites are able to connect with the highway network which is at odds with trying to reduce the need to travel. Accessibility should also be quantifiable in order to assess sites equally and fairly.

The development strategy focuses development in the urban areas, A421 corridor and possible new railway stations. The site assessment questions for transport should include consideration of a site's proximity to a nearby rail stations as it forms a part of the development strategy.