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.

Appendix 1: Sustainability Appraisal The Council has produced a Sustainability Appraisal (SA) to accompany the Issues and Options consultation. DWH have submitted separate comments on this which are attached to their response to the Issues and Options document. The SA assesses the suitability of a number of different locations that have been identified as having the potential to accommodate new development going forward. Bearley is one such location that has been assessed as part of this process. Since the SA assesses the wider area around Bearley, we have reviewed the assessment of the proposed site against the SA objectives and consider that the site is not encumbered by some of the constraints identified in the SA while development at the site offers the potential to address a number of the negatives that have been identified and turn these into positives or benefits that the site can deliver. Set out below is an extract from the summary table with the SA for Bearley village and an assessment for the site together with an accompanying commentary. SA.1 Climate Change Bearley Village '-' Site (Our Assessment) '+' See Note 1 SA.2 Flood Risk Bearley Village '+' Site (Our Assessment) '++' See Note 2 SA.3 Biodiversity Bearley Village '--' Site (Our Assessment) '+ See Note 3 SA.4 Landscape Bearley Village '--' Site (Our Assessment) '-' See Note 4 SA.5 Cultural Heritage Bearley Village '-' Site (Our Assessment) '0' See Note 5 SA.6 Environmental Bearley Village '-' Site (Our Assessment) '0' See Note SA.7 Natural Resources Bearley Village '--' Site (Our Assessment) '--' See Note 7 SA.8 Waste Bearley Village '-' Site (Our Assessment) '-' See Note 8 SA.9 Housing Bearley Village '++' Site (Our Assessment) '++' See Note 9 SA.10 Health Bearley Village '-' Site (Our Assessment) '+' See Note 10 SA.11 Accessibility Bearley Village '-' Site (Our Assessment) '++' See Note 11 SA.12 Education Bearley Village '-' Site (Our Assessment) '+' See Note 12 SA.13 Economy Bearley Villa '+' Site (Our Assessment) '+' See Note 13 Notes 1. The site is located on rail and bus corridors offering the opportunity to integrate public transport within the development and encourage a modal shift on to more sustainable forms of transport. Dwellings will be constructed to ensure compliance with latest environmental standards and building regulations to minimise energy use. 2. The development will incorporate SUDS that will improve surface water flooding over the existing conditions. SUDS will be incorporated as part of the overall blue/green infrastructure to be provided on site performing not only a drainage benefit but also contributing to sense of openness, amenity and ecology/biodiversity net gain. 3. The site does not directly affect areas of ecological importance whilst offering significant opportunities to deliver biodiversity net gain on site 4. The site lies outside areas of high landscape value 5. The site has no heritage assets on it nor is it located within the setting of listed buildings or other local heritage assets 6. The site offers the opportunity to manage traffic pollution and air quality by reducing traffic speeds and minimising noise pollution from the railway line by careful design 7. The site includes an area of over 20ha of Grade 3 ALC land 8. The development will look at opportunities to manage and minimise waste through the construction process. Opportunities to recycle will be provided for new residents as part of the waste collection services to be offered. 9. The site will deliver a significant quantum of new housing to meet the needs of the District 10. The site offers opportunities for Active Travel as well as increasing accessibility to the countryside and informal recreation opportunities. 11. The development will be constructed to ensure it is accessible to all, with new pedestrian and cycle links created to offer opportunities to travel by non-car modes 12. A new primary school is to be provided on site that will help meet the needs of new residents and also provide choice to existing residents of Bearley 13. The development will generate a number of economic benefits during its construction as well as providing new local shops and services Our assessment highlights that the site at Bearley already has the potential to deliver a number of benefits when assessed against the SA objectives. We will of course look at how we can develop these themes further as we work up the proposals for the site and the accompanying masterplan. RESPONSE TO SUSTAINABILITY APPRAISAL (NOVEMBER 2022) Barratt David Wilson Homes (Mercia) (“BDW”) have a series of comments on the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options consultation draft document. These are set out below on a topic basis in the same order that matters are raised in the SA. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions The SA testing of the 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 allocation on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the 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 a new school that would be of benefit to the local area generally. Sustainability appraisals are an iterative 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 in the SA. Paragraph 2.4.6 of the SA states that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses) are likely to increase greenhouse gas emissions by more than 1% and adversely affect climate change. Developments of between 50 to 500 dwellings could increase greenhouse gas omissions by more than 0.1% and have a lesser effect on climate change than the larger sites. 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. The greenhouse gas emissions from the construction of these properties will have a total accumulative impact based on the total number of houses built. The total amount of greenhouse gas omitted as part of the construction of these houses will be broadly the same, regardless of whether the houses are provided on a larger number of small sites or a smaller number of large sites. Larger scale developments are unlikely to have a greater impact on greenhouse gas emissions than smaller schemes. Large scale developments are more likely to provide onsite infrastructure, such as schools, places to work, local services and facilities than small scale developments. In terms of the Rail Corridor Growth Option, development near existing stations will help facilitate sustainable commuting patterns. Smaller schemes of 50 to 500 dwellings are less likely to provide onsite infrastructure or have the benefit of close proximity to a train station. It is, therefore, inappropriate for the climate change appraisal to penalise larger sites in comparison to smaller sites due purely to their size. 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. 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 completed at this stage to inform the assessments in the 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. The SA’s conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information is 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. Indeed, the SA recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. The landscape appraisal selection of the SA must be treated with caution as the evidence base is not complete. Paragraph 2.7.6 states that large scale residential-led development is likely to adversely impact the countryside and urban area where the various reasonable alternative development locations are located. This is a broad brush conclusion. Whilst development may impact on the landscape, impacts are not automatically negative or unacceptable. Indeed, well designed and high quality landscaping could potentially enhance the landscape character of a development area. Cultural Heritage Paragraph 2.8.3 of the SA confirms that the 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 on cultural heritage impact must be treated with caution. Where site specific heritage information has been provided with Call for Sites submissions 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. Given the need for increased use of sustainable travel it is ironic that development proposals which would help to reduce the use of railway transport by being located further away have a positive score. The SWLP correctly recognises that there are significant benefits in a Rail Corridor Growth Option and that providing access to a train station reduces the need for people to travel using the private car. The approach of the SA in this regard directly conflicts with the Rail Corridor Growth Option. It is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability credentials due to road related air and noise emissions. This conclusion does not automatically follow as it is possible for sites within 200 metres of a main road to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources The SA has a flawed 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. However, the approach of the SA means that it favours the allocation of a large number of smaller sites (less than 20 hectares) rather than a small number of large sites (more than 20 hectares) whilst the total amount of agricultural land developed is likely to be the same. 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, especially larger one with more space, 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 gives a negative sustainability rating to potential development locations that are more than 400 metres from a bus stop and more than 800 metres from a food store. 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 larger schemes to include a local centre. 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. 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 likely to provide employment opportunities as part of the overall proposals. It is inappropriate for the SA to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision.

The Sustainability Appraisal has been very broadly applied and as such does not accurately reflect the sustainability of land around the settlements. At Wilmcote, for example, the appraisal does not accurately assess the land in the vicinity of the station (Site 244) 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.

RESPONSE TO SUSTAINABILITY APPRAISAL (NOVEMBER 2022) Barratt David Wilson Homes (Mercia) (“BDW”) have a series of comments on the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options consultation draft document. These are set out below on a topic basis in the same order that matters are raised in the SA. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions The SA testing of the 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 allocation on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the 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 a new school that would be of benefit to the local area generally. Sustainability appraisals are an iterative 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 in the SA. Paragraph 2.4.6 of the SA states that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses) are likely to increase greenhouse gas emissions by more than 1% and adversely affect climate change. Developments of between 50 to 500 dwellings could increase greenhouse gas omissions by more than 0.1% and have a lesser effect on climate change than the larger sites. 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. The greenhouse gas emissions from the construction of these properties will have a total accumulative impact based on the total number of houses built. The total amount of greenhouse gas omitted as part of the construction of these houses will be broadly the same, regardless of whether the houses are provided on a larger number of small sites or a smaller number of large sites. Larger scale developments are unlikely to have a greater impact on greenhouse gas emissions than smaller schemes. Large scale developments are more likely to provide onsite infrastructure, such as schools, places to work, local services and facilities than small scale developments. In terms of the Rail Corridor Growth Option, development near existing stations will help facilitate sustainable commuting patterns. Smaller schemes of 50 to 500 dwellings are less likely to provide onsite infrastructure or have the benefit of close proximity to a train station. It is, therefore, inappropriate for the climate change appraisal to penalise larger sites in comparison to smaller sites due purely to their size. 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. 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 completed at this stage to inform the assessments in the 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. The SA’s conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information is 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. Indeed, the SA recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. The landscape appraisal selection of the SA must be treated with caution as the evidence base is not complete. Paragraph 2.7.6 states that large scale residential-led development is likely to adversely impact the countryside and urban area where the various reasonable alternative development locations are located. This is a broad brush conclusion. Whilst development may impact on the landscape, impacts are not automatically negative or unacceptable. Indeed, well designed and high quality landscaping could potentially enhance the landscape character of a development area. Cultural Heritage Paragraph 2.8.3 of the SA confirms that the 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 on cultural heritage impact must be treated with caution. Where site specific heritage information has been provided with Call for Sites submissions 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. Given the need for increased use of sustainable travel it is ironic that development proposals which would help to reduce the use of railway transport by being located further away have a positive score. The SWLP correctly recognises that there are significant benefits in a Rail Corridor Growth Option and that providing access to a train station reduces the need for people to travel using the private car. The approach of the SA in this regard directly conflicts with the Rail Corridor Growth Option. It is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability credentials due to road related air and noise emissions. This conclusion does not automatically follow as it is possible for sites within 200 metres of a main road to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources The SA has a flawed 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. However, the approach of the SA means that it favours the allocation of a large number of smaller sites (less than 20 hectares) rather than a small number of large sites (more than 20 hectares) whilst the total amount of agricultural land developed is likely to be the same. 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, especially larger one with more space, 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 gives a negative sustainability rating to potential development locations that are more than 400 metres from a bus stop and more than 800 metres from a food store. 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 larger schemes to include a local centre. 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. 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 likely to provide employment opportunities as part of the overall proposals. It is inappropriate for the SA to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision.

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 (page 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 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. Resulting in a combined total of 1,679 per annum. Option II uses the Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 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. 3.2 The South Warwickshire Local Plan should be more ambitious with its housing numbers and the SA process should include an option of a higher level of housing. As described elsewhere within this Representation, housing growth should be significant elevated if both Councils are to even come close to meeting the level of affordable housing need identified within the HEDNA. This also does not include the provision of housing to meet unmet need arising from within neighbouring authorities. 3.3 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). 3.4 Further comments in respect of the Sustainability Appraisal are including within the Sustainability Appraisal Review, included at Appendix 3 to this Representation.

The scores used in the sustainability appraisal are of little meaning as many of them depend on intention or policy rather than factual information. This means scores used to rank the ‘Best Performing Locations’ are unreliable.

The Parish Council consider flood plains need to be respected. The Plan should have a clear policy to resist development on land that has a record of flooding. Building on flood plains should be avoided, but if developments are allowed, the developer should be liable for future problems.

St. Modwen acknowledge and support the Sustainability Appraisal of the identified Broad Locations. We acknowledge that Southam is included in the 9 Broad Location settlement and that these have been identified to be capable of delivering up to 2,000 homes and significant areas of greenspace to facilitate effective green infrastructure planning. We support Southam as a highly sustainable location for future housing growth. 5.5.2 Overall Southam scores very well in the Sustainability Appraisal as a preferred town or location for growth and when compared to the 9 Key Towns should be seen as a preferential location for significant new housing. When considering the Broad Locations we believe that in line with St. Modwen’s Vision Document (appended) that the South East direction of growth for Southam should be considered the preferred location for new housing in Southam. 5.5.3 It is also important to ensure that appraisal relating to accessibility in the sustainability appraisal take account of new facilities such as the proposed new Aldi food store when assessing proximity to services. The new store sits adjacent to the Southeast Broad Location of development assessed by the SA. Committed development should be factored into the evidence base to ensure a fair assessment is undertaken. St. Modwen raises inaccuracies in the conclusions of the Sustainability Appraisal for Southam which appear to conclude (ref page 79 section 4.13) that Southam SouthWest is the most sustainable location for growth. 5.5.5 The following key factors appear to have been assessed and a recording error made. Para 4.11.9 (see below) clearly states that SW are within high/medium and high sensitivity land parcels that will be challenging to mitigate. We agree with this assessment but the conclusion in 4.13 records in error that the SW performs best in this category. The correct 4.13 annotation should have read “BEST PERFORMING BL: SOUTHAM SOUTHEAST”. If the above landscape scoring is corrected on the page 79 summary (table 4.13.1) and a sensible approach taken to onsite infrastructure set out in our vision document including enhanced public transport facilitating the 20 minute Neighbourhood principles, local facilities enhancement, employment land and the provision of a new primary school, the findings of any balance appraisal would clearly support development on land to the South East of Southam as the preferred Broad Location. 5.5.7 St. Modwen would also highlight within the SA report (Figure 4.3) shows that of all Southam options ‘Southam Southeast’ is the least impacted location across the SWLP area relating to the impact on priority habitats. 5.5.8 St. Modwen would also flag the Agricultural Land Classification data collected for Broad Location which shows Southam Southeast has no Grade 2 land and that Southam generally is Grade 3 land when compared to other Broad Locations. The above extract taken from the Table 4.1 of the Sustainability Appraisal shows that of all Southam option ‘Southam Southeast” scores the best from a Sustainability perspective. St. Modwen fully agree with this finding.

Both Councils have declared a climate emergency. If this is to be more than just a ‘political slogan’ it must be the Golden Thread that runs through all the policies in the local plan. At present The Vision has five elements of which ‘A climate resilient and Net Zero Carbon South Warwickshire’ is just one. The other four elements are laudable but must be subordinate to that one key aim of Net Zero Carbon South Warwickshire. Unfortunately the ‘climate emergency’ is glossed over in many places in the document. Set out below are a few examples of a total lack of ambition: P21 the fourth element of the vision statement “A well connected South Warwickshire..” that “promotes active travel”. In view of the climate emergency should this not read, “gives absolute priority to active travel”. P29 Improving connectivity why does this not express an absolute priority for active travel? P67 “Many businesses are reliant on the strategic road network for transporting products, and realistically this is unlikely to change significantly in the near future.” This certainly won’t change unless there are ambitious policies in place now to ensure change happens and as rapidly as possible. P153 penultimate paragraph “If there is a gradual move away from residents relying on the use of a private car….” This must not be a question of “if” but how fast can change occur. The above are just four of countless examples in the document where the wording does not reflect the ‘climate emergency’. It is essential that not only the policies drive this key objective but the wording of the whole document reflects the absolute priority of the need to respond to the climate change emergency.

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.

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 (page 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 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. Resulting in a combined total of 1,679 per annum. Option II uses the Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 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. 3.2 The South Warwickshire Local Plan should be more ambitious with its housing numbers and the SA process should include an option of a higher level of housing. As described elsewhere within this Representation, housing growth should be significant elevated if both Councils are to even come close to meeting the level of affordable housing need identified within the HEDNA. This also does not include the provision of housing to meet unmet need arising from within neighbouring authorities. 3.3 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). 3.4 Further comments in respect of the Sustainability Appraisal are included within the Sustainability Appraisal Compliance Review, included at Appendix 4 to this Representation.

Whilst it is noted that the SA generally states that large scale residential development will likely result in increased GHG emissions, it does not appear to recognise that mixed-use schemes will have lower GHG emissions. The proposed allocation site at Copham’s Hill (site ref. ID 385) provides an opportunity for a mixed-use scheme that would be in accordance with the TCPA 20-Minute Neighbourhoods report, including: • Diverse mix of homes, including affordable • Network of pedestrian and cycle routes • Local shops • Local employment • Green infrastructure, including accessible open space • Community centre Therefore, the SA should give more consideration to the potential for the development of mixed-use sites, particularly with reference to larger sites such as that at Copham’s Hill (see Appendix D) as per Appendix B B.27 Stratford-upon-Avon Northwest in the SA. A detailed, robust SA should clearly set out the site selection process methodology with principles and key sustainability issues clearly defined. Strategic design principles should form an element of this assessment methodology. The site selection process and sustainability appraisal should support the identification and maximisation of potential benefits through the consideration of alternatives and assessment of both negative and positive significant effects on location for growth.

[NOTE: There are a number of figures and tables that cannot be reproduced in this text editor - see original comment in JDi] 4 SUSTAINABILITY APPRAISAL COMMENTS 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. 4.1 It is a requirement of European and UK Legislation that a Sustainability Appraisal (‘SA’) is undertaken incorporating the requirements of the Environmental Assessment of the Plans and Programmes Regulations 2004 which was derived from the Strategic Environmental Assessment (SEA) Directive. 4.2 The purpose of the SA (incorporating the requirements of the SEA Directive) us to ensure that the plan or programme (in this instance the emerging Our Future Birmingham City Plan) promotes the principles of sustainable development by assessing the potential environmental, social and economic impacts or benefits of the plan and incorporating suitable mitigation measures to decrease of increase these respectively. 4.3 The Strategic Environmental Assessment Regulations requirements checklist requires the “preparation of an environmental report that identifies describes and evaluates the likely significant effects on the environment of implementing the plan or programme and reasonable alternatives taking into account the objectives and geographical scope of the plan or programme (regulation 12(2))”. 4.4 Paragraph 32 of the NPPF states that “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 relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever 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”. 4.5 We note that the SA at this stage is identifying reasonable alternatives, these being ‘reasonable alternative broad locations’ and ‘reasonable alternative small settlement locations’, based on a set of criteria (see Figure 8). Figure 4-1 Procedure for identifying reasonable alternative Broad Locations and Small Settlement Locations 4.6 Regarding the list of alternative development locations, we note that ‘South of Coventry’ and ‘South Coventry’ has been identified to provide an alternative scale of development. Whilst we accept that the Councils identified list of 32 broad locations and 22 small settlement locations is not an exhaustive list, and which fits a number of criteria relating to accessibility and position in the settlement hierarchy, it has been arbitrarily defined. 4.7 We object to the SA on the grounds that the land further east of ‘South Coventry’ (as shown in C.17, page 117 of SA Appendices) hasn’t been considered in the SA as a reasonable location option for analysis. 4.8 We take fundamental issue with the reasonable alternative development options that could be located near existing services in the main settlements, the Main Settlements listed in paragraph 3.5.2 of the SA Report (page 46) have been divided into Broad Locations. Essentially, this has been done on the basis that the main settlements were all sufficiently large that they could each have three or more Broad Locations associated with them. We question why - given the scale of Coventry as a city - ‘South of Coventry’ has not been identified in bold font as a main settlement with reasonable alternative broad locations to the south of the city. In effect, RPS considers the whole study area set out in Warwick District Council’s April 2022 Cabinet Report should be identified as a broad location, so as to ensure it has been assessed appropriately. 4.9 Whilst the ambition is to deliver approximately 2,000 homes as part of a strategic allocation, the plan must provide options for all scales. The 1,000 homes mark is preferable given it REPORT JBB7597.C8255 | South Warwickshire Local Plan (Part 1) Issues and Options Representations | FINAL | rpsgroup.com Page 26 supports primary education provision, reducing pressure on existing services in the local area, providing a degree of self-containment, mitigating its impacts when assessed against the SA. Furthermore, RPS considers that the ‘identified’ (based on the criteria set by the Councils) sites on the edge of Coventry should be considered differently in SA terms given their ability to utilise and be accessible from many higher order services that are resultant of the proximity with Coventry. Figure 4-2 Current extent of C.17 'South Coventry', excerpt of SA Report, page 117 4.10 We contend that the Site, Coventry Gateway West presents an opportunity to provide an alternative scale of development that meets the criteria relating to key aspects of accessibility and position in the settlement hierarchy. Therefore, the extent of C.17 [South Coventry] should be drawn to a greater extent to envelope a true extension to Coventry, or present two parcels to C.17, acknowledging the planning commitments at King’s Hill coming forward and thus form a clear ‘arc’ south of Coventry as an alternative development location. A map below (Figure 3-3) highlights the possible extent of an alternative development location we contend should be assessed against the SA objectives. This extent aligns with the master planning work being undertaken by Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, for land to the north of Kenilworth/south of Coventry area. Given the scale of masterplan area, it would not be appropriate, or expected to assess all areas within it. Figure 4-3 RPS proposed extent of C.17 small settlement at South Coventry or broad location ‘South of Coventry’ 4.11 RPS’s proposed extent of SA reasonable alternative locations (above) is presented at this stage as a broad parcel area, given an in-depth assessment has not been undertaken of our (presented) additional segment enveloping the land at Coventry Gateway West. It is envisaged the area when considered as a whole or as smaller parcels (to discount constrained areas) would score as equally positive, if not more so against SA objectives, in particular access to employment opportunities (shown as employment allocation). 4.12 Chapter 7 of the SA ‘Evaluation of the Spatial Growth Options’ sets out the various spatial growth options and how they perform against each SA objective. Table 7.1 of the SA summarises the findings of these options, as replicated in Table 1. Table 1 Excerpt of SA - Summary of findings for the spatial growth options 4.13 We wish to make clear that the distinction between Options should not be too broad and wide-ranging and not to disregard mid-high growth options. In this regard the PPG states: “Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in the plan. They need to be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made.” 4.14 Given some of the spatial options, in the Council’s own words consist of some level of overlap, RPS consider that the finding indicates considerable overlap in the likely effects across the different options. We contend some changes are required to the scoring to assess the sites more accurately in sustainability terms. These are set out in Table 2. Table 2 RPS amendments to spatial growth option scoring 4.15 In respect of SA Objective 4 ‘Landscape’ against spatial options 3 & 4, we consider that all spatial options are likely to be located, in large part, on previously undeveloped land into the surrounding countryside. Recognising that landscape receptors at each location will determine the extent to which a landscape can accommodate change without permanent adverse effects, it is perhaps too broad brush an approach to score that overall, a significant adverse effect on the local landscape cannot be ruled out, when discussing growth at the scale envisaged by the plan. Coupled with possible emergent policy options that may require a ‘landscape-led’ development framework concept. It is possible for development of sites in the countryside to enhance the landscape character by restoration of landscape features; mitigation of potential adjacent housing and provide integration between built and rural landscapes with improved access for future residents. We therefore contend, the effects likely to landscape are positive within these spatial options and thus be scored ‘+’ or ‘0’ at a minimum. 4.16 In respect of SA Objective 7 ‘Natural Resources’ against spatial options 3 & 4, we consider that all spatial options are to be directed towards open countryside. Given that development, regardless of the type of proposal would be directed to previously undeveloped locations and would be expected to result in a permanent and irreversible net loss of ecologically and agriculturally valuable soils caused by excavation, compaction, erosion, contamination, and removal of vegetation cover. We therefore contend that the spatial options 3 & 4 should be scored as ‘0’. With respect to options 1 & 2, given they may potentially promote higher density development, this is an assumption and is dependent of forthcoming proposals, therefore a score of ‘+/-‘ would be more reflective of the possible alternatives.