Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on.

Sustainability Appraisal of the South Warwickshire Local Plan. The methodology used in the Sustainability Appraisal (SA) is not sufficiently clear for the reader to understand the process by which locations are assessed using the SA/SEA approach. There are several parts to the methodology: 1). Selection of 13 SA Objectives which are scored at each location; 2) Assessment of each SA Objective based on a SA Framework (SA vol. 3 Appendix A pages 538-541 pdf pp.580-583) which includes Decision-making criteria – a set of questions – and Indicators used to answer the questions for each SA Objective; 3) Scoring for each SA Objective (and sub-objectives) based on Explanations (assessment of Indicators) using a six category scoring system (SA vol.2 Table 2.1 page 410 pdf p.452) represented by Impact Symbols (--,-,+/-,0,+,++); 4) Evaluation of the performance of different options based on the scoring for SA Objectives, sometimes tabulated, averaged or shown graphically through the use of rose diagrams (e.g. Kenilworth SA vol. 2, 4.5 page 458, pdf p 500). It may be challenging to identify quantitative Indicators for all the SA Objectives but some Indicators are statements of intention or policy rather than factual information. For example, SA1 Climate Change is described through six Decision-making criteria that include the question: “Will the option ensure that sustainable construction principles are integrated into developments including energy efficient building design?” To which, one of the Indicators is listed as “Implementation of adaptive techniques in building design e.g. passive heating/cooling”. This criterion and indicator cannot be addressed in 2022-24 as they depend on future policy. Or, the Decision-making criterion question “Will the option help to reduce reliance on personal car use? Indicator - Encourage active travel to local services and amenities.” This is not an indicator that can be used to judge the performance of an objective for a location now as it represents a future intention or action. Some questions are unclear. For example, SA13 Economy, one of the Decision-making criterion questions is “Will the option provide or improve sustainable access to a range of employment opportunities?” It is not clear what this means: how could it be answered on the basis of locations for housing alone, and what is the appropriate Indicator? It is not clear how the Explanations are arrived at. We might expect to see these based on answers to the Decision-making criteria using the stated Indicators. For Kenilworth North, the Explanation for the scoring of SA1 Climate (SA vol 3. B.5.1 page 565 pdf p.607) only uses one of the stated Indicators (carbon emissions), as in “Large scale residential-led development is likely to result in an increase in GHG emissions. Development in this Broad Location could deliver up to 2,000 dwellings and therefore could increase carbon emissions in the District by more than 1% and result in a major negative impact.” Why are the other stated Indicators not included ? In any case this is contradictory given that one of the Indicators acknowledges future houses (up to 2050) are likely to be low energy/zero carbon. The apparent inconsistencies above potentially undermine the value of the SA methodology. It is not clear how the Impact Symbols are translated into SA Objective Performance scores on the rose diagrams. The rose diagrams are scored 0 to 5 which suggests they map on to the six impact symbols. But this is not the case. For example, SA1 Climate Change for Kenilworth North (SA vol 3. B.5.1 page 565 pdf p.607) is given an Impact Symbol of (--) (most adverse effect) but is mapped on to a score of 1 in the rose diagram – not 0 (zero) (SA vol. 2, 4.5 page 458, pdf p 500). It is not clear how the Impact Symbols are ‘averaged’ for an SA Objective on a rose diagram when there are sub-objectives with different Impact Symbols. For example, SA6 Pollution for Kenilworth North (SA vol 3. B.5.6 page 568 pdf p.610) has five sub-objectives all scored with the same Impact Symbol (-) yet the rose diagram score is 2.2. Or, SA3 Biodiversity (SA vol 3. B.5.3 page 566 pdf p.608) that has eight sub-objectives (+/-, 0, 0, -,--,-,0,-,) and also with an average score 2.2 (a simple mapping of 0 to 5 to these would give an average score of 14/8 = 1.75). Perhaps the different sub-objectives are weighted differently, though this is not clearly stated, or there is an error in the mapping. These concerns are far from trivial. The underlying methodology to the whole exercise is based on simple scores, many of which are contentious because they depend on intention or policy rather than factual information. As a result, the findings are very sensitive to particular scoring values and provide relatively weak discriminatory power (i.e. many of the rose diagrams look very similar). Yet the scores are used to rank locations (e.g. Best Performing Location) as evidence for the Issues and Options report. Minor errors in the scorings, rose diagrams and ‘averaging’ across objectives could result in quite different findings. Consideration should be given to investigating the use of a new tool which is being used to help local authorities with spatial carbon modelling. This has recently been used to assist Greater Cambridge and Central Lincolnshire to identify the lowest-carbon route for new developments. The link to the webpage is here: https://www.bioregional.com/projects-and-services/casestudies/helping-local-authorities-model-emissions-from-proposed-growth

Chapter 4 Meeting South Warwickshire’s Sustainable Development Needs Issue I1: Sustainability Appraisal (SA) 5. The HEDNA for Coventry and Warwickshire says it provides evidence about how many jobs should be created by 2050 and how many homes would be needed to house those workers (pg 25). The SA provides an evaluation of the different spatial options for growth, concluding that all options tested would increase the volume of housing. However, in terms of the level of growth the SA has only tested two options for housing numbers (page 128). Option I uses the HEDNA trend-based projections which point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. This results in a combined total of 1,679 per annum for South Warwickshire. Option II uses the Standard Method calculation and identifies a higher need of 5,554 dwellings annually across Coventry and Warwickshire, but only 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Resulting in a combined total of 1,239 per annum for South Warwickshire. 6. The HBF would suggest the Plan should be more ambitious with its housing numbers and the SA process should include options for a higher level of housing. As set out in the NPPF, the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Government’s standard methodology identifies the minimum annual LHN, which is only a minimum starting point. This is not a housing requirement figure. The Government’s objective of significantly boosting the supply of homes set out in the NPPF remains (para 60). 7. The HBF would also suggest that there is a need to consider the interaction between employment and housing. As the HEDNA itself acknowledges an increase in the number of jobs can it itself generate a requirement for additional housing. High/higher growth scenarios should be tested in the SA. 8. The HBF would request that the Council considers the annual LHN as only the minimum starting point and fully considers all of the issues that may result in a need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing. 9. It may be that a higher housing figure is needed for economic reasons and a higher housing number is also needed for housing delivery reasons. Both options could be tested in the SA separately and in combination. 10. The evidence provided in the supporting document called ‘High Level SA of Growth Options’ notes that the geographical distribution of development may impact on the Plan’s ability to deliver affordable housing where it is most needed. The HBF notes that the level of open-market housing provided may also impact on the amount of affordable housing that can be developed (see comments on Viability). Infrastructure Requirements 11. Development is only required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision. Any policy wording in the Plan about Section 106 agreements will need to ensure decision makers consider the need for infrastructure requirements at the time of making the decision. Planning obligations must be necessary to make the development acceptable in planning terms, directly related to the development; and fairly and reasonably related in scale and kind to the development (PPG, Reference ID: 23b-002-20190901).

Braemar is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 7. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper or technical note with assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. There are other settlements, such as Bishop’s Itchington, which should be included on the list. 8. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 9. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 10. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 3 11. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.

Issue 1 Sustainability Appraisal. Consideration should be given to investigating the use of a new tool which is being used to help local authorities with spatial carbon modelling. This has recently been used to assist Greater Cambridge and Central Lincolnshire to identify the lowest-carbon route for new developments.

Reasonable Alternatives: The reasonable alternatives do not consider developments less than 50 dwellings. This appears to be an arbitrary and an unreasonably high threshold. Similarly, the benefits of smaller scale development for employment, such as that proposed at Holly Farm Business Park are not given sufficiently serious consideration.

The Beaudesert and Henley-in-Arden JPC have informed us that the SWLP are considering 500-2000 houses in Henley-in-Arden. Why is this the case when the sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes? There is nothing in the sustainability appraisal which supports Henley being singled out for growth comparable to a broad location. On a map from a distance Henley looks to have good connectivity with access to bus stops and railway station but these services are poor with infrequent and unreliable train and bus service. Henley has been shown to actually have poor connectivity (5.13.4) thus car usage would increase on the already very congested road. Due to the local topography, railway, river, and listed buildings there is little opportunity to improve the road layout. SWLP has no apparent plans to improve infrastructure, leaving this on a local level or to the developers which is not adequate. Henley is the only small settlement shown to have more that 50% of land within flood zone 2. (5.4.2). Being in a valley, Henley already flash floods with the roads becoming impassable frequently in winter months. Risk of flooding will likely increase due to global warming with more extreme weather events. The heavy clay soil bakes hard in summer and completely saturates in winter with a high-water table, creating perfect conditions for increased surface run off year-round. Development would increase surface run off, particularly development of proposed site currently used for growing Christmas trees which of course creates natural flood defence. How would developers prevent increased flood risk? Existing drainage is not sufficient to accept further volumes, the river frequently bursts its banks already and use of soakaways is ineffective due to the nature of local heavy clay soil and high water table, retention ponds would fill in winter and then be ineffective. Increasing building in Henley will certainly contribute to adverse events. 2.9.7 Acknowleges water quality will be affected if infrastructure is not put in place and yet the SWLP has no plan to put infrastructure in place. This is at odds with your vision and objectives. 2.6.10 Protected species survey information has not been used and there is no plan to assess this in more detail until after the plan has been adopted. How then does the SWLP think it can decide where to build the most houses in the most sustainable way for biodiversity if it had no information of where endangered species are. 2.9.6 admits development near watercourses will potentially impact the banks and water quality with the suggestion in 2.9.7 that developers can voluntarily provide additional measures to protect water quality. Given developers focus on profit this is not good enough. The river Alne which runs through Henley has a population of endangered white-clawed crayfish. Sustainability appraisal has failed to recognise Henley has a local nature reserve 5.5.4 – Henley sidings nature reserve would likely be impacted by some of the proposed sites for development. Based on the evidence Henley is not suitable for growth over 500 houses. More information is needed about the local services and environment to establish appropriate lower numbers of proposed development. I am concerned that NOT reviewing the green belt hasn’t been considered as an option.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, and it is recognised that the SA is at an early stage however the SA only considers a limited number of settlements and excludes some settlements that should be considered as sustainable locations for growth, such as Welford-on-Avon. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives. Further comments are made below and in following sections regarding the SA with specific reference to Welford-on-Avon and the Site [Land North of Milcote Road].

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements and excludes some settlements that should be considered as sustainable locations for growth, such as Ettington. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives.

3.1. The Issues and Options document is supported by a Sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements and excludes some settlements that should be considered as sustainable locations for growth, such as Harbury. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives. Further comments are made below and in following sections regarding the SA with specific reference to Harbury and the Site.

The Sustainability Appraisal (SA) being used to support the emerging SWLP (2023) is not promoting the most sustainable patterns of new housing development to the most sustainable site locations within the South Warwickshire Region. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach on this issue fails the ‘Sustainability’ Local Plan test of ‘Soundness,’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021) as referred to below. On this basis, both the accompanying Sustainability Appraisal (SA) being used to support Local Plan-preparation, and the emerging SWLP (2023), are both in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should be aware of this NPPF guidance and its critical importance to Local Plan-making. The position is perfectly, this highly obstructive planning policy approach and ongoing failure and continued incompetence being taken towards Local Plan-preparation, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Local Plan Review (2023), alongside its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. It is important that these ongoing failings discussed above are now addressed within the emerging SWLP Review and its remaining Plan-preparation stages. We have fundamental planning policy concerns in relation to proposed new housing development and new employment land growth options and proposed site allocations being brought forward through the emerging SWLP Review given that these growth options are still continuing to force through an unreasonable, unsound and inflexible set of policies and an inflexible spatial planning policy framework approach by continuing to use the existing planning policy approach already set out and fixed within Stratford-on-Avon District Council’s existing adopted Development Plan – The Stratford-on-Avon District Core Strategy (2011 – 2031) (adopted July 2016). The year 2016 Core Strategy is now a long out-of-date Plan which is based on a heavily out-of-date pre-COVID-19 economic data, and an unsound set of supporting background technical evidence base documents, and unsound spatial planning policy modelling assumptions (based upon a heavily out-of-date economic landscape that existed over 8 years ago). These components are all no longer relevant and fit-for-purpose for future Plan making purposes – particularly given the shelf life timeframe of the SWLP, extending up until the year 2050! The Council’s preparing the emerging SWLP Review and its sister document - Stratford-on-Avon District Council’s emerging SAP (2023), are taking forward a highly inflexible and obstructive planning policy approach by refusing to accept proposed new housing site locations that are not already on the agreed list/ closed list of sites previously agreed by the year 2016 Core Strategy referred to above. Despite the fact that these proposed new housing site allocations, such as the Lockley Homes proposed housing allocation site, are in far more sustainable site locations in comparison to many of the housing site allocations being carried over from the year 2016 adopted Core Strategy. The position is perfectly clear, the Council’s are failing to promote the most sustainable patterns of new housing development, in direct conflict with a range of NPPF guidance already referred to within this wider Representations Statement. The emerging Sustainability Appraisal (SA) being used to support SWLP Plan-preparation has failed to take onboard these fundamental issues and therefore fails the tests of ‘Soundness’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). These issues are already considered within this wider SWLP Representations Statement (2023), as well as our extensive Representations already made to Stratford-on-Avon District Council’s emerging SAP, and the earlier SWLP ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation. We have concerns that the Council’s are still failing to grasp these important issues, which are fundamental to the Soundness and Legal compliance (NPPF – para 35) of the emerging SAP and SWLP Local Plan Reviews.

The Beaudesert and Henley-in-Arden JPC have informed us that the SWLP are considering 500-2000 houses in Henley-in-Arden. Why is this the case when the sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes? There is nothing in the sustainability appraisal which supports Henley being singled out for growth comparable to a broad location. On a map from a distance Henley looks to have good connectivity with access to bus stops and railway station but these services are poor with infrequent and unreliable train and bus service. Henley has been shown to actually have poor connectivity (5.13.4) thus car usage would increase on the already very congested road. Due to the local topography, railway, river, and listed buildings there is little opportunity to improve the road layout. SWLP has no apparent plans to improve infrastructure, leaving this on a local level or to the developers which is not adequate. Henley is the only small settlement shown to have more that 50% of land within flood zone 2. (5.4.2). Being in a valley, Henley already flash floods with the roads becoming impassable frequently in winter months. Risk of flooding will likely increase due to global warming with more extreme weather events. The heavy clay soil bakes hard in summer and completely saturates in winter with a high-water table, creating perfect conditions for increased surface run off year-round. Development would increase surface run off, particularly development of proposed site currently used for growing Christmas trees which of course creates natural flood defence. How would developers prevent increased flood risk? Existing drainage is not sufficient to accept further volumes, the river frequently bursts its banks already and use of soakaways is ineffective due to the nature of local heavy clay soil and high water table, retention ponds would fill in winter and then be ineffective. Increasing building in Henley will certainly contribute to adverse events. 2.9.7 Acknowleges water quality will be affected if infrastructure is not put in place and yet the SWLP has no plan to put infrastructure in place. This is at odds with your vision and objectives. 2.6.10 Protected species survey information has not been used and there is no plan to assess this in more detail until after the plan has been adopted. How then does the SWLP think it can decide where to build the most houses in the most sustainable way for biodiversity if it had no information of where endangered species are. 2.9.6 admits development near watercourses will potentially impact the banks and water quality with the suggestion in 2.9.7 that developers can voluntarily provide additional measures to protect water quality. Given developers focus on profit this is not good enough. The river Alne which runs through Henley has a population of endangered white-clawed crayfish. Sustainability appraisal has failed to recognise Henley has a local nature reserve 5.5.4 – Henley sidings nature reserve would likely be impacted by some of the proposed sites for development. Based on the evidence Henley is not suitable for growth over 500 houses. More information is needed about the local services and environment to establish appropriate lower numbers of proposed development. I am concerned that NOT reviewing the green belt hasn’t been considered as an option.

This section makes reference to Chapter 7 of the SA ‘Evaluation of the Spatial Growth Options’. It is understood that the Growth Options included as part of this consultation are an amalgamation of the Growth Options considered in the previous consultation. This representation in principle supports growth relating to: • Rail Corridors (previously Growth Option A); • Sustainable Travel (previously Growth Options A and B); • Economy (previously Growth Options D and E); and • Sustainable Travel and Economy (previously Growth Options A, B, D and E). Table 7.1 in the SA demonstrates that these growth options are the most sustainable options for the delivery of development when compared to the remaining Growth Option ‘Dispersed’. We agree with the conclusions of the SA and support the principle of delivering growth concentrated around these options, which in turn supports the delivery of Long Marston Airfield and indeed the densification of the allocation.

The Planning and Compulsory Purchase Act requires a sustainability appraisal to be carried out on development plan documents in the UK. Additionally, the Environmental Assessment of Plans and Programmes Regulations15 (SEA Regulations) require an SEA to be prepared for a wide range of plans and programmes, including local plans, to ensure that environmental issues are fully integrated and addressed during decision-making. 5.2 It should also be noted that SA is an iterative process and, as such, should be undertaken alongside development of the SWLP as it moves forward through the various stages in order to maximise its sustainability credentials. This includes taking into account responses made by stakeholders to the SA and SWLP consultations as part of the plan-making process, including those submitted by local and national house builders. In this context, the IO document explains (page 26) that the SA process will take on board any comments on the SA and use them to furnish the next report with greater detail and accuracy. 5.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) and provide a response to the question below.

NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ It is noted that in the conclusion for the Sustainability Appraisal it states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ [emphasis added] Furthermore, the following technical assessments are currently being undertaken to help inform later stages of the plan: • Transport Assessment • Climate Change Impact Assessment • Biodiversity and Green Infrastructure Assessment • Landscape Character Assessment • Health Impact Assessment • Green Belt Study • Heritage Assessment The Issues and Options SA is, by its own admission, heavily caveated and no mitigation has been considered. We therefore reserve the right to comment further at a later stage, once the Sustainability Assessment has advanced following the outcome of key evidence base documents.

k. It is therefore unclear how the SA Framework has been devised or how it has been applied in appraising each option, given there is scant reference to it in the evaluation of options or the detailed commentary in the supporting appendices. This lack of clarity and consistency in how the SA Framework has been applied undermines the transparency in the SA process, which is critical to ensure the appraisal is both robust and credible. However, whilst some initial mitigations have been suggested for some categories of options, none have been identified for the generic policy options (see IO SA Appendix E) nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potential mitigation hasn’t been identified for these options. This again points to a lack of clarity and consistency in how the options have been appraised which further undermines the transparency in the process. Consequently, the potential contributions of 5000 or 10,000 dwellings to address unmet need as outlined in the IO document, and the spatial options to accommodate this need, represent reasonable alternatives that should be considered through the SA process for the SWLP. This should be undertaken and presented in the next iteration of SA, and a suitable policy response should also be presented in the draft (preferred options) version of the SWLP. It is therefore important that the findings from the SA are considered in the round alongside other relevant evidence regarding the suitability of specific locations and settlements in supporting the delivery of the spatial development strategy.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, however it is recognised that at this stage the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

Issue I1: Sustainability Appraisal Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. To support the Issue and Options consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA: source: Table 2.1, Sustainability Appraisal, November 2022 The site assessments undertaken within Appendix D of the SA assess a general area rather than specific parcels which have been promoted. It is acknowledged that these areas will evolve into more defined spatial areas through the plan making process which will allow for more detailed assessments of the sites to take place. Lone Star Land Ltd support the SA Framework which has evolved from the thirteen SA objectives and its associated decision-making criteria. It is considered that the objectives address all relevant subject areas which need to be covered within the South Warwickshire Local Plan. It is considered that the overall scoring and assessment within the SA should provide further clarity and consistency in respect of the overall assessment and proposed mitigation matters to address these issues. For example, New Settlement site F2 has scored the lowest (Major Adverse Impact) for landscape sensitivity, but has not for landscape character, moreover the site is not under any landscape designations. The SA acknowledges that the impact of a new settlement in this area could be mitigated through design and masterplanning intentions for the New Settlement Locations. This could be considered through the assumption that a principle for 40% of greenspace provision within these locations will be followed and therefore could be mitigated. Furthermore, the SA considers that this level of greenspace provision should help to provide good scope for design solutions that deliver design led mitigation that can avoid and reduce impacts on changing character and views. Therefore, it is unclear why future mitigation measures and provisions to address these potential issues have not been taken into consideration within its wider assessment. Table 2.15 of the SA provides a summary of the mitigation hierarchy used which provides limited consideration and acknowledgement of potential mitigation methods through either design or through infrastructure provision need to be addressed. Within Chapter 6 (The 7 New Settlement Locations) of the SA it is noted within Figure 6.1 theProposed New Settlement Site F2 is labelled as Deppers Hill. However, within the Issues and Options Document the site is labelled as Deppers Bridge. Therefore, it is advised that the labelling of Proposed New Settlement Site F2 is amended to Deppers Bridge for consistency with the Issues and Options document and supporting evidence going forward in the evolving plan making process.

EVIDENCE BASE 5.1 The Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘SA’) (2022) comprises a core component of the evidence-base underpinning the emerging Local Plan. 5.2 Together, the Councils’ have identified five reasonable alternative spatial strategy options to be considered within the SA concerning where housing and employment development should be distributed at a strategic scale across the Plan area. These five options comprise: a) Seven alternative options for New Settlement locations for large scale development of not less than 6,000 new homes and associated infrastructure, b) 32 Broad Locations which represent options for up to 2,000 homes located around the Main Settlements such as Warwick, Stratford-upon-Avon and Southam for medium scale, chiefly residential, development and associated infrastructure, and c) 22 Small Settlement Locations for intermediate scale, chiefly residential, development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. 5.3 As noted within the SA, the high-level assessment of the various spatial growth options, which are not distinct from each other (with the exception of Option 5), means that their performance can only be evaluated with several caveats. Such caveats include the fact that detailed locational information is not available, meaning the ability to identify potential effects with precision is challenging. As such, the assessment within the SA cannot represent a diagnostic analysis. 5.4 Furthermore, the SA has not factored any mitigation into the analysis of the growth options, as this is best worked up once more detailed locational information is available. 5.5 The SA evaluates the five spatial options against the SA criteria at a high level, at Table 2.1. The SA concludes that Spatial Option 5 performs worst, with the remaining options being relatively indistinct. However, Kingacre disagrees with this conclusion and the discussion below sets out the areas of dispute and the reasons for the disagreement: SA1: Climate Change Commentary Agreed. SA2: Flood Risk Commentary Agreed. Flood Risk effects are challenging to evaluate given the lack of locational information. SA3: Biodiversity Commentary Greenfield land does not necessarily equate with high-quality habitats. Development in dispersed locations provides an opportunity to deliver Biodiversity Net Gain and associated improvements across South Warwickshire’s ecological network. Given the requirement to deliver a minimum of 10% Biodiversity Net Gain on all new developments, it is considered that there would be a minor positive effect. SA4: Landscape Commentary Agreed. SA5: Cultural Heritage Commentary Agreed SA6: Environmental Pollution Commentary Agreed SA7: Natural Resources Commentary Agreed SA8: Waste Commentary As noted within the SA assessment (paragraph 7.9.1), all options perform similarly as they purport to deliver the same quantity of housing. SA9: Housing Commentary Agreed SA10: Health Commentary Agreed SA11: Accessibility Commentary Agreed SA12: Education Commentary As noted within the SA (paragraph 7.13.1), The extent to which all spatial options would facilitate good education for new residents is almost entirely dependent on the specific location of development, which is uncertain at this stage. It is therefore not considered to be possible to draw conclusions on the effect of this SA Objective at this stage. SA13: Economy Commentary As noted in the SA (paragraph 5.15.1), SA Objective 13 looks at opportunities for new residents to access local employment opportunities by sustainable or active modes of transport or being situated within proximity to existing employment. The assessment of all potential development locations, including those of the small settlements (at Table 5.1), provided a net positive result within the SA, given the proximity of the locations within the target distance of several employment opportunities. It is therefore not clear how the assessment of the overall spatial strategy option could reasonably be considered to provide a negative effect. Noting the comments set out in Table 1 (above), regarding the revised appraisal of Spatial Option 5 in relation to the SA Objectives, the Council is encouraged to challenge and reassess the current appraisal set out within the SA. In doing so, the Council is invited to take account of these comments when developing the next iteration of the SA and when directing and testing the next iteration of the SWLP.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, nvironmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, however it is recognised that at this stage the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported however it is recognised that at this stage, the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

The Issues and Options document is supported by a Sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA: The principle and broad approach of the SA is supported, and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements and excludes some settlements altogether that should be considered as sustainable locations for growth, such as Bishops Itchington and Harbury. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives. Further comments are made below and in following sections regarding the SA with specific reference to Bishops Itchington/Harbury and the Site.

Reasonable Alternatives: The reasonable alternatives do not consider developments less than 50 dwellings. This appears to be an arbitrary and an unreasonably high threshold.

The Beaudesert and Henley-in-Arden JPC have informed us that the SWLP are considering 500-2000 houses in Henley-in-Arden. Why is this the case when the sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes? There is nothing in the sustainability appraisal which supports Henley being singled out for growth comparable to a broad location. On a map from a distance Henley looks to have good connectivity with access to bus stops and railway station but these services are poor with infrequent and unreliable train and bus service. Henley has been shown to actually have poor connectivity (5.13.4) thus car usage would increase on the already very congested road. Due to the local topography, railway, river, and listed buildings there is little opportunity to improve the road layout. SWLP has no apparent plans to improve infrastructure, leaving this on a local level or to the developers which is not adequate. Henley is the only small settlement shown to have more that 50% of land within flood zone 2. (5.4.2). Being in a valley, Henley already flash floods with the roads becoming impassable frequently in winter months. Risk of flooding will likely increase due to global warming with more extreme weather events. The heavy clay soil bakes hard in summer and completely saturates in winter with a high-water table, creating perfect conditions for increased surface run off year-round. Development would increase surface run off, particularly development of proposed site currently used for growing Christmas trees which of course creates natural flood defence. How would developers prevent increased flood risk? Existing drainage is not sufficient to accept further volumes, the river frequently bursts its banks already and use of soakaways is ineffective due to the nature of local heavy clay soil and high water table, retention ponds would fill in winter and then be ineffective. Increasing building in Henley will certainly contribute to adverse events. 2.9.7 Acknowleges water quality will be affected if infrastructure is not put in place and yet the SWLP has no plan to put infrastructure in place. This is at odds with your vision and objectives. 2.6.10 Protected species survey information has not been used and there is no plan to assess this in more detail until after the plan has been adopted. How then does the SWLP think it can decide where to build the most houses in the most sustainable way for biodiversity if it had no information of where endangered species are. 2.9.6 admits development near watercourses will potentially impact the banks and water quality with the suggestion in 2.9.7 that developers can voluntarily provide additional measures to protect water quality. Given developers focus on profit this is not good enough. The river Alne which runs through Henley has a population of endangered white-clawed crayfish. Sustainability appraisal has failed to recognise Henley has a local nature reserve 5.5.4 – Henley sidings nature reserve would likely be impacted by some of the proposed sites for development. Based on the evidence Henley is not suitable for growth over 500 houses. More information is needed about the local services and environment to establish appropriate lower numbers of proposed development. I am concerned that NOT reviewing the green belt hasn’t been considered as an option.

Reasonable Alternatives: The reasonable alternatives do not consider developments less than 50 dwellings. This appears to be an arbitrary and an unreasonably high threshold.

Response to SWLP Sustainability Appraisal Issues and Options Herewith comments on the above document. * The development assumption of 500 houses if fully implemented would double the number of existing dwellings. This would overwhelm and destroy the character of the ancient village with its eclectic housing including important Shakespearian connections and Wilmcote would become Stratford on Avon “ Urban Sprawl” * The village is “washed over” by the Green Belt with all the development protection that currently gives.It is hoped and expected that this will still carry significant weight when any new development is considered * A recent rigorous process involving many villagers helped to produce The Wilmcote Neighborhood Plan which was adopted in 2018.This concluded there was potential for 75 new houses. We would hope and expect that this plan would continue to carry weight in the new SWLP. * Should there there be any further housing proposed it is expected that a significant proportion would be secured for affordable homes by way of a S106 Agreement or its successor. It should be noted that development costs on agricultural land are usually considerably lower than on brownfield sites therefore provision of affordable housing is more realistic to impose on the developer. * At this stage the SA is only a desktop study which makes broad assumptions which are probably unachievable not the least being the necessary associated infrastructure particularly the provision of education and medical facilities public transport and adequate road safety measures.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported however it is recognised that at this stage, the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

The Sustainability Appraisal has been very broadly applied and as such does not accurately reflect the sustainability of individual sites. It, therefore, does not accurately interpret the deliverability of the sustainable transport Growth Options and the proposed development strategy of the SWLP. A detailed response to the Suitability Appraisal is attached at Appendix 1.

RESPONSE TO SUSTAINABILITY APPRAISAL (NOVEMBER 2022) Barratt David Wilson Homes (Mercia) (“BDW”) have the following comments to make in respect of the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options Consultation draft document. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions The SA testing of Growth Options against the 13 criteria identified in paragraph 2.21 of the report is appropriate. These criteria reflect the objectives of the SWLP and the topics identified in Annex 1(f) of the SEA directives. The outcomes of the assessment process, however, needs to be treated with caution. The SA is a snapshot in time. It assesses the sustainability of the Growth Options and potential locations for allocations on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the Draft Plan policies, growth options and potential locations for development against Matter 11 – Education, regard has been had to existing education provision in the locality. It does not, however, consider how new development could improve local education facilities, through the provision of a new education infrastructure, such as new schools or the contributions that can be made to improve existing facilities. It is appreciated that this is a difficult process, until the current Call for Sites consultation is completed and responses reviewed, the local authorities will not have a clear understanding of what services and facilities are being promoted with the various development opportunities being presented. However, in due course this should be a key consideration for the local authorities in determining the preferred strategy, growth options and allocations within the SWLP. Climate Change While the assessment of the proposals against climate change objectives is required, there are concerns with the way in which this has been applied It is advised at paragraph 2.4.6 of the SA that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses), are likely to increase greenhouse gas emissions in the plan area by more than 1% and adversely affect climate change in the future. Developments of between 50 to 500 dwellings could increase carbon emissions in the plan area by more than 0.1% and have a lesser effect on climate change. As a consequence, it is effectively concludes that larger schemes are likely to result in a greater amount of greenhouse gas emissions than smaller development proposals. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have a set housing requirement. That housing requirement will be delivered through various residential developments of different sizes. The greenhouse gas emissions from the construction operation of these properties will have a total accumulative effect based on the total number of houses built. This significance will be broadly the same, regardless of whether the houses are delivered through a larger number of small sites or a smaller number of large sites. The SWLP should consider the most appropriate way of delivering the houses in order to try to reduce greenhouse gas emissions because although larger developments may have relatively bigger higher emissions of greenhouse gases the amount emitted to deliver all the housing need will remain unchanged. It is also suggested that development of greenfield sites for housing has a potential to lead to local, long term significant adverse effects in the form of increasing flooding, drought and storm events. This is not necessarily the case. Indeed, it is not uncommon for new development to introduce flood risk and drainage control measures that improve the flood risk and drainage situations locally. New developments must achieve greenfield run off rates and can often be used to address localised problems associated with flood risk. It is inappropriate for it to be immediately assumed that the development of greenfield sites can have adverse effects on flooding, drought and storm events. Biodiversity and Geodiversity The impact of development on biodiversity and geodiversity is a clear consideration in the SA process. However, the SA advises that no detailed ecological surveys have been in the SA. However, the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in this report (paragraph 2.6.14) and detailed ecology surveys and assessments will determine, on a site by site basis, the presence of priority species and priority habitats (paragraph 2.6.12). The SA has, therefore, made assumptions about the sensitivity or otherwise of potential development options from an ecological basis linked to their proximity to identified assets. That being the case, the conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information available from the Call for Site submissions this should be actively considered in the site selection process. Landscape The SA advises at paragraph 2.7.2 that detailed designs for each development appraisal are uncertain at this stage of the assessment. The landscape assessment is a desk based exercise which has not been verified in the field. Therefore, the nature of potential impacts on the landscape is uncertain. Furthermore, it is recognised and recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. Consequently, the landscape appraisal selection of the SA should be treated with caution as the evidence base is not complete. Cultural Heritage It is advised at paragraph 2.8.3 of the SA that impacts on heritage assets will largely be determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. At this stage, the risk of substantial harm to the significance of the heritage asset has been assessed based on the nature and significance of, and proximity of sites to, the heritage asset in question. It is also advised that whilst the Heritage and Settlement Sensitivity Assessment is being prepared, this assessment was not available for use at the time of undertaking the SA process. The conclusions of the SA must, therefore, be treated with caution. Where site specific heritage information has been provided with our Call for Sites submission, this should be considered in the site selection process. Environmental Pollution There is concern about some of the assessment criteria used within the environmental pollution section. Development proposals that are within 200 metres of a railway station are negatively scored. Development proposals located over 200 metres from a railway station have a neutral score. In addition, it is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability impacts due to road related air and noise emissions. These conclusions do not automatically follow as it is possible for sites within the metres of railway lines and main roads to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources We are concerned with the SA approach towards assessing the agricultural land implications of development. Development proposals that include over 20 hectares of Grade 1, 2 or 3 agricultural land score a double negative while development proposals that include an area of land of less than 20 hectares of Grade 1, 2 or 3 agricultural land have a single negative impact. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have to allocate land to deliver a set amount of housing. This will be from a combination of brownfield and greenfield sites. The amount of agricultural land developed in the plan area as a whole is likely to be fixed, as the housing requirement will be fixed. Health Impact Development options are scored down if they are more than 800 metres from an area of green space, or 600 metres away from a public right of way or cycle path. Development proposals will, in all likelihood, provide onsite green space to meet their needs, and may be able to provide connections to nearby footpaths/cycle paths. Accessibility The SA accessibility assessment criteria for proximity to bus stops and food stores advises that sites that are more than 400 metres from a bus stop and sites that are 800 metres from the food store will receive a negative rating. Whilst this is a sensible starting point, large scale developments will, in all likelihood, provide new bus stops and convenience stores. Indeed, we would fully expect the local authority to require these larger schemes to include a local centre. As a consequence, the assessment criteria must be treated with caution as part of the site selection process. Similarly, development options that are located over 800 metres from a primary school have a negative rating. Large scale sites are likely to provide primary schools. Indeed, we would expect primary school provision to be a key component of any scheme providing 800+ dwellings. Economy The SA assessment criteria for economic opportunities penalises schemes that are more than 5km from a “key employment location” whilst positively scores sites that are within 5km of a key employment location. Large scale residential sites are, in all likelihood, likely to provide employment opportunities as part of the overall proposals. It is, therefore, inappropriate to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision. Initial Identification of Settlements The 30 settlements identified in paragraph 3.5.2 of the report are a combination of the main settlements, that expect to be able to deliver up to 2,000 homes, as well as smaller locations that might be able to deliver between 50 and 500 homes. It is incorrect to exclude Bishop’s Itchington from the list of settlements that were evaluated. Bishop’s Itchington is a sustainable settlement. It has a school, various services and facilities and employment opportunities. It has been identified as a suitable location for the allocation of Reserve Housing Sites through the Site Allocations Plan process. Additional development needs to be directed towards Bishop’s Itchington to support its continued development. It isa significant omission of the plan not to identify Bishop’s Itchington as a broad location or main settlement. This matter should be re-considered.

The Sustainability Appraisal has been very broadly applied and as such does not accurately reflect the sustainability of land around the settlements. At Bearley, for example, the appraisal does not accurately assess the land in the vicinity of the station (Site 243) or the deliverability of the sustainable transport Growth Options at the site. Attached to these representations at Appendix 1 is a response to the Sustainability Appraisal for the land at Bearley Station which shows why site specific appraisals should be undertaken. If this is not done then sites which are entirely appropriate as allocations may be excluded from consideration.