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.
No answer given
The following comments are made in respect of the SA for Wellesbourne. The SSL for Wellesbourne (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. For example, land to the west is constrained by the Airfield, and land to the south by the proximity to the Ancient Woodland ‘Wellesbourne Wood’. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Wellesbourne, and this is a suitable location for growth. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.
No answer given
The following comments are made in respect of the SA for Stratford-upon-Avon. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations. The Site promoted by Bloor Homes (Site 382) forms part of Stratford-upon-Avon South (Broad Location 28), but also includes a small parcel of land to the south of the area. In assessing the five Broad Locations (BL) identified against the SA Objectives, the SA concludes that Stratford-upon-Avon East is the least constrained in terms of environmental receptors. However, Stratford-upon-Avon East is not considered developable without significant highway infrastructure improvements, as its only highway connection to the strategic road network is via the Clopton Bridge and the town centre. In the absence of any evidence to demonstrate this BL would be developable in transport terms, it is not therefore a ‘reasonable alternative’ for up to 2,000 homes, and therefore should not be carried forward in the SA process. If such evidence can demonstrate it is developable, the highway infrastructure essential to the delivery of this BL must form part of the SA and therefore this BL will need to be re-assessed in the next iteration. It is also noted that a large part of Stratford-upon-Avon East is a golf course that has not been submitted through the call for sites. If a large proportion of the land is not available, this is not a ‘reasonable alternative’. The following specific comments are made in relation to the SA and Stratford-upon-Avon South. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. This is welcomed as an updated assessment is required, particularly in respect of Stratford-upon-Avon South given the ongoing and completed development of older peoples accommodation at Land south of the Rosebird Centre. These developments, along with the south-western relief road (LMA) to the west once built, will significantly change the landscape character of the southern part of this BL. It is worth remembering that paragraph 73. a) of the National Planning Policy Framework (NPPF) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the development south of Rosebird Centre and the planned south-western relief road. SA Objective 5: Cultural Heritage and paragraph 4.14.14 incorrectly states that Stratford-upon-Avon South is in close proximity to a Grade I Listed building. This should be amended in the next iteration of the SA. The Heritage and Settlement Sensitivity Assessment has assessed this site as part of the South-east area which scores Green. Further, the Heritage Evidence supporting the Site Allocations Plan finds no heritage constraints on the land east of Shipston Road. Stratford-upon-Avon South performs arguably equally with NorthWest, and should be assessed as such in the next iteration of the SA. SA Objective 11: Accessibility and paragraph 4.14.31 is inconsistent with the text in table B.28.11 for Stratford-upon-Avon South. Stratford-upon-Avon South performs equally with Northeast, and should be assessed as such in the next iteration of the SA. Further, with regard to SA Objective 13: Economy, Stratford-upon-Avon South falls within the sustainable target distance for employment, and therefore performs equal best. Stratford-upon-Avon South performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, there are parts of the BL that do not result in any negative impacts against the Objectives.
The following comments are made in respect of the SA for Stratford-upon-Avon. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations. The Site promoted by Bloor Homes forms part of Stratford-upon-Avon Southwest (Broad Location 29). In assessing the five Broad Locations (BL) identified against the SA Objectives, the SA concludes that Stratford-upon-Avon East is the least constrained in terms of environmental receptors. However, Stratford-upon-Avon East is not considered developable without significant highway infrastructure improvements, as its only highway connection to the strategic road network is via the Clopton Bridge and the town centre. In the absence of any evidence to demonstrate this BL would be developable in transport terms, it is not therefore a ‘reasonable alternative’ for up to 2,000 homes, and therefore should not be carried forward in the SA process. If such evidence can demonstrate it is developable, the highway infrastructure essential to the delivery of this BL must form part of the SA and therefore this BL will need to be re-assessed in the next iteration. It is also noted that a large part of Stratford-upon-Avon East is a golf course that has not been submitted through the call for sites. If a large proportion of the land is not available, this is not a ‘reasonable alternative’. The following specific comments are made in relation to the SA and Stratford-upon-Avon Southwest. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. This is welcomed as an updated assessment is required, particularly in respect of Stratford-upon-Avon Southwest given the ongoing development of Land west of Shottery and the Western Relief Road. These developments, along with the Employment Area (SUA.2) to the north once built, will significantly change the landscape character of the northern part of this BL (i.e. the land promoted by Bloor Homes for development which was defined as High/Medium in the previous 2011 Assessment). It is worth remembering that paragraph 73. a) of the National Planning Policy Framework (NPPF) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the development at Land west of Shottery and SUA.2. SA Objective 5: Cultural Heritage notes the potential major impact of Stratford-upon-Avon Southwest on the setting of Anne Hathaway’s Cottage. This is reflected in the Heritage and Settlement Sensitivity Assessment. However, it is acknowledged that parts of the area could accommodate development, and therefore harm can be avoided if only part of the BL was proposed for development. The northern part of this BL can be developed without harm to the setting of the heritage assets. SA Objective 10: Health notes that Stratford-upon-Avon Southwest is not within the sustainable target distance of a GP Surgery. However, a Health Centre is a consented element of the Land west of Shottery Development to the immediate north east of the BL, and once completed will change the assessment. The next iteration of the SA should acknowledge the proposed Health Centre in its assessment. SA Objective 11: Accessibility concludes that BLs (other than Northeast) have very poor connectivity. However, Stratford-upon-Avon Southwest has good connectivity to the urban area and its facilities via active travel modes. These routes are shown within the Transport Appraisal and Strategy that is submitted with these representations. With regard to SA Objective 12: Education, Stratford-upon-Avon Southwest falls within the sustainable target distance for all schools, and therefore performs equal best. Notwithstanding, it is to be noted that a new primary school also forms part of the Land west of Shottery Development to the immediate north east of the BL. Further, with regard to SA Objective 13: Economy, Stratford-upon-Avon Southwest falls within the sustainable target distance for employment, and therefore performs equal best. Stratford-upon-Avon Southwest performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, there are parts of the BL that do not result in any negative impacts against the Objectives.
The following comments are made in respect of the Sustainability Appraisal (SA) for Bidford-on-Avon. The Small Settlement Location (SSLs) for Bidford-on-Avon includes Rosconn Strategic Land interest south of Avon Way, with the site abutting the built up area boundary to the north. The SSL for Bidford-on-Avon covers a large area of land around all sides of the edge of the village. It is clear that certain parts of Bidford-on-Avon are more sensitive than others. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. It is clear from Table 5.1 that the only major adverse impact identified for Bidford-on-Avon relate to agricultural land classification. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon the development of a site. It is significant to note that Bidford-on-Avon is the only SSL where there is not a major adverse impact in relation to landscape. The SA demonstrates therefore that there are no in principle impediments to growth at Bidford-on-Avon and that it is considered as a suitable location for growth, with a good range of facilities available. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.
The following comments are made in respect of the Sustainability Appraisal (SA) for Kineton. The Small Settlement Location (SSLs) for Kineton does not include Rosconn Strategic Land interest north of Banbury Road, Kineton (Site 470). However, it includes land on the sites western and eastern boundaries, and therefore Site 470 falls between the SSL and the built-up area boundary. As Site 470 is available, this anomaly should be rectified in the next iteration of the SA. The SSL for Kineton covers a large area of land around all sides of the edge of the village. It is clear that certain parts of Kineton are more sensitive than others. For example, land to the south is more constrained by flood zones 2 and 3, and heritage assets. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. It is clear from Table 5.1 that the only major adverse impacts identified for Kineton relate to landscape sensitivity, cultural heritage, and agricultural land classification. With respect to landscape sensitivity, site 470 lies within the least sensitive part of the settlement, within parcel ‘K05’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). Parcel K05 is identified as an area where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). Furthermore, as demonstrated in the accompanying Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries to the north and west. This will further reinforce the site’s visual containment and its clear alignment with the existing built up area. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Kineton, with the 2012 Landscape Sensitivity Assessment showing the areas of lower sensitivity. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon the development of a site. In terms of Cultural Heritage, the SA states that the southern part of the village coincides with an area designated as a Registered Battlefield (Battlefield of Edgehill 1642) and that the impacts of this designation should be mitigated through the location and layout of future proposals. Proposals for land north of Banbury Road, which are illustrated in the accompanying Development Framework Plan demonstrate that the site is located north of the Registered Battlefield, with the site enclosed behind existing residential development along Banbury Road and Devereux Close. The heritage impacts can therefore be avoided through the location of the development. The SA demonstrates therefore that there are no in principle impediments to growth at Kineton and that it is considered as a suitable location for growth, with a good range of facilities available, specifically recognising the excellent location to Schools. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.
The following comments are made in respect of the Sustainability Appraisal (SA) for Long Itchington. The Small Settlement Location (SSLs) for Long Itchington partly includes Rosconn Strategic Land interest east of Marton Road, with the majority of the site congruous with the built up area boundary and the remainder within the SSL. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village and partly overlaps the site. It is clear that certain parts of Long Itchington are more sensitive than others. For example, land to the west is more constrained by flood plain. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. It is clear from Table 5.1 that the only major adverse impacts identified for Long Itchington relate to landscape sensitivity and agricultural land classification. With respect to landscape sensitivity, this site lies within the least sensitive part of the settlement, within parcel ‘LI03’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). LI03 adjoins other parcels (LI02 to the west and LI01 to the east) where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). This is further explained in the enclosed Landscape Statement (FPCR, October 2020). In landscape terms, the site aligns with the Council’s own decision-making in this part of Long Itchington, with it adjoining the Bloor Homes scheme at Bishop Drive where the landscape’s capacity to accommodate change was considered acceptable. Furthermore, as demonstrated in the enclosed Landscape Statement and shown on the Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries to the north, south and east. This will further reinforce the site’s visual containment and its clear alignment with the existing built up area. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Long Itchington, with the 2012 Landscape Sensitivity Assessment and subsequent Council decision-making showing the areas of lower sensitivity, including an area which includes this site. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon the development of a site. 1The SA demonstrates therefore that there are no in principle impediments to growth at Long Itchington and that it is considered as a suitable location for growth, with a good range of facilities available. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.
Harbury is excluded from consideration in the Sustainability Appraisal. Bloor Homes Midlands consider that Harbury should be identified in the next iteration of the SA as a Small Settlement Location (SSL). It is noted that there are a number of SSLs identified which are Category 1, 2, 3 and 4 Local Service Villages in Stratford-on-Avon, but not Harbury which is a Category 1 Local Service Village in the adopted Core Strategy. This is an inconsistent approach, and Bloor Homes Midlands considers that, at a minimum, all Category 1 Local Service Villages in Stratford-on-Avon should be included in the Sustainability Appraisal as a SSL, including Harbury. Settlements at this level of the hierarchy should make a notable contribution towards meeting housing needs, and therefore should be included in the SA. The Councils will need to be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations.
The following comments are made in respect of the SA for Wellesbourne. The Small Settlement Location (SSLs) around Wellesbourne excludes the land east of Warwick Road promoted by Rosconn Strategic Land. As the land falls between the SSL and the settlement boundary, this anomaly should be rectified in the next iteration of the SA. The SSL for Wellesbourne (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. For example, land to the west is constrained by the Airfield, and land to the south by the proximity to the Ancient Woodland ‘Wellesbourne Wood’. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Wellesbourne, and this is a suitable location for growth. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course
The Site partially sits within the north eastern portion of Broad Location: B.16 Royal Leamington Spa Southwest. Overall, the assessment is positive about the sustainable effects of this area, including the potential for provision of a mix of uses, reducing the need to travel, provision of jobs and homes and avoiding settlement coalescence. However, the following comments should be considered for the next iteration of the SA. SA4 should be reconsidered as it is stated that B.16 is not in proximity to a Country Park. The Site is immediately adjacent to Tachbrook Country Park, which is already informally used and subject to improvements. Furthermore, Land East of Europa Way could substantially extend the Country Park. SA5 notes the proximity of Grade II Listed Buildings, and recognises that detailed heritage assessments can ensure the setting of heritage assets. It is questioned therefore whether this should be deemed to have a major negative effect. A number of the spatial assessments in relation to SA Objectives 10 to 13 should be reconsidered in relation to committed development and that currently under construction. In particular, the land uses at the Asps should be considered, including primary school, park and ride and a local centre. SA12 also suggests B.16 is outside of the target distance to a secondary school. This does not take account of Oakley School, which is within walking distance of the Site.
There is no sustainability to any of these plans. All it wants to do is build!
No answer given
Kingswood is identified in the SA as one of 22 Small Settlement Locations (SSLs), considered for intermediate scale, primarily residential development for between 50 and 500 dwellings. Land at Station Lane, Kingswood falls partly within one of the potential SSLs on the outskirts of the settlement. A summary of the findings of the SA assessment of the SSLs is provided at Table 5.1 of the SA. It is clear that all SSL perform differently in different areas, with no one option standing out as the best performing option across all areas. Having said that, it is recognised that Kingswood is one only five SSLs which performs strongly against SA Objective 11: Accessibility reflecting the settlement’s public transport offer. It is noted and considered important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. The findings of the SA are important to guide decision making, but other matters such as the availability of land which meets the NPPF definition of Developable and the suitability of sites when considering the range of opportunities and constraints is most important.
The Sustainability Appraisal (SA) has understandably focussed on exploring reasonable alternatives in relation to the location of new homes and infrastructure (Broad Locations, New Settlements, and Small Settlements). However, the SA should not exclude or ignore testing options in relation to employment and this will need to be addressed in the next iteration of the SA.
The one aspect of the Sustainability Appraisal we wish to comment on is the ‘Evaluation of Broad Locations at the Main Settlements and Small Settlement Locations’. This has identified 32 ‘Broad Locations’ around various main settlements and 22 ‘Small Settlement Locations’. Our concern is that there is a significant flaw with the approach being taken in that both the Broad Locations and Small Settlement Locations cover quite large areas. For example, the SA deals with all of the land around Small Settlements as one option. In many cases, this will result in failing to consider individual smaller parcels of land within such areas that may in fact be appropriate for development in isolation, or in combination with other parcels put forward for consideration for development, within the identified wider areas. Whilst we understand that this approach is a starting point, it is critical that this does not result in smaller parcels within the various Locations being omitted or discounted without due regard to the assessments and the full SHELAA process.
In any sustainability appraisal, there should be reference to local community need. In all five of the SA considered developments, there is no reference to local community need or opinion. All planning applications should have a weighted consideration of local community need.
Main concerns are: - Greenbelt land being re-allocated to be available for development: don't agree with this approach as need to protect greenbelt land - Flood risk assessments: only looks at rivers/ waterways but there are a number of areas that are at moderate to high risk of surface water flooding due to hills and slope of land. Already causing flooding when heavy rain. Fields absorb some of water so placing buildings/ roads etc. on this will increase risk of flooding for existing properties/ houses. Specifically proposed sites next to the railway station/ track in Wootton Waven is not suitable because of how the land slopes from 3 different directions, taking water in heavy rain down Wavensmere Road with Bulls Head Pub and houses around it having flooded numerous times over the years when heavy rain. Building on this land will increase this risk and number of times flooding will occur, including risk to surrounding properties. This does not seem to be considered in current appraisals.
The assessment of sites at Appendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. We think this is wrong and ignores the main purpose of designated Green Belt, particularly in this location.
No answer given
Sustainable development is the key word.
Hiding the sustainability appraisal in the depths of a 477 page appendix and not mentioning it really does inspire confidence on you motives. I regularly walk these paths with my dog and know from experience the range of wild life on my door step - nothing like coming face to face with a deer on a frosty morning. With what is proposed and what I've seem proposed for Kenilworth unless the people take action there will be no divide and the wild life will be gone - any action take - even the spitfire development is detrimental and cannot be undone. There is also a variety of fauna that supports the abundance of wildlife. This is not a "minor negative impact" You seem to be forgetting that the green belt is there to restrict uncontrolled sprawling, prevent the merger of adjacent towns and villages, safeguard the countryside, maintain the characteristics the define the region and encourage re-cycling rather than redevelopment As discussed when this has previously been proposed this is some of the most productive and rated land in the area so where is the justification for this to be consigned to housing as nothing has been put forward to defend this proposal which is contrary to government policy.
it is wrong to say (appendix 3) that development in Old Milverton and Blackdown would lead to no merging of settlements and a minor negative impact on recreational experience.
B.33 ‘Whitnash’ Broad Location Option in fact covers the stables and farms, farmed for generations, at the heart of rural Radford Semele! Landscape – this would lead to COALESENCE of Whitnash and Radford Semele Cultural Heritage – The following fall either within, or in close proximity to, this Broad Location: Roman Villa (Warwickshire Historic Environment Record MWA1905); Castle Hill Field (MWA8287); Via Regia Bridleway - which, unauthorised, has been renamed ‘Greenfield Road’ on Google Maps (see Planning Applications W/22/0232, W/21/0590, W/20/0617, W/12/0027); Whitnash Holy Well (MWA7390), Fosse Way Roman Road. Health – GP surgery with spaces? ACCESSIBILITY: Bus Stop -where? Connectivity – extremely poor (see Analysis map) Food stores – where? Education – Briar Hill Infant School/St Margaret’s C of E Junior School is already over 2 miles by road from the Chesterton Gardens Development (see Planning Application W/22/0232) – what would be the proposed route? Constraints include: Whitnash Brook and Zone 3 Floodplain; Whitnash Brook Valley Nature Reserve and Wildlife Buffer per Whitnash Neighbourhood Development Plan; Railway with single-width bridges over at Church Lane and under at Fieldgate Lane; Via Regia Bridleway (see above). Economy – access to employment opportunities in Stratford-upon-Avon?
The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. I think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.
sorry but the link to the SA of the various locations did not bring me to either appendix 4 or 5 so not able to read the individual SA for each settlement listed to No Comments, but do consider that each existing settlement will be capable to taking some additional development, the various NDP's should assist in identifying which settlements would welcome improvements in infrastructure, such would then be facilitated by allowing development.
The SA does not contain adequately quantitative estimates to support a decision. Quantitative estimates, and quantitative uncertainties in those estimates, are needed to ascertain whether (i) what is the actual requirement for new homes in North Kenilworth (ii) what transport infrastructure is required, what actual journeys will be taken and by what means (car? Train? Bike?) that is, where will the employment be located (iii) what medical (GP clinics etc) and health and welfare (gyms, swimming pools, green spaces) are needed. The proposed development is of sufficient scale that it cannot be simply absorbed into the current infrastructure and amenities of Kenilworth.
3.1 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).’ 3.2 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] 3.3 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 3.4 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.
5. The following three comments are made in respect of the SA. 6. Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Coventry as a major City on its borders that has a significant influence over the area should be recognised in the description of the area. 7. Secondly, the Appraisal has only assessed South Coventry for 50-500 homes as a reasonable alternative Small Settlement Location (SSLs) alongside a number of villages. South Coventry has a level of infrastructure, jobs, and services (not least a World Class University) which dwarfs the other SSLs and therefore is out of place in this list. 8. South Coventry is clearly more akin to the Main Settlements, and therefore Broad Locations (BL) should be appraised for up to 2,000 homes as reasonable alternatives. South Coventry as an area is sufficiently large that it could have three or more BLs in accordance with paragraph 3.6.1 of the SA. Further, having regard to Figure 3.3 of the SA, the area around South Coventry is within 800m of service provision that is either existing (e.g. bus interchange at the University, Woodfield Primary School, GP and retail facilities at the University, Tocil Wood Nature Reserve, Wainbody Wood, Crackley Woods Nature Reserve) or planned as part of the Kings Hill SUE or Coventry South Rail Station and Public Transport Interchange. 9. Finally, land has been put forward through the call for sites process in 2021 (including the HLM site 103) which could accommodate a scale of growth up to 2,000 homes in this location, so this is a ‘realistic option’ having regard to Paragraph: 018 Reference ID: 11-018-20140306 of the NPPG. 10. It is not clear from the SA on what basis the HLM site has not been assessed in the SA, with only one site south of Coventry having been assessed as an SSL (C.17). 11. Having regard to Figure 3.3 of the SA, the entire HLM site falls within 800m of the existing Woodfield Primary School, and the planned Primary School which is part of Phase 1 of the Kings Hill SUE to the immediate north of the site (illustrated within the Vision Document). Whilst it is acknowledged that Woodfield Primary School is a special education school, and that the primary school at Kings Hill SUE is yet to be built, it will be within the next 5 years based on the Council’s Housing Trajectory. 12. Further, the Transport Authorities for the area have consulted on a new train and bus station/interchange within the HLM site, and are planning for its delivery during the early part of the Plan period (as illustrated within the Vision Document). 13. In respect of GP surgery and local shop, all of these facilities will be provided within the Kings Hill SUE to the north of the site. This is likely to be slightly beyond 800m, however, the HLM site is of a scale such that it has capacity to accommodate a GP surgery and local shop within a local centre as illustrated within the Vision Document. 14. In respect of publicly accessible greenspace, the majority of the site is within 800m of Wainbody Wood to the north as acknowledged within the Landforms Analysis in the Settlement Design Analysis. 15. The HLM site does therefore satisfy the criteria within Figure 3.3 for primary schools and publicly accessible greenspace, and can satisfy the criteria in respect of all other elements during the Plan Period. As only one criteria needs to be satisfied, the HLM site is therefore a BL and should be assessed as a reasonable alternative. 16. An overly rigid application within the SA of Figure 3.3 that ignores planned service provision that is to be delivered early in the Plan period, and ignores potential service provision that can be delivered within the site, will result in missed opportunities to contribute sustainably towards growth up to 2050. 17. It is worth remembering that paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the planned facilities at Kings Hill SUE. 18. The HLM site 103 is well placed to achieve the 20 minute neighbourhood principle for all services listed in Figure 3.3, and is therefore a BL reasonable alternative which HLM would request be assessed as part of the next iteration of the SA. 19. Failure of the SA to appraise realistic growth options south of Coventry as a reasonable alternative could result in the Plan not demonstrating that its proposals are ‘appropriate’ and ‘justified’.
6. The following comments are made in respect of the SA for Southam. 7. The Site promoted by HLM forms part of Southam Southeast (Broad Location 22). In assessing the four Broad Locations identified in Southam against the SA Objectives, the SA concludes that Southam Southwest is the best performing. That is not the correct conclusion to draw from the Appraisal based on its findings as evidenced below, moreover Southam Southwest is heavily constrained by HS2 which splits the area into two, separating the majority of the Broad Location from the town itself. This site is not therefore a ‘reasonable alternative’ for up to 2,000 homes as part of a single strategic allocation as any new community would be divided by HS2, and therefore the site should not be carried forward in the SA process. Indeed, it is obvious from the assessment of Broad Locations against the SA Objectives at Table 4.1 of the SA that Southam Southeast is the strongest performing Broad Location in the town. 8. The following specific comments are made in relation to the SA and Southam Southeast. 9. SA Objective 2: Flood Risk identifies Southam Northeast as the best performing Broad Location in Southam as it has the smallest proportion of land coinciding with Flood Zone 3. However, and as set out in the SA, Southam Southeast has only a small proportion of land within Flood Zone 3 and indeed this is negligible given it can be easily avoided and mitigated through masterplanning. As such, HLM consider Southam Southeast should be considered equal best performing with regard to SA Objective 2. 10. SA Objective 4: Landscape incorrectly concludes that Southam Southwest is the best performing Broad Location in Southam. The commentary in the SA (at Paragraph 4.11.9) concludes that Southam Southeast is the best performing parcel in terms of landscape sensitivity as it falls within an area of medium landscape sensitivity. The other three Broad Locations contain substantial quantities of high/medium and high sensitivity land parcels which will be more challenging to mitigate, with major adverse effects anticipated. This error should be remedied in the next iteration of the SA. 11. Further, HLM endorse the evidence base that has informed the SA within the Landscape Sensitivity Assessment of Main Settlements including Areas of Restraint Assessment (White Consultants) - July 2011. HLM have supplemented this work with a more up-to-date Landscape and Visual Overview of the town which is appended to these representations. HLM would request the Council take this work into account if it chooses to update its Landscape Character Assessments. 12. SA Objective 5: Cultural Heritage states that Southam Northeast and Southam Southeast are the best performing Broad Locations in Southam. However, in the conclusion Southam Northeast is singled out as the best performing Broad Location without further explanation. This error should be remedied in the next iteration of the SA. 13. With regard to SA Objective 11: Accessibility, HLM acknowledge that connectivity of Southam Southeast would benefit from enhancement through investment in infrastructure and safe pedestrian/cycle crossings of the A423. HLM have submitted with these representations a Wider Connectivity Plan to demonstrate how it would improve and enable connections to the existing built-up area. These include links to the existing underpass under the A423 to the north, a new controlled toucan crossing of the A423 at grade connecting into Stowe Drive, links to the existing signalised crossing point adjacent to the junction of the A423 and A425, and proposed links across Banbury Road. 14. We consider that insufficient account has been taken of accessibility issues elsewhere in Southam, for example school congestion concerns at Southam Northwest and Southam Southeast being effectively cut off from the main settlement because of HS2; this is should rectified in the next iteration of the SA. Given Southam Southeast is free from such accessibility issues, and considering the accessibility enhancements described above, HLM argue that Southam Southeast is the best performing Broad Location when assessed against SA Objective 11. 15. With regard to SA Objective 12: Education, the SA summary suggests that Southam Northeast is the best performing Broad Location in Southam on the basis of having the largest proportion of land within 800m of an existing primary school. However, any strategic development of this scale will include on-site provision of primary education facilities. Therefore at the very least, the Broad Locations should be considered to perform equally in relation to this SA Objective. 16. Southam Southeast also has advantage in education terms due to the willingness of HLM to accommodate a new sixth form centre within this area (as described within the Education Technical Note). This new facility would relieve pressure on the Southam College site, remove traffic generated by sixth form students from Welsh Road West, and improve facilities for students and staff. The new sixth form centre is proposed to form part of a wider Education hub which is to include a primary school, supporting the combination of administration and other facilities which will reduce running costs. As such, it is contended that Southam Southeast performs strongest in relation to Education and this should be reflected in the SA. 17. Taking all of the above into account, it is clear that Southam Southeast does in fact perform best when assessed against the SA Objectives, as set out in our assessment below: SOUTHAM Northeast Northwest Southeast Southwest Climate Change Flood Risk =BEST =BEST Biodiversity and Geodiversity BEST Landscape BEST Cultural Heritage =BEST =BEST Environmental Pollution Natural Resources BEST Waste Housing Human Health =BEST =BEST Accessibility BEST Education =BEST =BEST =BEST =BEST Economy =BEST Score 4 2 7 2 18. Southam Southeast performs strongest compared to other Southam Broad Locations and this should be recognised in the next iteration of the SA.