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.
3. 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.
78. 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. 79. 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. 80. 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. 81. 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 Developable16 and the suitability of sites when considering the range of opportunities and constraints is most important. 16 Glossary of the National Planning Policy Framework (July 2021)
The Beaudesert and Henley-in-Arden JPC advise that the SWLP is considering 500-2000 houses in Henley-in-Arden. The sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes. The SWLP is totally at odds with the sustainability appraisal. Current Henley travel provision is poor, with infrequent bus & rail services. A large number of school coaches already travel through Henley which has a High Street bottle neck causing traffic problems. Current residents are car dependent on congested roads and new roads would spoil current views of rolling countryside which has hills, rivers and listed sites of interest. SWLP shows no detail for resolving this. Being in a valley, Henley has flood prone land and this is not suitable for housing. Concreting over green space will only increase flooding risk and overload drainage systems. 2.9.7 - This point accepts water quality will be affected but the SWLP has no detail on what infrastructure would be required, how it would work or who would fund capital and operational costs. 2.6.10 - Protected species information has not been assessed and taken into account. How can a plan be adopted, which seeks to build in a sustainable way for biodiversity when no impact assessment data is available? 2.9.6 – This acknowledges development near watercourses will impact riverbanks and water quality but 2.9.7 mitigates this with ‘voluntarily’ measures by developers to protect the environment.
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 general approach of the Sustainability Appraisal is supported, albeit only a limited number of settlements appear to have been considered and other settlements including Stockton can contribute sustainable growth. Future iterations of the emerging Plan should therefore consider additional settlements.
2 Comments – SA Appendix B Kenilworth sites 2.1 Northwest – this site provides the best extensive, historic view of the castle. The site is crossed by the Millennium Way from Chase Lane to Purlieu Road. An excellent view is also available from East Chase Farm walking across to Purlieu Road. Any development of this site should be restricted to the north side of Chase Lane, with the south side saved for future generations and the numerous users of this popular walk – local and visitors. This is key to the preservation of Kenilworth’s most important heritage asset. (A well designed and beautiful Souh Warks: D5 – Protecting and enhancing heritage assets) 2.2 SA technical methodology makes green field sites to be preferred as mitigation will almost always be easier. 2.3 West – this is solely a green field site which will need a substantial road to the transport network. Difficulty and impact of this is not in the SA. 2.4 North – there are various pieces of land that appear to be within the development site that are already established elements recreational elements: Parliament Fields; Allotments on Beehive Hill; school playing fields on Upper Laydes Hills (Coventry Rd). Inclusion within the site could lead to overdevelopment and understatement of recreational facilities. 2.5 Geography of roads around new secondary school should impact on technical SA impact and mitigation but does not appear to have. Also, narrow width of existing roads will create difficulties for walking and cycling access. 2.6 There do not appear to be any requirements on developments to ensure that key climate change aspects are met. This should be the case for all sites - domestic, industrial and other e.g. solar panels on all south(erly) facing roofs. 2.7 All Supplementary Planning Documents (SPDs) should include financial implications for the relevant Council when they are approved.
The Beaudesert and Henley-in-Arden JPC have informed us that the SWLP are considering 500-2000 houses in Henley-in-Arden. Why is this the case when the sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes? There is nothing in the sustainability appraisal which supports Henley being singled out for growth comparable to a broad location. On a map from a distance Henley looks to have good connectivity with access to bus stops and railway station but these services are poor with infrequent and unreliable train and bus service. Henley has been shown to actually have poor connectivity (5.13.4) thus car usage would increase on the already very congested road. Due to the local topography, railway, river, and listed buildings there is little opportunity to improve the road layout. SWLP has no apparent plans to improve infrastructure, leaving this on a local level or to the developers which is not adequate. Henley is the only small settlement shown to have more that 50% of land within flood zone 2. (5.4.2). Being in a valley, Henley already flash floods with the roads becoming impassable frequently in winter months. Risk of flooding will likely increase due to global warming with more extreme weather events. The heavy clay soil bakes hard in summer and completely saturates in winter with a high-water table, creating perfect conditions for increased surface run off year-round. Development would increase surface run off, particularly development of proposed site currently used for growing Christmas trees which of course creates natural flood defence. How would developers prevent increased flood risk? Existing drainage is not sufficient to accept further volumes, the river frequently bursts its banks already and use of soakaways is ineffective due to the nature of local heavy clay soil and high water table, retention ponds would fill in winter and then be ineffective. Increasing building in Henley will certainly contribute to adverse events. 2.9.7 Acknowleges water quality will be affected if infrastructure is not put in place and yet the SWLP has no plan to put infrastructure in place. This is at odds with your vision and objectives. 2.6.10 Protected species survey information has not been used and there is no plan to assess this in more detail until after the plan has been adopted. How then does the SWLP think it can decide where to build the most houses in the most sustainable way for biodiversity if it had no information of where endangered species are. 2.9.6 admits development near watercourses will potentially impact the banks and water quality with the suggestion in 2.9.7 that developers can voluntarily provide additional measures to protect water quality. Given developers focus on profit this is not good enough. The river Alne which runs through Henley has a population of endangered white-clawed crayfish. Sustainability appraisal has failed to recognise Henley has a local nature reserve 5.5.4 – Henley sidings nature reserve would likely be impacted by some of the proposed sites for development. Based on the evidence Henley is not suitable for growth over 500 houses. More information is needed about the local services and environment to establish appropriate lower numbers of proposed development. I am concerned that NOT reviewing the green belt hasn’t been considered as an option.
Issue I1: Sustainability Appraisal 3.1 CEG and Mixed Farms have reviewed the SA and welcome its findings with regards to the consideration of the growth options around Stratford-upon-Avon. Five growth locations were considered, and, of these, Stratford-uponAvon East scored was the best performing, scoring the outright best on 4 out of 13 objectives and scoring broadly comparable or the same on the remaining 9 objectives. Furthermore, when the broad location of Stratford-uponAvon East is considered against all other broad locations, Table 4.1 of the SA would suggest that this location is one of best rated across the all the options in the Plan as a whole. It is noted that Stratford-upon Avon South benefits from a positive assessment overall with the SA albeit slightly worse than Stratford-upon-Avon East due to potential landscape impacts. We do not consider that such impacts would apply to land controlled by CEG and Mixed Farms to the north of Banbury Road for the reasons outlined below. 3.2 We would provide the following additional observations. 3.3 The positioning of boundaries that have used to define broad areas within the SA is questioned as with specific regard to the Stratford-upon Avon East (B.25) and Stratford-upon-Avon South (B.28), the rationale for the dividing boundary between these two areas does not seem entirely logical. The result is that the boundary transects land ownerships – namely that of CEG and Mixed Farms – rather than following existing features, namely Banbury Road.It is worth noting that these locations are outlined in the SA Appendices as areas B.25 and B.28, but when they are shown on Figure 4.1 of the SA Main Report, they are listed as locations 24 and 27. 3.4 The boundaries considered in the SA may have limited impact when considering broad locations, particularly so if both the south and east options are taken forward as locations for development in the Local Plan. However, as well as the important role physical features have in defining brad locations, ownership boundaries should also be a consideration for any eventual allocation as this can impact on deliverability. 3.5 As mentioned earlier based on the findings of the SA, Stratford-upon-Avon East is the least constrained option around the settlement – a conclusion we agree with - and should this be taken forward without Stratford-uponAvon South, the boundary of the eastern parcel should be reviewed so that it follows the built form of Banbury Road and reflects land ownership. Importantly, we do not consider that adding land to the boundary with Banbury Road would adversely affect the overall SA scoring for Stratford-upon-Avon East as it does not exhibit any materially different characteristics or constraints (including landscape sensitivity) meaning it would remain one of, if not the, most sustainable broad location for growth in the Plan. Indeed, it is worth noting that the relevant part of Stratford-upon-Avon South is proposed as a reserve housing allocation in the Draft Stratford Site Allocations Plan (site ref. STR.D), thus demonstrating its suitability for development. The image below is taken from the SA Appendices and shows the Stratford-upon-Avon South boundary but also includes green hatching to demonstrate the area which should be excluded from this option and incorporated into Stratford-upon-Avon East. 3.6 CEG and Mixed Farms has also reviewed the SA Appendices which provides the detailed scoring and commentary of each broad location against the 13 SA Objectives and the individual criteria within each objective. At this stage, we do not seek to challenge the scoring that has been given as there appears to be consistency in the way that scoring has been applied across the broad locations at Stratford-upon-Avon. However, we would make the following comments with specific regard the Stratford-upon-Avon East. 3.7 As outlined above, Stratford-upon-Avon East scores positively and is one of the best options across the plan area as a whole, and the best performing in Stratford-upon-Avon. Nevertheless, it is considered that this scoring could be further improved upon at the next stages of consideration and assessment against a conceptual masterplan. It is evident that for the scoring under SA Objectives 3 (Biodiversity), 4 (Landscape), 5 (Cultural Heritage) and 6 (Pollution), where a minor negative impact has been identified, it has also been identified that mitigation is possible against these impacts through the detailed masterplanning of the layout, design and landscaping of a scheme. Against each of these criteria, the mitigation is rated as either ‘A’ meaning that impacts could be avoided, or ‘M’ where the level of impact could be reduced – a position we agree with. As such, these minor negative impacts could be reduced to negligible/neutral. Indeed, the Site Constraints and Opportunities Plan and Conceptual Framework provide by CEG and Mixed Farms at Appendix 2 demonstrates how such impacts could be mitigated against. 3.8 In reference to Stratford-upon-Avon South, it is evident that it also scores well overall against each of the SA Objectives, with the main difference between it and Stratford-upon-Avon East being the major negative for Landscape Sensitivity criterion under SA Objective 4. This is as a result of the western part of the broad location including an Area of Restraint landscape designation. However, this impact would not apply to the eastern part of the broad location to the north-east of Banbury Road. As outlined above, were the boundary between the southern and eastern broad locations to be amended to more logically reflect physical features, such Banbury Road, the inclusion of the parcel of land east of Banbury Road within Stratford-upon-Avon East rather than Stratford-uponAvon South, would not negatively impact on the scoring that Stratford-upon-Avon East currently receives.
3.1 There a number of concerns with the approach taken in the SA, which include the general approach and specific issues regarding land to the South Coventry which are set out below. General Approach 3.1 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Council’s decide the over-arching distribution strategy in the SWLP and refine options to specific locations, given that certain specific locations have not been assessed in detail. 3.2 Furthermore, when examining the conclusions in detail there are inconsistencies and errors in the assessment of the growth options, which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives; despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travel scores a single positive whereas Sustainable Travel and Economy scores a single negative. 3.3 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be incorrect considering the NPPF (para 176) places the highest status of protection on the conservation and enhancement of the landscape and scenic beauty of AONBs. South Coventry 3.4 The SA evaluates South Coventry as a small settlement location, however, this is considered to be inappropriate. 3.5 When reviewing the SA, is clear that broad locations were considered on the edge of the ‘main settlements’ and the selection of those settlements for assessment appears generally logical in terms of scale and facilities offered by each location. However, the failure to include South of Coventry and place it under the small settlement category appears inward looking and counterintuitive, noting the WDLP rightly identifies South of Coventry as a focus for growth through Policy DS4 and all other settlements identified in that policy were concluded in the SA to comprise ‘main settlements’. 3.6 In addition, part of the land within the South of Coventry is identified as Safeguarded land in the WDLP under policy DS21 which establishes the principle of it being released to meet longer-term strategic development needs. Policy DS20 also clearly identifies the broader area South of Coventry as an area of growth and in response to this, WDC gave Cabinet approval in April 2022 for the preparation of a wider south of Coventry masterplan. This masterplan area extended from Westwood Heath and around to Coventry airport and represents a significant area and opportunity to the south of Coventry. Finally, the site is located in close proximity Coventry and to the University of Warwick’s main campus, which is identified as a Major Investment Site. 3.7 A call for sites form submitted in May 2021 to the SWLP indicated the capacity could be between 900 to 2,500 dwellings and this is the scale in which the site should have been assessed, noting it clearly meets the SWLP’s own criteria for identification of broad locations in terms of scale of housing (circa 2,000 dwellings). Furthermore, growth in this location has the potential to unlock major new infrastructure, as identified in the justification given by WDC to progress a masterplan framework for land south of Coventry. 3.8 Given the above, there is no justification as to why South of Coventry was not assessed in the SA as a broad location for growth. Therefore, to inform the production of the preferred option this area should be appraised as a potential broad location for growth. 3.9 Focusing on specific objectives within the Sustainability Appraisal we would note the following for South of Coventry; SA4: Landscape 3.10 Regarding landscape the site scores a single negative with concerns raised about it including a high landscape sensitivity and coalescence with Burton Green. This is despite the principle of part of its release from the Green Belt being established through it being identified as safeguarded land. Furthermore, it is important to recognise that the HS2 line, which is currently under-construction, runs to the south of this option and this will significantly reduce the potential for coalescence through the creation of new, substantial, defensible and enduring boundary in the landscape. Such new and significant infrastructure delivery will also reduce the sensitivity of the landscape to change. The scoring therefore should be adjusted accordingly. 3.11 The HS2 line does cut through Burton Green and thus the extent of the settlement to the north of the line would not be directly separated by this infrastructure, however such separation could easily be preserved through appropriate master planning, avoiding development in close proximity to Burton Green and creating appropriate landscape buffers. SA11: Accessibility 3.12 The site scores a single negative for accessibility. Whilst the scoring accurately reflects the proximity to Tile Hill railway station it doesn’t reflect the accessibility to the services and facilities associated with the University of Warwick’s main campus which include retail and leisure alongside the potential to integrate with the existing public transport connections providing a frequent service to the City Centre. On this basis the site should therefore score a double positive. SA12: Education 3.13 The site scores a single negative for access to Primary, Secondary and Further Education, however the site is less than 1 mile from the Westwood Academy (Secondary) and is adjacent to the University of Warwick’s Main Campus (Further education) and therefore the scoring should be increased accordingly to at least a single positive, potentially a double positive. In respect of primary education, assessing the site as a larger option would enable on-site provision to be taken into account which would also support a more positive score against this objective. SA13: Economy 3.14 The site scores a single positive for access to employment, however the location benefits from access to employment to the north of the site in Coventry. Westwood Way (34ha employment site) is classified as a major employment site by Coventry Council and provides for a diverse range of occupiers this can be accessed by dedicated off road pedestrian and cycle connections opposite the site and is within 250m of the site frontage. The industrial estates located off Charter Avenue and Westwood Way are also within walking distance of the site. In addition, the proximity to the University of Warwick’s main campus, which provides a number of employment opportunities, should also be taken into account. Consequently, the site’s scoring against the economy objective should be increased to a double positive.
2.1 The concerns with the Sustainability Appraisal (“SA”) relate to the overall approach for how options have been assessed and specific concerns that Gaydon/Lighthorne Heath and land within its proximity has not featured within the assessment process. 2.2 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Councils decide the over-arching distribution strategy in the SWLP and refine options to specific locations. This is particularly important given that certain specific locations have not been assessed in detail and therefore a fully informed evidence base will not underpin the plan. 2.3 When examining the conclusions in detail there are inconsistencies and errors which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives;despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travelscores a single positive whereas Sustainable Travel and Economy scores a single negative. For Natural Resources this is justified based on the Sustainable Travel option potentially promoting higher density development. For Landscape this is on the basis that this option is likely to feature urban extensions to areas that are already built up and may be less sensitive to effects on the Landscape. However, given that the Sustainable Travel and Economy option also focuses on areas which are already established and has the potential for higher densities, including key employment centres, this rationale is equally applicable to this option and its scoring should be adjusted accordingly. 2.4 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be questionable considering the NPPF (para 176) attaches the highest status of protection on conserving and enhancing the landscape and scenic beauty of AONBs. 2.5 In terms of specific concerns, these relate to the lack of recognition Gaydon/Lighthorne Heath receives within the assessment despite the area being the location of Jaguar Land Rover’s principal design and engineering centre and Aston Martin Lagonda’s headquarters, significant residential growth and an existing 100ha allocation for commercial use (solely for the expansion of JLR). This is disappointing given the current policy status of the New Settlement (a Main Rural Centre), the extant employment within the area associated with JLR and AML, and the acknowledged employment opportunity through the 100 Ha allocation in both policy and the adopted SPD for the area as referenced earlier in these representations. 2.6 Gaydon/Lighthorne Heath is a 3,000 home new settlement allocated in the Stratford-on-Avon District Core Strategy. The development features a range of services, facilities and green infrastructure and the Site is now coming forward with over 250 homes occupied. 2.7 The Core Strategy recognises the eventual sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.” 2.8 The settlement hierarchy for Stratford-on-Avon District in the extent Local Pan clearly recognises the transformative nature of this new settlement to the local area. For the purposes of this plan, particularly as the plan is looking to cover a period to at least 2041, Gaydon/Lighthorne Heath should now be considered as a Main Rural Centre and should be considered alongside other Main Rural centres such as Alcester, Shipston-on-Stour and Southam. The SA identifies broad locations at these settlements and therefore for consistency the same approach should be taken at Gaydon/Lighthorne Heath. 2.9 Furthermore, the Gaydon area/M40 Junction 12 is identified as a Major Investment Site within the Issues and Options consultation and therefore specifically identified for it’s potential to attract further inward investment and economic growth. Consequently, the SA should assess options for further development in these locations. 2.10 Therefore, to ensure consistency with other equivalent settlements and to reflect the status of the area as a Major Investment Site, the SA should assess this area as a potential development option. This will ensure that a range of development scenarios are assessed, and that the most suitable and justifiable strategy is taken forward in the plan.
Having reviewed the Sustainability Appraisal, we wish to make comments in relation to Broad Area B.30 Warwick Northeast. The southern end of this broad area contains the land that BDWH is promoting to the north west of Warwick Parkway Railway Station (as set out in the Vision Document submitted to the Call for Sites process accompanying this letter). These comments are set out in Appendix A of this letter. Firstly, it is entirely appropriate to include this broad area as a potential option for the consideration of development in the future, given its location on the western edge of Warwick, which is one of the largest and most sustainable settlements within the SWLP boundary. The proximity of this broad area to the Warwick Parkway Railway Station, which provides public transport connectivity within the District and beyond, makes it a highly sustainable location. However, the approach taken to assess the Broad Areas within the Sustainability Appraisal process results in the overgeneralisation of some of the impacts due to the size of the areas being assessed. The review of reasonable alternatives ought, therefore, to assess specific opportunity sub-areas within these Broad Areas. One of these specific opportunity sub-areas that should be assessed needs to be the land to the north west of Warwick Parkway Railway Station on the basis that this is a self-contained area which is separated from the remainder of B.30 by the Birmingham Road (A4177). The site is bound by the Birmingham Road (A4177) to the north, the Grand Union Canal to the south, the Old Budbrooke Road to the east and an existing hedgerow to the west. In this regard we have re-appraised this sub-area on its own merits against the criteria used within the Sustainability Appraisal. The output from this process, included in Appendix A, highlights that the appraisal outcome for this sub-area is more positive than the appraisal outcome included within the Sustainability Appraisal for the Broad Area as a whole, notably in relation to: Ancient Woodland; ecological designations; access to leisure, food store and PROWs; and potential for delivering some employment floorspace. The Vision Document which is being submitted alongside these Issues and Options representations demonstrates the potential that the BDWH land to the north west of Warwick Parkway Railway Station offers for delivering residential development and green infrastructure in a way which connects and assimilates development into the wider landscape context.
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.
Savills has undertaken an initial review of the Sustainability Appraisal (SA) which has been produced to inform the Issues and Options consultation version of the emerging South Warwickshire Local Plan (SWLP). The SA has, at a high level, reviewed the sustainability credentials of a number of Broad Areas being considered for development. The land being promoted by BDWH to the north west of Warwick Parkway Railway Station is at the southern end of Broad Area B.30. Savills considers that the SA scoring for the BDWH sub-area is more positive than the stated scoring for Broad Area B.30 as a whole. The Savills proposed scoring for the BDWH sub-area is presented alongside the SA in the table included within the remainder of this Appendix. Below (left) we have included a plan of broad area B.30 – Warwick Northeast, the southern end of which includes the BDWH land at Warwick Parkway (right). It should be noted BDWH acknowledges that a number of the proposed revisions to the SA conclusions relate to its reliance on desktop evidence for a wider broad area, rather than evidence base scoped to review specific sites. [See page 15 to 19 of PDF version of representation - not possible to reproduce table here due to formatting]
3.4 IM agree that the approach to the Sustainability Appraisal is reasonable at this stage of the proposal. However, there is now a need to progress with the wider evidence base to ensure that sufficient mitigation can be considered in the next round of the Sustainability Appraisal, which should in turn demonstrate which is the most appropriate growth option. With the absence of consideration of mitigation, the Sustainability Appraisal in its current form does not help identify the most appropriate options. 3.5 With regards to the Site, the findings of the Sustainability Appraisal prepared in support of the adopted WDC Local Plan (2017), which were supported and resulted in the allocation of the Site as a safeguarded site within the plan, should be recognised and referenced through the updated evidence-based documents.
3.4 Taylor Wimpey agrees that the general approach and framework to the Sustainability Appraisal is reasonable at this stage of the proposals. The SA also appreciates the limitations to the assessment process and assumptions made, and that ultimately further consideration, research, and consultation are required to better inform the SA. 3.5 As identified in the SA, it is clear that further work is required before any conclusions relating to locations for growth can be made. A key part of this work must consider the potential mitigation for each location for growth and then for each individual site within those areas. This next stage of work should be underpinned by a suitable evidence base. It is only once this stage of works has been completed that the SWLP authorities will be able to determine the best locations for growth. 3.6 As referenced in section 2 of these representations, the Site was previously identified for partial allocation and partial safeguarding during the preparation of the now adopted WDC Local Plan (2017). The findings of the SA and the proposed mitigation provided sufficient evidence to justify the proposed allocation at that time. Had the Inspector found that exceptional circumstances existed to release the Site from the Green Belt, it would have been released at that time.
2.1 The concerns with the Sustainability Appraisal (“SA”) relate to the overall approach for how options have been assessed and specific concerns that Gaydon/Lighthorne Heath and the wider M40 Junction 12 area has not featured within the assessment process. 2.2 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Council’s decide the over-arching distribution strategy in the SWLP and refine options to specific locations. This is particularly important given that certain specific locations have not been assessed in detail. 2.3 Furthermore, when examining the conclusions in detail there are inconsistencies and errors which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives; despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travel scores a single positive whereas Sustainable Travel and Economy scores a single negative. For Natural Resources this is justified based on the Sustainable Travel option potentially promoting higher density development. For Landscape this is on the basis that this option is likely to feature urban extensions to areas that are already built up and may be less sensitive to effects on the Landscape. However, given that the Sustainable Travel and Economy option also focuses on areas which are already established and has the potential for higher densities, including key employment centres, this rationale is equally applicable to this option and its scoring should be adjusted accordingly. 2.4 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be incorrect considering the NPPF (para 176) places the highest status of protection for conserving and enhancing the landscape and scenic beauty of these areas. 2.5 In terms of specific concerns, these relate to lack of recognition of Gaydon/Lighthorne Heath receives within the assessment despite the area being the location of Jaguar Land Rover’s principal design and engineering centre and Aston Martin Lagonda’s headquarters, significant residential growth and an existing 100ha allocation for commercial use (solely for the expansion of JLR). 2.6 Gaydon/Lighthorne Heath is a 3,000 home new settlement allocated in the Stratford-on-Avon District Core Strategy. The development features a range of services, facilities and green infrastructure and the site is now coming forward with a number of houses completed and occupied. 2.7 The Core Strategy recognises the eventual sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.” 2.8 The settlement hierarchy for Stratford-on-Avon District in the extant Local Plan clearly recognises the transformative nature of this new settlement to the local area. For the purposes of this plan, particularly as the plan is looking to cover a period to at least 2041, Gaydon/Lighthorne Heath should now be considered as a Main Rural Centre and should be considered alongside other Main Rural centres such as Alcester, Shipston-on-Stour and Southam. The SA identifies broad locations at these settlements and therefore for consistency the same approach should be taken at Gaydon/Lighthorne Heath. 2.9 Furthermore, the Gaydon area/M40 Junction 12 is identified as a Major Investment Site within the Issues and Options consultation and therefore specifically identified for it’s potential to attract further inward investment and economic growth. Consequently, the SA should assess options for further development at these areas. 2.10 Therefore, to ensure consistency with other equivalent settlements and to reflect the status of the area as a Major Investment Site, the SA should assess this area within its assessment of development options. This will ensure that the plan is underpinned by robust evidence.
2.1 The concerns with the Sustainability Appraisal (“SA”) relate to the overall approach for how options have been assessed and specific concerns that Gaydon/Lighthorne Heath and the wider M40 Junction 12 area has not featured within the assessment process. 2.2 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Councils decide the over-arching distribution strategy in the SWLP and refine options to specific locations. This is particularly important given that certain specific locations have not been assessed in detail and therefore a fully informed evidence base will not underpin the plan. 2.3 Furthermore, when examining the conclusions in detail there are inconsistencies and errors which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives; despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travel scores a single positive whereas Sustainable Travel and Economy scores a single negative. For Natural Resources this is justified based on the Sustainable Travel option potentially promoting higher density development. For Landscape this is on the basis that this option is likely to feature urban extensions to areas that are already built up and may be less sensitive to effects on the Landscape. However, given that the Sustainable Travel and Economy option also focuses on areas which are already established and has the potential for higher densities, including key employment centres, this rationale is equally applicable to this option and its scoring should be adjusted accordingly. 2.4 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be incorrect considering the NPPF (para 176) places the highest status of protection for conserving and enhancing the landscape and scenic beauty of these areas. 2.5 In terms of specific concerns, these relate to lack of recognition Gaydon/Lighthorne Heath receives within the assessment despite the area being the location of Jaguar Land Rover’s principal design and engineering centre and Aston Martin Lagonda’s headquarters, significant residential growth and an existing 100ha allocation for commercial use (solely for the expansion of JLR). 2.6 Gaydon/Lighthorne Heath is a 3,000 home new settlement allocated in the Stratford-on-Avon District Core Strategy. The development features a range of services, facilities and green infrastructure and the Site is now coming forward with 250 homes occupied. 2.7 The Core Strategy recognises the eventual sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.” 2.8 The settlement hierarchy for Stratford-on-Avon District in the extant Local Plan clearly recognises the transformative nature of this new settlement to the local area. For the purposes of this plan, particularly as the plan is looking to cover a period to at least 2041, Gaydon/Lighthorne Heath should now be considered as a Main Rural Centre and should be considered alongside other Main Rural centres such as Alcester, Shipston-on-Stour and Southam. The SA identifies broad locations at these settlements and therefore for consistency the same approach should be taken at Gaydon/Lighthorne Heath. 2.9 Furthermore, the Gaydon area/M40 Junction 12 is identified as a Major Investment Site within the Issues and Options consultation and therefore specifically identified for it’s potential to attract further inward investment and economic growth. Consequently, the SA should assess options for further development at these areas. 2.10 Therefore, to ensure consistency with other equivalent settlements and to reflect the status of the area as a Major Investment Site, the SA should assess this area as a potential development option. This will ensure that a range of development scenarios are assessed, and that the most suitable and justifiable strategy is taken forward in the plan.
I agree with Warwickshire Wildlife Trust whose key concerns are summarised below : • There should be 20% Biodiversity Net Gain through new development, currently, only 10% is included in the plan. • The Green Infrastructure study used is now 10 years old and needs to be reviewed early on to inform growth options and to include joined-up wildlife corridors. • We would like to see a more detailed assessment of local biodiversity and river habitats in the proposed growth and new settlement locations, especially in the areas adjacent to the river Avon and a number of key ‘Potential Local Wildlife Sites’. • We would like to see more detail on how the Councils’ policies will resolve the climate change emergencies in practice. I also agree with the Green Party that while the proposal is to reduce carbon emissions to net zero from WCC’s own activities by 2030 and the wider County by 2050 this will not happen. WCC’s own annual emissions will only reduce by 46% and the wider County emissions by 40%. This would require 60% of emissions to be offset. A very high figure if only tree planting and natural action are considered. The Green Party is calling for a sustainable strategy which includes more ambitious actions around energy use savings, generation of renewable energy and transport policy.
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 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 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 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 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 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.
2.10. The Respondent wishes to express their concern at this stage regarding the content of the Sustainability Appraisal (SA) in so far that it is unclear how the SA comes to the conclusions that it does in terms of the performance of the identified small settlements against the identified SA objectives. Generally, the document lacks transparency in this regard and there would appear to be inconsistency in the approach to some settlements. 2.11. Turning to Hampton Magna specifically, it is unclear how a settlement that started life in the 1960/70s and contains only a handful of listed buildings and no Conservation Area can be identified as performing the same as settlements with much greater cultural significance (i.e. Bidford, Wootton Wawen, and Wellesbourne). In the Respondent’s view there are clear advantages in locating growth at Hampton Magna compared to these settlements. 2.12. Furthermore, while Hampton Magna resides in the Green Belt (which is a functional policy protection to protect against urban sprawl) it is not located within an area that has been identified as having any particular landscape value i.e., it does not fall within an area designated as a Special Landscape Area or Area of Outstanding Natural Beauty (AONB). While there is potential for coalescence this is not necessarily likely (SA, Paragraph 5.6.4) particularly if an allocation were to be made to the west of village. It is therefore unclear why Hampton Magna has scored as poorly as it has in respect of objectives SA4 and SA5. 2.13. With regard to objective SA12: Education, it would appear that while the SA considers proximity to primary, secondary and further education it does not consider whether there is capacity. With regards to Hampton Magna, it is understood that there is spare capacity of over 100 pupils at Budbrooke Primary School. This means that additional pupils could be accommodated with relative ease and assist in securing the long-term future of the school. 2.14. In short, while it is appreciated that the SA is intended to be a high-level appraisal, in its current form, it does not go far enough in the assessment of settlements to be of any real value in understanding the relative performance of each. Regarding Hampton Magna specifically, the SA does not fully reflect the benefits of growth at the village in respect of its lack of landscape impact, lack of heritage impact, accessibility or school capacity relative to other settlements.
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 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 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 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.
With reference to drawing LC-813_Wooton_Wawen_ILE contained within SA of SWLP section C.22. The location identified behind the Catholic Church encompasses some existing agricultural land, which adjoins that directly behind our property. During periods of seasonal storms and prolonged rainfall, land drainage floods our property, that of my neighbours and the local highway. My neighbours and I have already invested in improvements to mitigate this. I am deeply concerned by any proposals involving a land use change of this area as development will increase the amount of flooding we already experience. I am rather surprised with the positive rating for accessibility. As my partner attempts to use active transport/train to commute into Birmingham, and this not reflective of his experiences: 1) The train service passes through once an hour in either direction. It is often delayed or cancelled, resulting in journey times of hours. 2) Travelling to the train station in winter months requires travel by foot, as there is no/limited parking near to the station. His route requires a journey along unlit road, with limited footway. This isn't suitable for vulnerable users. 3) As a keen cyclist and someone who cycle commutes during summer months, he is unaware of the referenced cycle path network? Unless the plan referred to is the permissive route along the canal towpath. This routing presently doesn't meet cycle path standards and has stairways located on it, making it unsuitable for vulnerable users. Finally, we have concerns regarding connection to utilities. Many properties within the village, including our own, do not have mains gas or sewage connections. I cannot see where this has been considered in either the waste or pollution sections of the report. 500 additional properties is a significant addition, requiring significant management on a network which already doesn't service the entire village.