SA of Canalside DPD

5.0 SUSTAINABILITY APPRAISAL OF THE WARWICK CANALSIDE DPD

SA of DPD Objectives

5.1 The Canalside DPD includes a list of objectives as follows:

• Identify issues and opportunities and address/exploit them
• Look at a wide range of potential schemes to encourage more use of the canals and be imaginative and creative
• Increase the use of the canals and their environs to open them up to a new range of activities
• Create new frontages to face the canals instead of backing onto them, especially with new residential development
• Change perceptions of hidden backwaters as dangerous and crime ridden
• Make the canals safe and attractive and accessible to everyone
• Improve the visual aspects of the canals and widen their appeal to include all sectors of the community
• Protect any aspect of the canal that needs to be preserved whether tangible or conceptual
• Protect wildlife, habitats and water quality
• Increase awareness by use of directional and information boards in appropriate locations

5.2 A compatibility analysis was undertaken of the DPD's objectives against the SA objectives in the SA Framework using professional judgment and a simple compatibility approach - + compatible; - not compatible; ? uncertain; and O not applicable. The findings are shown in the table following:

Table 5.1: Compatibility Analysis – DPD & SA Objectives

DPD Objectives SA Objectives	Issues & Opportunities	Range of schemes	Increase Use	Create new Frontages	Change Perceptions	Safe & accessible	Improve visual	Protect any aspect	Protect wildlife & WQ	Increase Awareness
1.Economy	+	+	+	+	+	+	+	+	+	+
2.Sustainable Transport	+	+	+	O	+	+	+	+	?	+
3.Reduce Travel	+	+	+	O	+	+	+	+	?	+
4.Reduce Waste	+	+	?	O	+	+	+	+	+	+
5.Use of Land	+	+	+	O	+	+	+	+	+	+
6.Natural Environment	+	+	?	O	?	O	+	+	+	?
7.High Quality	+	+	+	+	+	+	+	+	+	+
8.Historic Environment	+	+	?	O	+	O	+	+	O	+
9.Air, Water, Soil Quality	+	+	?	O	+	O	+	+	+	+
10.Climate Change	+	+	+	O	+	+	+	+	?	+
11.Flood Risk	+	+	+	O	O	+	O	+	+	+
12.Housing	+	+	+	+	+	+	+	+	+	+
13.Services & Facilities	+	+	+	O	+	+	O	+	?	+
14. Health & Wellbeing	+	+	+	+	+	+	+	+	+	+
15.Reduce Poverty	+	+	+	O	+	+	+	+	+	+
16. Reduce Crime	+	+	+	+	+	+	+	+	+	+

5.3 Most SA Objectives were found to be compatible with the DPD objectives; there were no incompatibilities identified. A few uncertainties were recorded, for example, the historic and natural environments and increased use. However, other policies in the Local Plan will ensure that both objectives are progressed and protected. The SA only made one suggestion – to amend the objective on protecting wildlife and water quality to "improving" and thus be more in line with the recent changes to biodiversity net gain in planning^[36].

SA of Site-Specific Policies CS9-CS11

5.4 The detailed SA of the 3 sites proposed for residential development is presented in Appendix II of this SA Report.

Table 5.2: Site Specific Policies – SA Summary

DPD Site Specific Policies SA Objectives	CS9 Sydenham Industrial Estate		CS10 Industrial Estate Millers Road/ape Road		CS11 Former school at Montague Road
1.Economy	=		=		=
2.Sustainable Transport	+	+?	+	+?	+	+?
3.Reduce Travel	+		+		+
4.Reduce Waste	=		=		=
5.Use of Land	++		++		++
6.Biodiversity; Landscape	+	+	++	+	++	++
7.High Quality	+		+		+
8.Historic Environment	+		=		+
9.Air, Water, Soil Quality	=		=		=
10.Climate Change	+		+		+
11.Flood Risk	=		=		=
12.Housing	+		+		+
13.Services & Facilities	=		=		=
14. Health & Wellbeing	+		+		+
15.Reduce Poverty	+		+		+
16. Reduce Crime	+		+		+?

5.5 The SA found mostly neutral or positive effects; there were no negative effects identified. The review of industrial estates undertaken to inform the Local Plan found that these estates no longer reflect the requirements of many businesses as explained in Local Plan Policy DS8 Employment Land. Employment land to meet needs is allocated in Policy DS9 and guided through Policy EC1 Directing New Employment Development. Criteria in DPD Policies CS9 & 10 further explain the current situation with regard to the current use of industrial units and requirements for redevelopment. Therefore, no loss of employment land and neutral effects for SA No 1 Economy.

5.6 The 3 site areas are well located within the urban areas of Leamington/Sydenham (CS9) and Warwick (CS10-11) for sustainable transport with good access to bus stops and railway stations – minor positive effects for SA No 3 Travel; some uncertainty as to the extent that this might help reduce congestion elsewhere. DPD CS2 provides some mitigation measures that could help reduce congestion by requiring new development to meet with district parking standards. Also, good access to local services and community facilities nearby indicating neutral effects for SA No 13. All new development can reduce waste & increase recycling in accordance with other LP Policies – neutral effects.

5.7 Reuse of previously developed land has major positive effects for prudent use of land and resources, reducing loss of greenfield or agricultural land – for all three areas; remediation of any contamination associated with CS11 will have further positive effects for the soil resource and helping to resolve an existing sustainability problem.

5.8 Local Plan Policy NE3 Biodiversity requires new development to lead to no net loss and where possible a net gain; DPD Policy CS4 requires protection and enhancement of the canal green corridor – minor positive effects for biodiversity and SA No 6. DPD Policies CS10 & CS11 include specific requirements for green space indicating further positive effects for biodiversity and the green infrastructure networks that could be synergistic and cumulative in the longer term, extending beyond the canals themselves.

5.9 Proposals must comply with LP Policy BE1 Layout & Design and DPD Policy CS1that requires new development to be of an appropriate scale, height, form and massing, utilising appropriate materials and details; and reflect, respect and reinforce local architectural and historical distinctiveness, particularly where sites fall within the Canal Conservation Area. The redevelopment and enhancements will result in positive effects for landscape/townscape for SA Nos 6 & 7 protecting/enhancing local character and promoting high quality-built environments.

5.10 Such an approach to design and redevelopment will also promote positive effects for SA Nos 7 and 16 – to improve safety; reduce crime, fear of crime and antisocial behaviour. DPD Policies CS9 & CS11 specifically refer to requirements for design/layout that provides surveillance of the canal, increasing safe access – all with positive effects that could be synergistic and extend beyond the immediate area thus helping to resolve an existing sustainability issue.

5.11 The historic environment is protected through LP Policies HE1-4 and DPD Policy CS1 requires new development to respect and reinforce the local historical distinctiveness indicating at least neutral effects but likely positive effects through regeneration, enhancement of the built environment. There are no Listed Buildings of Scheduled Monuments near to the sites, with the exception of the Grade II listed Bridge House adjacent to the Coventry Road Bridge at edge of CS11 – redevelopment here may improve the existing setting. The potential for archaeological resources is recognised at the CS9 site and there are site-specific requirements to investigate. Overall, no significant sensitive assets and mitigation measures in place, indicating neutral effects for SA No 8 Historic Environment.

5.12 LP Policy NE5 Protection of Natural Resources requires that new development should not give rise to air, or water pollution, indicating neutral effects for SA No 9. It is noted that there may be some particular issues associated with air quality for CS11 and the DPD draws attention to the need for proposals to address this – any proposal will need to be in compliance with the Air Quality SPD (January 2019) and indicating that mitigation measures are in place. DPD CS2 requires that parking standards should be met, and this may reduce congestion and associated air quality emissions.

5.13 New development must comply with LP Policies CC1-2 on climate change adaptation including sustainable construction, multifunctional green infrastructure, and water efficiency (also Policy FW3) - with minor positive effects that will be cumulative in the longer term. DPD Policy CS5 requires that canals should be recognised as a potential renewable energy resource. All development must also comply with LP Policy FW1 Reducing Flood Risk indicating at least neutral effects; reinforced by DPD Policy CS1 that requires there should be no increase in the risk of flooding.

5.14 Provision of housing will have positive effects for SA No 12, contributing to meeting the identified needs. Policies CS9 & CS10 require specific proportions for low cost or affordable homes – and this will contribute to positive effects for SA No 15 aiming to reduce poverty and social exclusion.

5.15 DPD Policy CS1 requires new or improved safe access to the canal; this is reinforced by DPD Policies CS9-11 that specifically require maintenance, enhancement of open access to the canal with new public access in suitable locations – all contributing to enhanced access to the community asset of the canal with positive effects for SA No 13 on accessibility. These effects may be synergistic and extend beyond the immediate environs of the sites.

5.16 Provision of good quality housing will contribute to health and wellbeing; enhanced access to the canal for walking, cycling and other leisure or reflective activities will all encourage a healthier lifestyle and contribute to positive effects for health & wellbeing and SA No 14 for improving health. The canals are nationally waymarked long distance paths and the enhancements to these sites will contribute to an improved environment for other users.

SA of Policies CS1-CS8

5.17 The adopted Local Plan recognises the changing requirements for business and commercial/industrial estates as explained in Local Plan Policy DS8 Employment Land with the commitment to investigate the potential for these three sites set out in LP Policy DS17. Thus, the LP and the DPD have set in place guidance to enable effectiveness use of land resources with overall neutral effects indicated through protection of employment land elsewhere.

5.18 Provision of high-quality housing will contribute to health and well-being with positive effects. The DPD notes that some purpose built student accommodation (PBSA) is already being constructed and that this can help to reuse the more neglected canalside sites. DPD Policy CS6 seeks to ensure that PBSA is located in suitable areas and to reduce the concentration of such developments in any one area – the Council is committed to preparing another DPD dealing with this specific type of housing development through the district. For now, the Canalside DPD explains that linear PBSA development will not be suitable along the canal and that such proposals must be in accordance with LP Policy H6 and any made Neighbourhood Plans. This ensures mitigation measures are in place to encourage the appropriate range and mix of housing in the most suitable locations.

5.19 The site areas are all located within the urban areas of Warwick and Leamington Spa/Sydenham with good access to local services and facilities. The Grand Union Way is a national long-distance walking route and is a component of the Centenary Way^[37] – 100 miles of walking networks throughout Warwickshire. The redevelopment and enhancements of these sites, including improved accessibility and safety will encourage more use of the path – to access local services and the wider network – and this could have synergistic and cumulative positive effects in the longer term that extend beyond the sites through into the wider district and beyond. The use of canals is promoted widely for a range of activities by the Canal & River Trust (CART)^[38] for boating, angling, walking, cycling, wildlife, art & learning – all with positive effects for health and well-being, both mental and physical.

5.20 Policy CS7 requires new and improved directional and informational signage where appropriately designed and located. Policy CS8 encourages the inclusion of public art in new schemes where it makes a positive contribution to the local area. Both these policies will help encourage use of the canal areas for sustainable transport and other activities, further enhancing the positive effects indicated for well-being and health.

5.21 Policy CS1 requires that development frontages should address the canal, allowing views and providing much needed surveillance, increasing security and reducing fear of crime. In residential developments this includes maintaining an open view of the canal from residential properties and gardens. Increasing security and reducing crime or fear of crime overall will have positive effects for health and well-being.

5.22 The increased accessibility and safety of the canal pathways as described previously will have positive effects for objectives on sustainable transport and the location of the sites in urban areas will reduce the need to travel. DPD Policy CS1 requires new or improved safe access to the canal as essential and should be included wherever possible, including bridges and accesses to the canal from nearby roads. Where appropriate, developments should integrate with existing paths, streets, circulation networks and patterns of activity.

5.23 CS1 also requires the provision of a towpath which will be wide enough to accommodate pedestrians, cyclists and wheelchair users with the aim of creating a cycle/walking route alongside the canal or, where a towpath already exists, it is widened and/or improved where possible to allow access for all users, without compromising the natural environment. This will ensure implementation of sustainable transport with positive effects that should be cumulative and synergistic in the longer term.

5.24 Policy CS2 recognises that parking will be required for new development and requires that it should be in accordance with the Council's adopted Parking Standards. However, the location and setting of the parking should be sympathetic to any environmental, historic or landscape features ensuring that canalside frontages do not present the view of a car park – mitigating any negative effects for SA No 6 the natural environment. CS2 also requires safe parking for cycle and motorcycles where there is adequate surveillance – further contributing to positive effects for SA No 16 to reduce crime or fear of crime. The DPD acknowledges that movement of freight on the canal systems is not viable and that the use of the canals is focused on leisure, access, biodiversity and well-being.

5.25 The major threat to air pollution is from traffic emissions^[39]. Warwick District Council has designated five air quality management areas (AQMA) due to elevated annual average concentrations of nitrogen dioxide (NO²). The AQMAs include Warwick Town Centre, Coventry Road (Warwick), Leamington Spa and two AQMAs in Kenilworth.              Guidance on air quality and planning is provided through the Air Quality SPD (January 2019)^[40] that includes information and suggests mitigation measures. Any new development arising from the Canalside DPD will need to take into account other LP policies and the Air Quality SPD such that potential negative effects should be mitigated. The selection of areas of redevelopment within the existing urban areas and with good accessibility to services and facilities should reduce the need to travel by private vehicles and associated reduced traffic emissions.

5.26 Policy CS5 recognises that canals are a potential renewable energy resource; canal water could be used for heating and cooling buildings – also for onshore hydropower where practicable. Implementation of such schemes will have positive effects for air quality and climate change in the longer term. The supporting text explains that canals and rivers contribute to urban cooling and thus reduce carbon dioxide emissions. Introducing more soft landscaping and trees into new developments will also contribute to reducing climate change effects in the longer term.

5.27 LP Policy NE5 Protection of Natural Resources requires that new development should not give rise to land, air, or water pollution, indicating neutral effects for SA No 9. ensure that, where evidence of contamination exists, the land is made fit for its intended purpose and does not pose an unacceptable risk to sensitive receptors Reuse of previously developed land is an effective use of land resources and provides mitigation measures by avoiding use of greenfield or best and most versatile agricultural land for development.

5.28 The DPD explains the importance of the canals as green corridors for wildlife and people. Policy CS4 requires that new development should incorporate features that recognise, protect and enhance the biodiversity and environmental quality of the canal corridor; a detailed arboricultural survey is also required. An environmental impact report is required where development directly abuts the canal or towpath or is likely to impact on the setting of the canal. These requirements provide mitigation measures to ensure that biodiversity is enhanced and will be implemented with positive effects that will be cumulative in the longer term, helping to extend green infrastructure networks.

5.29 Policy CS1 provides detailed guidance for new development with regard to building being of an appropriate scale, height, form and massing, utilising appropriate materials and details. Where appropriate, developments should integrate with existing paths, streets, circulation networks and patterns of activity. Developments should respect and reinforce local architectural and historical distinctiveness, particularly where sites fall within the Canal Conservation Area. New residential development will be assessed against the principles outlined in the Council's Residential Design Guide to ensure that a high standard is attained – further confirming that there should be positive effects for townscape/landscape objectives that will be synergistic and cumulative in the longer term.

5.30 The recent designation of the Canal Conservation Area^[41] with documents and maps provides detailed guidance for new development to ensure that the historic environment is understood, protected and enhanced, including the settings of historic assets. Policy CS1 requires that developments should reflect, respect and reinforce local architectural and historical distinctiveness, particularly where sites fall within the Canal Conservation Area, thus providing further mitigation measures and ensuring at least neutral effects with the potential for some positive effects.

5.31 The potential for archaeological interest has been recognised and Policy CS3 requires that new development should undertake an assessment of the archaeological status of the site. This provides mitigation measures to further protect the historic environment and avoid or minimise any negative effects.

5.32 The adopted Local Plan provides guidance to protect water resources: LP Policy FW4 Water Supply requires developers to ensure that there is an adequate water supply having regard to the Severn Trent Water's WRMP; it also recognises the ecological status of water and requires that development must not affect objectives as set out in the River Severn RBMP. LP Policy NE5 Protection of Natural Resources requires that new development should not give rise to water pollution where the level of discharge, emissions or contamination could cause harm to sensitive receptors; does not result in a reduction in the quality or quantity of groundwater resources. Thus, the Local Plan Policies provide mitigation measures to ensure that there are no significant negative effects on water resources, water levels or water quality.

5.33 LP Policies FW1 Reducing Flood Risk and FW2 Sustainable Drainage provide strong clear guidance to ensure that there will be no increase in flood risk and that sustainable water management will be encouraged with requirements for incorporation of sustainable drainage systems (SuDS) that provide biodiversity, water quality and amenity benefits. The LP Policies are further reinforced by DPD Policy CS1 that requires new development should not have an adverse impact on water quality or increase the risk of flooding. Overall, there is strong mitigation provided through embedded policy to ensure no negative effect on the water environment.

Habitats Regulations Assessment (HRA)

5.34 The HRA screening (2014)^[42] undertaken of the developing Local Plan concluded that there would be no likely significant effects (LSEs) associated with changes in air quality, water quality and levels, recreational disturbance or habitat loss/fragmentation on Ensor's Pool SAC. The SAC is somewhat isolated as an abandoned claypit and designated for the presence of the white-clawed crayfish such that it was unlikely that the new development proposed in the Local Plan would have any impacts. The pool is clay-lined and not connected to other waterbodies/watercourses; it is replenished through rainfall.

5.35 The HRA screening at that time also noted that the need for supplying water from Wales to growing Midland conurbations could have a potential impact on hydrologically dependant Welsh SACs. At that time, Severn Trent Water advised that water resources in the Warwick District area would continue to be sourced locally and therefore, the HRA screening concluded that this would not be a potential issue for the Warwick Local Plan.

5.36 The Warwickshire River Avon drains into the Severn Estuary to the south-east and this is designated as a SPA, SAC & Ramsar. The canals are supplied through surfacewater and groundwater sources and therefore, there is the potential for environmental pathways through the water networks. It is considered very unlikely that any development activities arising from the Canalside DPD would have significant effects on designated sites.

5.37 The Warwick District area is some 75 km distance^[43] from the Severn Estuary such that it is considered very unlikely that there is any relevant functionally linked land. It is understood that there is some concern about increased recreational use arising from new development in Gloucestershire and potential impacts on functionally linked habitats used by certain bird species associated with the Severn Estuary SPA/SAC/Ramsar. However, it is considered that the Warwick area is too distant and the limited new development proposed in the Canalside DPD indicates that there would be no LSEs in this respect.

5.38 However, it is appreciated that the HRA screening for the Warwick Local Plan was prepared before certain recent CJEUs (2017-2018)^[44] were issued with significant implications for the HRA methods used in the UK. Competent authorities cannot take account of any integrated or additional avoidance or reduction measures when considering at the HRA screening stage whether a plan is likely to have an adverse effect on a European Site. The HRA screening (2014) for the Local Plan reached its conclusions taking into account embedded policy mitigation such as environmental criteria in policies that have to be met.

5.39 Therefore, in consideration of the increased awareness and requirements for sustainable water management and building resilience to climate change; the fundamental change to the UK method of undertaking HRA screening/ appropriate assessment with recent updated Government guidance (July 2019)^[45] that takes into account the implications of the CJEUs; increased understanding of potential disturbance on SPA/SAC/Ramsar sites, particularly the Severn Estuary; and since the Canalside DPD is focused on the water environment – the HRA screening with regard to water levels & water quality was updated.

5.40 A pragmatic and proportional approach was taken and to clearly demonstrate due process in line with the updated guidance. Since the DPD is focused on canals that are linked to other water systems, there could be the potential for environmental pathways. The Warwick Local Plan does include relevant policy mitigation and this HRA essentially clarifies this through the updated methodology - thus making the process and conclusions explicit with regard to the updated requirements. This precautionary approach is being taken in particular consideration of the significant changes to the HRA process in the UK since the screening undertaken for the Local Plan.

5.41 The primary reason for designation of habitats in the Severn Estuary SAC^[46] is for its estuaries, mudflats, sandflats and Atlantic salt meadows; also, for species of lamprey and the Twaite shad. The Severn Estuary SPA^[47] supports internationally important assemblages of overwintering birds with conservation objectives for Bewick's Swan, Gadwall, White-fronted Goose Dunlin, Shelduck and Redshank. The Ramsar^[48] designation relates to the importance of the estuary and river for migratory fish (salmon, trout, lamprey, shad and especially eel) and the particular importance for birds during spring and autumn.

5.42 HRA screening indicates that there is the potential for an environmental pathway through the linkages between the water networks of river, canal and groundwater with the River Severn catchment area^[49] covering the Warwick District area. Whilst the extent of the new development that will be supported through the Warwick Canalside DPD is limited, there could be the potential for likely significant effects on the designated site – its functionally linked water and/or land since migratory birds may extend some distance upstream on the River Severn.

5.43 Therefore, if this aspect is taken to the second stage of the HRA process – appropriate assessment – the embedded policy mitigation measures may be taken into consideration. Local Plan Policy FW4 Water Supply requires developers to ensure that there is an adequate water supply having regard to the Severn Trent Water's WRMP; it also recognises the ecological status of water and requires that development must not affect objectives as set out in the River Severn RBMP. LP Policy NE5 Protection of Natural Resources requires that new development should not give rise to water pollution where the level of discharge, emissions or contamination could cause harm to sensitive receptors; does not result in a reduction in the quality or quantity of groundwater resources. DPD Policy CS1 that requires new development should not have an adverse impact on water quality or increase the risk of flooding. Local Plan Policy NE1 Green Infrastructure and NE2 Protecting Designated Biodiversity provide further embedded mitigation measures through policy requirements.

5.44 Therefore, it was concluded that the Warwick Canalside DPD will not have adverse effects, alone or in combination with other plans and projects, on the integrity of the internationally designated site Severn Estuary SPA/SAC/Ramsar. The major project of HS2 could interact with the DPD. It is explained in the document that only a very small section of the canal on the edge of the district in a rural area would be affected by the new high speed railway. At the time of writing, HS2 has been put on hold for 5 years such that its progress is uncertain at this stage. Mitigation measures are provided through the Local Plan and DPD Policies.

SA of Implementing the Warwick Canalside DPD

5.45 Overall, the Canalside DPD is likely to have positive effects for housing and communities. Strong policies are in place to protect and enhance environmental and historic resources and assets with at least effects mitigated to neutral with some enhancements indicating positive effects. For example, the requirements for biodiversity, green infrastructure and landscape/townscape will have positive effects that could be synergistic and cumulative in the longer term.

5.46 The DPD recognises likely future business needs, enabling regeneration and new residential development on underused industrial estates that will also facilitate improved accessibility. This is likely to have wider and synergistic effects on sustainable transport and health and well-being through increased safe use.

5.47 The DPD helps to resolve existing sustainability problems, for example, the poor access to the canal in certain urban areas and the concerns over crime and anti-social behaviour. Requirements in the DPD to improve access and the canal pathway, and for design/layout to provide surveillance will help reduce problems regarding safety and crime or fear of crime. These positive effects are likely to extend beyond the environs of the canals and development site areas. The approach of developing previously used land has major positive effects for the effective use of land.

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