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.

A sustainability appraisal is a useful but extremely cumbersome tool which tends to be user-unfriendly (in terms of relating the results to reality) and is ultimately based on subjective judgements which tend to ignore the costs of delivery or the quality of the outcome. The SA is incapable of thinking laterally and hence will often point towards standardised solutions. The SA results therefore need to be treated with extreme caution.

BGPC supports a focus on growth in areas of high levels of connectivity. However, consideration of small settlement location C.17 South Coventry should not overlook that this area is included in the Warwick Local Plan and as a result outline permission has already been granted for 425 dwellings at this location.

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 my property. During periods of seasonal storms and prolonged rainfall, land drainage floods my 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 I already experience. I am rather surprised with the positive rating for assessiblity. As someone who attempts to use active transport/train to commute into Birmingham, it is not reflective of my 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. ( There is no parking) My 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. I am unaware of the referenced cycle path network?? Unless they are referring to 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 I have concerns regarding connection to utilities. Many properties within the village, including my own do not have 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.

Given the findings of the Connectivity Analysis in terms of north of Kingswood having the best connectivity, it is surprising that Figure C.13.1 of the SA does not include the area north of Kingswood in the areas outlined in brown, identified as ‘Small Settlement at Kingswood’ in the key. Presumably these give an indication of the areas into which the settlement could be expanded, but the area around the junction of Rising Lane and Station Lane is not included, despite it having good connectivity with the railway station, as confirmed by the Connectivity Analysis. In view of the good accessibility and connectivity as outlined above, the area north of Kingswood should be included in the area of search for potential extensions to the settlement. SUSTAINABILITY APPRAISAL OF THE SOUTH WARWICKSHIRE LOCAL PLAN REGULATION 18: ISSUES AND OPTIONS STAGE – NOVEMBER 2022 We support the finding that the potential new settlement area C1 (Kingswood) is the best performing in terms of accessibility (para 6.13.3). However, given the Connectivity Analysis identifies the area north of Kingswood as having the best connectivity; the reason for considering a new settlement location at Kingswood is the rail connectivity; and the development of a new settlement would in any case involve the provision of new facilities and as such it is not necessary to locate it adjacent to the Kingswood village core; it is not justified that the area of search for a new settlement at Kingswood is to the south of the settlement, away from the railway station. If the SWLP is to seriously tackle the climate change emergency by locating growth where rail services can be conveniently accessed for commuting, then the first priority must be to locate growth close to the railway station. The area north of Kingswood should be considered for a new settlement location as it has the potential to achieve this objective and it has fewer heritage constraints as it relates to the 20th Century part of Kingswood, where there are fewer heritage assets.

SUSTAINABILITY APPRAISAL OF THE SOUTH WARWICKSHIRE LOCAL PLAN REGULATION 18: ISSUES AND OPTIONS STAGE – NOVEMBER 2022 First and foremost, Nurton Developments (Loes Farm) Ltd objects to the geographical extent of the ‘Warwick Northwest’ Broad Location that has been selected for assessment. This includes a broad area outside the A46 boundary, divorced from the settlement, containing Grade II* and II listed buildings. Including this area outside the A46 boundary unfairly influences the assessment of what would be a much more appropriate location for development, inside the A46 boundary. Nurton Developments (Loes Farm) Ltd has promoted this location (Loes Farm) for development and made representations to the previous consultation and Call for Sites to support this. The representations were supported by Heritage Assessment and Landscape and Visual Assessment to demonstrate that a masterplan for up to 260 dwellings could accommodate development while taking into account site constraints and sensitivities. The Sustainability Appraisal (SA) confirms at paragraph 4.16.15 that a Heritage and Settlement Sensitivity Assessment has been undertaken which will provide further evidence to inform the appraisal of potential impacts on cultural heritage, but the assessment was not available for use at the time of undertaking the assessment of Broad Locations. Therefore, the SA has failed to consider important evidence in arriving at its conclusion that there would be a ‘Major Negative’ impact on the adjacent Guys Cliffe RPG. Please refer to our representations below where it is discussed that the Heritage and Settlement Sensitivity Assessment actually finds that there may be scope for development in this area. Furthermore, the inclusion of the area outside the A46 boundary and including Grade II* and II listed buildings leads to the conclusion that there would be a Major Negative impact on two other sustainability objectives, whereas if just the land within the A46 were considered then there would not. Paragraph 4.16.26 of the SA says that “only Warwick NW doesn’t meet the sustainable target distance for access to a GP Surgery”. However, this is not borne out in the technical appendix where at table B.31.10 it states that the Broad Location is within the target distance to a GP Surgery and a Minor Positive impact would be expected under this sustainability objective. In relation to SA Objective 11: Accessibility, it is noted that the Broad Location scores very well in terms of accessibility. It performs best out of any of the Broad Locations. This should be given significant weight in the selection of Broad Locations for development, since it has the greatest potential to address the climate change emergency through reducing car trips. At paragraph 4.16.30 of the SA it is concluded that only the Warwick Northwest Broad Location meets the target distance criteria for a local food shop. As such, this Broad Location has the potential to contribute to 20-minute neighbourhood principles. Conversely, in terms of the other Broad Locations, at paragraph 4.16.31 of the SA it is noted that connectivity is very poor in the Warwick West Broad Location predominantly ranking as Grade E, which will present a major adverse impact on transport for site end users. Therefore, although this location was ‘best’ in terms of some of the other sustainability objectives, a decision to locate development here could lead to some very unsustainable outcomes. Building on the very good accessibility of the Warwick Northwest Broad Location and limiting and impacts through the selection of an appropriate area for development, inside the A46 boundary, would therefore present a highly sustainable option that should be given further consideration.

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 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 Acknowledges 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.

Bearley Parish Council’s additional comments refer to “The Sustainability Appraisal of the South Warwickshire Local Plan - Regulation 18: Issues and Options Stage - Volume 1 of 3: Non-Technical Summary”. In paragraphs N58 and N59 “Broad Locations” and Small Settlement Locations are identified towards meeting housing provision. Paragraphs N59 and N61 identify Bearley as a Small Settlement Location accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph. Paragraphs E11 and E12 of Sustainability Appraisal of the South Warwickshire Local Plan identifies Bearley to be capable of delivering between 50 and 500 new dwellings and significant areas of greenspace to facilitate effective green infrastructure planning. Evaluation of Small Settlement Locations characterises Bearley settlement as follows: 1. Para 5.5.4 “situated immediately adjacently to a designated Site of Special Scientific Interest”; 2. Para 5.5.10 lists Bearley to be among a. “Small settlement locations that are adjacent to a SSSI”; b. “Small settlement locations which coincide with Priority Habitats”; c. “Small settlement locations which coincide with Priority Habitats”; 3. Para 5.6.5 lists Bearley among “Small Settlement Locations that coincide with, are adjacent to or are in proximity to a Special Landscape Area”; 4. Para 5.7.4 identifies Bearley among “Small settlement locations that coincide with/are adjacent to a Conservation Area”; 5. Para 5.8.3 identifies Bearley as “Small settlement locations in proximity to a railway line”; 6. Para 5.9 confirms Bearley like all other small settlement locations, with the exception of South Coventry, coincide with a Mineral Safeguarding Area (MSA). 7. Para 5.11.12 states “The total number of houses to be built at each potential location is currently unknown but for the purposes of this assessment taken to be approximately 50-500 houses per location. On this basis it can be concluded that all locations have the potential to have a significant positive impact upon housing delivery.” 8. Para 5.12.7 states “All small settlement locations, with the exception of Bearley and Hatton Station, lie within the target distance for greenspace.” 9. Para 5.13.4 lists Bearley among small settlement locations were shown to have poor connectivity. 10. Para 5.14.4 lists Bearley among small settlement locations within the target distance to further education. The facts and details pertaining to characteristics of Bearley in items1 to 10 above with the exception of an assumption made in item 7 are given in Bearley Neighbourhood Development Plan 2011-2031 made in October 2021. Appendix C2 Bearley FigureC.2.1 on page 755 appears to have excluded the Bearley Mill brownfield site as pert the BUAB in Fig 8 of the Bearley Neighbourhood Development Plan 2011-2031 made in October 2021. Furthermore, it also appears to have excluded the Heart of England woodland planted adjacent to Ash Lane both in Figure C.2.1 and SA Objective 3: Biodiversity, Flora, Fauna and Geodiversity assessment. On page 759 under SA Objective 9: Housing it is difficult to see the justification for the assumption of delivery of a maximum of 500 dwellings given the facts relating to Bearley included in the document and impact of 500 dwellings upon the existing 300 as well as its meagre infrastructure and connectivity. We hope the realities on the ground will be fully reflected at subsequent phases of this plan. Figure 12 on page 1120 refers to Existing Rail Lines and lists Line A as from Bearley to Earlswood. The line A referred to is from Stratford to Earlswood and does not come anywhere within the boundaries of Bearley.

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

[This response appears to relate to the Sustainability Appraisal rather than the HEDNA, and as such has been moved to this question.] The HEDNA for the Shipston on Stour area is seriously flawed. There are substantial and significant errors, , inaccuracies and assumptions in the HEDNA for the Shipston on Stour area. B.17 Shipston on Stour East HEDNA Pages 639-644 B17.2, B17.3, B17.4, B17.10, B17.11, B17.12, B17.13 B18 Shipston on Stour North HEDNA Pages 645-650 B18.3, B18.4, B18.5, B18.9, B18.10, B18.11, B18.12 B.19 Shipston on Stour Southwest HEDNA Pages 651-656 B19.2, B19.3, B19.4, B19.5, B19.6, B19.10, B19.11, B19.12, B19.13 B.20 Shipston on Stour West HEDNA Pages 657-662 B20.2, B20.3, B20.4, B20.10, B20.11, B20.12, B20.13

[The text that follows appears to relate to the Sustainability Appraisal rather than the HEDNA, so has been moved here.] There is no granularity and thus no credibility to the HEDNA. In most places it appears to be a cut & paste exercise where the same bland observations are made against very different local areas. The lack of any local consultations or evidence (e.g. the consideration of local Housing Needs Surveys) is reprehensible. The HEDNA for the Shipston on Stour area is seriously flawed. There are substantial and significant errors and assumptions in the HEDNA for the Shipston on Stour area that renders it unreliable. B.17 Shipston on Stour East HEDNA Pages 639-644 B17.2, B17.3, B17.4, B17.10, B17.11, B17.12, B17.13 B.18 Shipston on Stour North HEDNA Pages 645-650 B18.3, B18.4, B18.5, B18.9, B18.10, B18.11, B18.12 B.19 Shipston on Stour Southwest HEDNA Pages 651-656 B19.2, B19.3, B19.4, B19.5, B19.6, B19.10, B19.11, B19.12, B19.13 B.20 Shipston on Stour West B20.2, B20.3, B20.4, B20.10, B20.11, B20.12, B20.13 There must be an opportunity created to take local input to correct these errors and inaccuracies and to fully understand the basis for assumptions before this document (HEDNA) can be accepted as a basis for future planning.

Issue I1: Sustainability Appraisal The Sustainability Appraisal (SA) has been submitted as part of the technical evidence which forms an essential component in the production of the Local Plan, which is used to inform where potential developments may be located. 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. In the Sustainability Appraisal (SA), our client’s land is included as part of the assessment for the Broad Location of Royal Leamington Spa Northeast, which is capable of delivering up to 2,000 homes, and thus has been evaluated against the SA’s 13 objectives. Within the SA it is commented that there is the presence of Local Wildlife Site’s (LWS’s) in Royal Leamington Spa Northeast – we would like to note that there are no LWS’s present on our client’s land and as such an allocation on our client’s land would not have a negative impact on SA Objective 3: Biodiversity. We would also like to note that there are no public rights of way over our client’s land and as such an allocation would not affect views for PRoW users thus not having a negative impact on SA Objective 4: landscape. SA Objective 7: Natural Resources comments that potential development may have an impact on quality agricultural land. We would like to comment that the vast majority of our client’s land is grade 3 agricultural land which whilst of moderate quality, is not part of an arable rotation and is instead permanent pasture and as such an allocation on our client’s land would not have a negative impact by removing high quality agricultural land. We strongly agree with the SA that this Broad Location, of which our client’s land forms a part of, may offer many benefits such as providing employment opportunities and additional school places all whilst providing a significant contribution to the housing need of the South Warwickshire District Area. Overall we agree with the SA that there are many positive impacts of development in Broad Location Royal Leamington Spa Northeast and any negative impacts may be easily mitigated thus making it a very sustainable settlement suitable for growth, which our client’s land would be suitable to accommodate.

Preliminary HRA Scoping Report (November 2022) Natural England welcomes the production of the preliminary HRA scoping report at this early stage of the plan making process. We welcome this thorough and clearly presented report. We agree with the Habitats sites identified for consideration in section 5 and the assessment of the potential impact pathways described in section 6. Air quality We agree with the thought process described in Table 6.1 Atmospheric pollution pathways of impact to Habitats sites within 20km of the SWLP administrative area and conclusion that air quality likely significant effects can be screened out of the HRA process. Hydrology We agree with the scoping outcome in Table 6.2 Water resource, levels and quality pathways of impact to Habitats sites and fully support recommendations outlined in Table 6.3. Recreation We welcome the precautionary approach to scope in the Bredon Hills Special Area of Conservation for consideration of recreational disturbance pathway and fully support recommendations outlined in Table 6.5. In particular, the recommendation that the Councils ensure formal and informal recreation provision is sufficient to accommodate level of growth set out in the SWLP. Urbanisation effects We agree with the thought process described and conclusion that there are unlikely to be any urbanisation effects as a result of the SWLP. Functionally linked land We welcome the precautionary approach taken with regards to consideration of the potentially functionally linked lands associated with the Severn Estuary and Humber Estuary designations and fully support recommendations outlined in Table 6.6. We welcome the broad spectrum of plans included in Appendix A for in-combination assessment. We would be happy to provide further comments as the HRA progress. Sustainability Appraisal (November 2022) Natural England welcomes the SA report prepared for the Issues and Options stage of the SWLP. We generally agree with the SEA Topic methodologies and assumptions applied to the appraisal process for SA Objectives. We note the current limitations to the assessment process and assumptions. We support recommendations for further research recommended on the biodiversity assessment and landscape assessment of Broad Locations. We would be happy to provide detailed comments on SA of the SWLP once the preferred options have been selected.

The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. To support the Issue and Options consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no. new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA [see attached document]. The principle and broad approach of the SA is supported but the alternatives it considers are quite limited in scope and do not include for any site or location which does not fall within one of the locations set out. L&Q Estates’ land interests on land at Station Road, Long Marston is such a location yet it is available and is considered a suitable, deliverable site which would deliver sustainable development. The Site (Map ref. 146) does not fall specifically within any of the Broad Locations or SSL’s identified. Whilst further comments are made below in relation to Q-S5.2 on the site’s suitability for development in order to assess all reasonable alternatives the L&Q Estates land on Station Road, Long Marston need to be assessed within the SA and taken on board in the formation of the spatial growth strategy as a reasonable alternative. If this is not done then the SA will not have considered all reasonable alternatives.

Issue I1: Sustainability Appraisal The Sustainability Appraisal (SA) has been submitted as part of the technical evidence which forms an essential component in the production of the Local Plan, which is used to inform where potential developments may be located. 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. In the Sustainability Appraisal (SA), Radford Semele is identified as one of the 22 settlements which is capable of delivering up to 500 homes and thus has been evaluated against the SA’s13 objectives. Radford Semele was found to be the best performing settlement with regards to heritage, education and economy showing its suitability for development. It was not found to be amongst the worst performing settlements for any objective again showing its suitability. However, it has been commented that Radford Semele has a couple of negative impacts which we believe to be incorrect in relation to our client’s land. Under SA Objective 3, it is commented that Radford Semele is a one of a number of settlements which coincides with Priority Habitats. We would like to comment that our client’s land does not contain any Priority Habitat and therefore does not have a negative impact. Under SA Objective 4, it is commented that Radford Semele is one of a number of settlements which has potential to coalesce with Leamington Spa thus having a negative impact. We would like to state that our client’s land is on the eastern side of Radford Semele and would not create any coalescence therefore not having a negative impact. Under SA Objective 11, it is commented that Radford Semele has poor connectivity, however, we would like to comment that that is contradictory to the Settlement Design Analysis, which has been published as a technical document alongside the Issues and Options Consultation. In the Settlement Design Analysis the area of Radford Semele in which our client’s land is located (area 3) is stated to be grade B connectivity which is the second highest connectivity grade. There is therefore no negative impact in regard to accessibility. Overall, Radford Semele has been shown to be a sustainable settlement which is very suitable for growth, which our client’s land would be suitable to accommodate.

Many of the strategic objectives are expressed, rightly, in positive terms –“creating”, “improving”, “developing” - but the appraisal criteria are for the most part about measuring negative effects – loss of environment, increased flood risk etc. The Appraisal methodology should include the scope that a possible location for development offers for improving elements of the existing physical, social and economic environment such as access to services, enhancing the vibrancy of district centres, and so on. Where are the existing problems and can new development if planned properly mitigate or remedy those problems? So, for example will the possible development locations identified in the Consultation enable the provision of services currently absent rather than noting the existing absence of that service.

The SA prepared to support the Issues and Options explores reasonable options in relation to: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. • 116 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. Each option has been assessed/scored against each of the 13 SA objectives in relation to 1. climate change; 2. flood risk; 3. biodiversity and geodiversity; 4. landscape; 5. cultural heritage; 6. pollution; 7. natural resources; 8. waste; 9. housing; 10. health; 11. transport; 12. education and 13. economy. The comments below relate first of all to the housing numbers and then to the growth options and broad locations around main settlements. Housing numbers Two reasonable alternatives to establishing housing number calculations have been undertaken. Option 1 – the HEDNA trend- based projections which point to a need for 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum in Warwick – total of 1,679 dwellings per annum. Option 2 – uses the Standard Method and identifies the need of 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum in Warwick – total of 1,239 dwellings per annum. It is reported within the SA that using the HEDNA figure would more accurately represent local housing need and would better meet the needs of the various members of the community (including affordable homes, student accommodation, older people’s accommodation, specialist housing and custom and self-build plus gypsy and traveller and travelling show people communities). Both options have a similar negative impact on climate change, biodiversity, pollution, natural resources and potentially waste. Option 1 would likely have a greater adverse impact on landscape and townscape character due to higher housing numbers. Both options have a similar minor positive impact on 11 – transport, by the location of new housing in closer proximity to workplaces. The consideration of housing numbers does not provide any locational information and so the impacts in relation to climate change, cultural heritage, health, education is uncertain. Whilst overall, at this stage option 2 appears to perform better overall, we would support the use of the higher HEDNA figure which will allow flexibility within the overall development strategy. This will enable the plan to accommodate a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry. Growth options As set out in the SA, scores each option against the SA objective, which indicates that each option is likely to perform better than others. All perform positively in relation to employment and housing and so, at this stage, no stage should be ruled out in our view. The broad locations for proposed new development have also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratford-upon-Avon and Warwick. These locations were further analysed to test distances from GP surgeries, schools, public transport etc, to remove land within flood zones 2 or 3, AONB, Grade 1 agricultural land, scheduled monuments, SSSI, Registered Parks and Gardens and Ancient Woodland. These broad locations all perform similarly against the SA objectives and at this stage, we would consider it too early to discount any broad locations without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. The same principle is considered appropriate in terms of reasonable alternatives put forward in relation to small settlement locations. Early indications within the SA consideration in relation to New Settlements suggest that this growth option would perform poorly against climate change overall and waste, use of natural resources and landscape; some performing poorly against flood risk, pollution, health, education and biodiversity and local wildlife sites. Whilst this option would achieve up to 6,000 dwellings, thereby resulting in a significant contribution towards meeting the housing need, and seen as being a major positive impact on housing provision, these large-scale developments invariably take years to come to fruition, requiring major investment in all types of infrastructure before housing can come forward. Numerous local plans relying on this type of option have failed. This option, in our opinion therefore is the least favoured and potentially should be ruled out at this stage.

The SA prepared to support the Issues and Options explores reasonable options in relation to: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. • 116 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. Each option has been assessed/scored against each of the 13 SA objectives in relation to 1. climate change; 2.flood risk; 3. biodiversity and geodiversity; 4. landscape; 5. cultural heritage; 6. pollution; 7. natural resources; 8.waste; 9. housing; 10. health; 11. transport; 12. education and 13. economy. The comments below relate first of all to the housing numbers and then to the growth options and broad locations around main settlements. Housing numbers Two reasonable alternatives to establishing housing number calculations have been undertaken. Option 1 – the HEDNA trend- based projections which point to a need for 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum in Warwick – total of 1,679 dwellings per annum. Option 2 – uses the Standard Method and identifies the need of 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum in Warwick – total of 1,239 dwellings per annum. It is reported within the SA that using the HEDNA figure would more accurately represent local housing need and would better meet the needs of the various members of the community (including affordable homes, student accommodation, older people’s accommodation, specialist housing and custom and self-build plus gypsy and traveller and travelling show people communities). Both options have a similar negative impact on climate change, biodiversity, pollution, natural resources and potentially waste. Option 1 would likely have a greater adverse impact on landscape and townscape character due to higher housing numbers. Both options have a similar minor positive impact on 11 – transport, by the location of new housing in closer proximity to workplaces. The consideration of housing numbers does not provide any locational information and so the impacts in relation to climate change, cultural heritage, health, education is uncertain. Whilst overall, at this stage option 2 appears to perform better overall, we would support the use of the higher HEDNA figure which will allow flexibility within the overall development strategy. This will enable the plan to accommodate a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry. Growth options As set out in the SA, scores each option against the SA objective, which indicates that each option is likely to perform better than others. All perform positively in relation to employment and housing and so, at this stage, no stage should be ruled out in our view. The broad locations for proposed new development have also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratford-upon-Avon and Warwick. These locations were further analysed to test distances from GP surgeries, schools, public transport etc, to remove land within flood zones 2 or 3, AONB, Grade 1 agricultural land, scheduled monuments, SSSI, Registered Parks and Gardens and Ancient Woodland. These broad locations all perform similarly against the SA objectives and at this stage, we would consider it too early to discount any broad locations without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. The same principle is considered appropriate in terms of reasonable alternatives put forward in relation to small settlement locations. Early indications within the SA consideration in relation to New Settlements suggest that this growth option would perform poorly against climate change overall and waste, use of natural resources and landscape; some performing poorly against flood risk, pollution, health, education and biodiversity and local wildlife sites. Whilst this option would achieve up to 6,000 dwellings, thereby resulting in a significant contribution towards meeting the housing need, and seen as being a major positive impact on housing provision, these large-scale developments invariably take years to come to fruition, requiring major investment in all types of infrastructure before housing can come forward. Numerous local plans relying on this type of option have failed. This option, in our opinion therefore is the least favoured and potentially should be ruled out at this stage.

2.1 The Site [land south of M40 J15, Longbrook] comprises two fields on either side of the A429, south of M40 J15. The fields form part of the Sherbourne Park Estate. Both fields are currently in arable use. The western field is roughly triangular in shape with an area of 9.04 hectares. It has significant frontage to the A46 (Stratford Road) and the associated M40 J15 roundabout to the north, Watery Lane to the west, and the A429 to the east. The southern boundary is shared with private residential land. 2.2 The eastern field is irregular in shape with an area of 6.78 hectares, owing to the meandering flow of Longbridge Brook, which defines its eastern boundary. The western site boundary includes significant frontage to the A429 and a local access road serving a Highways England depot. This access is also part of a National Cycle Route (Route 41) which crosses the M40 to the north. 2.3 The site is located in a sustainable location, within close proximity to the market town of Warwick and Sherbourne village. Sherbourne Conservation Area is located to the west of the Site, as identified in Section 2.1 of the attached Vision Document. Accessibility 2.4 The Site is bisected by the A429, a major road connecting Warwick and Cirencester. Adjacent to the Site, the A429 consists of a single two-way carriageway subject to a speed limit of 50mph. To the north, the A429 connects to Junction 15 of the M40. It is proposed a new four arm roundabout junction would provide access to the Site, which would avoid intensification of site access points, allowing access to both parcels from a single junction. Flood Risk and Drainage Flood Risk 2.5 The River Avon is located approximately 750m to the south of the Site. The Horse Brook tributary of the River Avon flows to the north and along the eastern boundary of the Site. The Longbridge Brook is located 500m to the north east, and the Sherbourne Brook is located 250m to the south west. 2.6 According to the Environment Agency (‘EA’) the majority of the Site is located within Flood Zone 3 (High Probability - Land having a 1 in 100 or greater annual probability of river flooding) and Flood Zone 2 (Medium Probability - Land having between a 1 in 100 and 1 in 1000 annual probability of river flooding). These Flood Zones are attributed to the Horse Brook. However, the Flood Zones are based upon outdated and strategic level data. The Flood Zones do not consider the Stratford Road or the Warwick Bypass which are located upon embankments elevated above the floodplain. Therefore, the current Flood Maps for Planning do not accurately represent the flood risk at the Site. 2.7 To address this, a new bespoke hydraulic model of the Horse Brook was commissioned and has been prepared by BWB Consulting. The model has been reviewed by the EA and it was approved in January 2023. The model is based upon detailed topographical survey of the watercourses and hydraulic structures, and it includes the latest aerial topographical survey (LiDAR) of the floodplain. This hydraulic model provides an up to date and more accurate representation of flood risk from the Horse Brook to the Site and the local area. The model identifies that the western parcel of the Site should be entirely removed from the 1 in 1000-year floodplain, therefore this parcel should be treated as Flood Zone 1. The eastern parcel is also shown to be largely outside of the 1 in 1000-year floodplain, it is only the eastern boundary that falls within the 1 in 100- year and 1 in 1000-year floodplain (equivalent to Flood Zone 3 and Flood Zone 2 respectively). An extract of the approved model is provided in Appendix 2. 2.8 The EA’s risk of Flooding from Surface Water (RoFSW) mapping has also been reviewed which shows a close correlation to the detailed floodplain mapping, giving further confidence that the flood risk to the majority of the Site is low. Surface Water Drainage 2.9 The Site is understood to currently drain through a combination of limited infiltration into the ground and overland flows to the local watercourse, which is expected to be maintained throughout any future development of the Site. Other environmental considerations 2.10 The enclosed Vision Document demonstrates that: • The Site is very much transitional in terms of landscape character, sitting between the majority infrastructure of the M40 and its associated roads from J15. This, coupled with existing robust vegetation along the Site’s boundaries, reduces the site’s sensitivity in landscape and visual terms. Any proposals will include buffering of sensitive receptors, such as a strong landscape framework through a landscape-led masterplan approach. • The Site is not constrained in terms of ecology, it comprises intensively managed agricultural land. There are opportunities for habitat creation to ensure any proposals deliver the necessary biodiversity net gain. • The nearest heritage assets are the nearby Sherbourne Conservation Area to the west, which includes the grade II* Sherbourne Park and grade II* Church of All Saints, along with a number of other scattered listed buildings. There are also three scheduled monuments to the south and east. Any proposals will include increased boundary planting to strengthen the existing well-vegetated edges of the Site to mitigate any potential impacts on heritage assets. Site Suitability for Employment Development 2.11 The Site’s location adjacent to the Strategic Road Network (‘SRN’) is a unique opportunity to facilitate the delivery of employment/ commercial development in a location which will assist in the reduction in carbon emissions and congestion through placing new employment development close to the labour and consumer markets, including Warwick, Leamington Spa, and Stratford-upon-Avon, which are all in close proximity. 2.12 Reflecting on the site’s proximity and sustainable connections to the SRN, Warwick, Leamington Spa, Stratford-upon-Avon and surrounding villages, the Site is a highly sustainable location and can contribute to South Warwickshire’s economic and employment needs. Indeed, it’s location provides connections to the wider supply chain within South Warwickshire as well as being ideally placed to be developed in accordance with the emerging high tech / knowledge industries championed within the Midlands Engine: Ten Point Plan for Green Growth’ (May 2021). 2.13 With regard to flood risk, the Vision Document for the Site (Appendix 1), illustrates how the layout of the proposed employment development will be arranged to avoid the Horse Brook floodplain, thus ensuring that the development is at a low risk of flooding. This approach will also ensure that no floodplain will be displaced and that the flood risk in the wider area will be unaffected by the development. 2.14 Additionally, the development will be offset by a minimum of 8m from the watercourse to the top of the bank, to provide an ecological buffer and allow for continued access and maintenance. To provide further flood resilience, finished floor levels of the proposed employment site will be set at a minimum of 300mm above the 1 in 100-year flood level including the central climate change allowance. 2.15 For surface water drainage, an appropriate Surface Water Management Strategy which complies with the latest local and national advice will be implemented on the Site to attenuate the increase in surface water runoff caused by the proposed employment development. The rate at which the runoff is discharged into the watercourse will be restricted to the equivalent greenfield runoff rate, preventing an increase in flows leaving the Site and thus ensuring that the development does not have a detrimental impact upon flood risk elsewhere. 2.16 Through the application of Sustainable Urban Drainage Systems (‘SuDS’), surface water will be stored within the Site and subjected to stages of treatment to guarantee that the water quality in the wider area is protected. Wherever possible, above ground SuDS will be used to enhance the aesthetic amenity of the development and provide valuable habitats for the local wildlife. The surface water attenuated storage provided will be located outside of the floodplain and appropriately sized to accommodate the 1 in 100-year storm including an allowance for climate change. Example SuDS features that could be incorporated into the proposed development include attenuation basins, filter drains, permeable paving, and swales. 2.17 The Vision Document (Appendix 1) provides further information in regard to the issues and opportunities associated with the Site, specifically in respect of landscape and visual considerations, ecology and protected species, the historic environment, access, and traffic noise; the vision and principles associated with the key deliverables of the Site; and a concept Masterplan.

3.9 Whilst a Sustainability Appraisal (‘SA’) has been prepared to support the emerging Plan, Rainier are concerned that the five potential options for growth in the area are all related to housing growth, no option explores how employment needs will be met (this is an issue with the wider plan, as per our response to Q V3.1 and Q S7.2 and the plan’s need to focus equally on housing and employment growth). 3.10 The SA should therefore consider separate options for how employment needs will be delivered and met.

In relation to the ‘Sustainability Appraisal of the South Warwickshire Local Plan -Main SA Report’ Historic England welcomes the inclusion of Objective 5: Cultural Heritage, which encompasses the protection, enhancement and management of sites, features and areas of archaeological, historical and cultural heritage importance. In terms of datasets included in the ‘Cultural Heritage Assessment Methodology’ at Table 2.6 of the SA Report, we suggest that the HER is also utilised. We note that the SA Report was prepared in advance of the Heritage and Settlement Sensitivity Assessment being available, and we would therefore suggest that this study, and any further heritage evidence, is fully utilised when the SA is revisited. Historic England understands that at the Issues and Options stage of a Local Plan detailed locational information is not available and that the ability to identify precise effects is challenging. However, we note that all of the growth options include settlements with historic assets and that the effects of new development on the historic environment will be dependent, in part, upon the specific location, layout and design of development, and also on any mitigation and enhancement, which is an unknown at this stage in the Plan process. We would therefore agree with the assessment of ‘Uncertain Impact’ (+/-) for Objective 5 Cultural Heritage in relation to Options 1-4, as presented in Table 7 of the Issues & Options document – ‘High level sustainability appraisal of Spatial Growth Options’. However, we also note that a ‘Minor Positive Impact’ has been assessed for Option 5 Dispersed. Given that many of the settlements included within Option 5 have not been assessed in relation to heritage impacts, we consider that this option should also be determined as having an ‘Uncertain Impact’ on Objective 5 at this current plan stage. In relation to the need for further heritage evidence to inform Option 5, further comments are provided below under ‘Issue S7: Refined spatial growth options.' To assist with your preparation of the SA in relation to the assessment of effect upon the historic environment we refer you to Historic England’s Advice Note 8: Sustainability Appraisal and Strategic Environmental Assessment, 2016 (HEAN8): Historic England Advice Note 8: Sustainability Appraisal and Strategic Environmental Assessment

Having reviewed the sustainability appraisal, Crest Nicholson wish to make comments in relation to small settlement C.17 South Coventry. This area contains our client’s existing committed development to the south of Westwood Heath Road and some of the proposed expansion area for this development (as set out in the Vision Document accompanying the representations). Firstly, Crest Nicholson support the inclusion of this area as a potential option for the consideration of development in the future, given its location on the southern boundary of Coventry and the development approved and under construction on the Crest Nicholson site to the south of Westwood Heath Road for 425 dwellings (W/22/0055) at the western end of the C.17 area. We however query why, when considering reasonable alternatives, the ‘South Coventry’ area is being classified as a ‘small settlement location’ and not a ‘broad location at the main settlements’ due to its location on the edge of Coventry. It is maintained that, whilst Coventry is outside of the Local Plan area, the South Coventry location is more akin to the ‘broad locations’ identified around settlements such as Leamington Spa, Warwick and Kenilworth, particularly given the commitment in the Local Plan Vision to meet, where agreed and appropriate, unmet need from neighbouring authorities. In relation to the boundary shown for the Coventry South location, it is noted that this omits land that has previously been removed from the Green Belt and forms part of the adopted Warwick Local Plan housing allocation H42. To maximise the potential capacity in this sustainable location adjacent to an existing committed development, and assist with reducing the amount of land that might need to be removed from the Green Belt through this new Local Plan, it is requested that the entirety of the H42 non Green Belt land is included as part of the Coventry South location. The additional land to be included is highlighted in the plan below. A Vision document is being submitted alongside these Issues and Options representations, which shows the potential of this blue land for accommodating additional residential development in a way which can be assimilated into the landscape context whilst not resulting in significant harm to the nearby Scheduled Monument. There is also currently considered to be capacity within the local highway network to accommodate the expansion of this existing committed site in the manner suggested. We have reviewed the assessment undertaken by the Sustainability Appraisal in relation to C17, and have the following comments: • Table C.17.1 ‘SA Objective 1: Climate Change’ refers to the assumption that this location could deliver a maximum of 500 dwellings. Clarification is sought that this is in addition to the already approved 425 dwellings (W/22/0055) in this location. • Table C.17.11 ‘SA Objective 11: Accessibility’ shows scores for a number of receptors, including a negative score for ‘Local Services’. However, the methodology set out in Chapter 2 of the SA refers to ‘Food Stores’ as opposed ‘Local Services’ and states that a positive score will be given where a location is within 800m of a food store. It is noted that the approved residential scheme at Westwood Heath will deliver a food store on site and therefore the entire South Coventry location will be within 800m of the store. This accordingly ought to be given a positive score. This is of particular relevance to SA Objective 11, where the South Coventry location has a positive score in relation to all other accessibility categories. However, due to the SA taking only the lowest score into account for each objective, the ‘Local Services’ negative score is the only one included in the summary table for the Small Settlement Locations (Table 5.1).

6.1 The Planning and Compulsory Purchase Act requires a sustainability appraisal to be carried out on development plan documents in the UK. Additionally, the Environmental Assessment of Plans and Programmes Regulations17 (SEA Regulations) require an SEA to be prepared for a wide range of plans and programmes, including local plans, to ensure that environmental issues are fully integrated and addressed during decision-making. 6.2 It should also be noted that SA is an iterative process and, as such, should be undertaken alongside development of the SWLP as it moves forward through the various stages in order to maximise its sustainability credentials. This includes taking into account responses made by stakeholders to the SA and SWLP consultations as part of the plan-making process, including those submitted by local and national house builders. In this context, the IO document explains (page 26) that the SA process will take on board any comments on the SA and use them to furnish the next report with greater detail and accuracy. 6.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) has provided a response to the question below. 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. General Comments 6.4 The IO document explains under Issue I1 that the IO SA has been prepared to support the Issues and Options Consultation which explores the following reasonable alternatives as part of the plan making process: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages; and • 88 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. 6.5 The IO SA also includes an ‘assessment’ of two housing number options, presented at Chapter 9 (Volume 2), but these are not listed in the IO document alongside the alternatives shown above. 6.6 The Sustainability Appraisal Framework and methodology is set out in Appendix A of the IOSA. The SA Framework comprises 13 SA Objectives, decision-making criteria (in the form of specific questions) and indicators used to appraise the sustainability performance of the reasonable alternatives as identified in the IO document. 6.7 Further detailed guidance is then provided in the form of ‘topic-specific methodologies’ for each SA Objective in sections 2.4-2.16 of the IO SA. The IO SA states (at para 2.3.3, volume 2) that these have been established which reflect the differences between the SA Objectives and how each receptor should be considered in the appraisal process. Having reviewed the detailed appraisals in the appendices, it appears that the topic-specific methodologies form the basis for the detailed appraisals of each option. However, none of these methodologies are referred to specifically in the SA Framework. It is therefore unclear how the SA Framework has been devised or how it has been applied in appraising each option, given there is scant reference to it in the evaluation of options or the detailed commentary in the supporting appendices. 6.8 Similarly, the SA Framework is highlighted in some chapters as being used to appraise the options, but not others. This lack of consistency suggests an arbitrary approach has been taken as a basis for the IO consultation and which adds further to the confusion as to how the SA Framework has been devised and then applied in the appraisal of options at this stage. This lack of clarity and consistency in how the SA Framework has been applied undermines the transparency in the SA process, which is critical to ensure the appraisal is both robust and credible. 6.9 This is evident when considering the approach to SA applied across different categories of options. Notably, this is of concern regarding how the housing number options have been assessed and presented in the IO SA, which is explained further in the next section. 6.10 In addition, Schedule 2, paragraph 7 of the SEA Regulations specifies that the Environmental Report (effectively the IO SA report at this stage) must include ‘the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme.’ Section 2.17 of the IO SA provides a brief commentary on how potential offsetting (or ‘mitigation’) of significant effects has been considered at this stage based on a mitigation hierarchy (see Table 22.15 of the IO SA for details). However, whilst some initial mitigations have been suggested for some categories of options, none have been identified for the generic policy options nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potential mitigation hasn’t been identified for these options. This again points to a lack of clarity and consistency in how the options have been appraised which further undermines the transparency in the process. 6.11 Lastly, the IO document provides a commentary on the potential of the SWLP to accommodate unmet needs from the wider Birmingham and Black Country HMA, under Issue H4. Page 112 of the IO document states that ‘For the purposes of the accompanying Sustainability Appraisal we have tested the effects of an additional 5,000 and 10,000 homes’ as possible contributions towards any unmet need. However, the IO SA as not appraised any such contribution, or undertaken any appraisal of possible locations where such unmet could be accommodated. Consequently, the potential contributions of 5000 or 10,000 dwellings to address unmet need as outlined in the IO document, and the spatial options to accommodate this need, represent reasonable alternatives that should be considered through the SA process for the SWLP. This should be undertaken and presented in the next iteration of SA, and suitable a policy response should also be presented in the draft (preferred options) version of the SWLP. SA of housing number options 6.12 Figure 3.2 of the IO SA identifies two housing number options. These options are derived from the updated Coventry & Warwickshire Housing and Economic Needs Assessment (HEDNA) ‘trendbased’ projection (Option I); and the Government’s standard methodology for calculating housing need in South Warwickshire as set out in the Planning Practice Guidance (Option II). 6.13 The two housing number options are as follows: • Option I: The HEDNA trend-based projections point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. Combined total of 1,679 per annum. • Option II: The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Combined total of 1,239 per annum. 6.14 The extent of the appraisal of these two options is set out in Chapter 9 of the IO SA. RPS raises two broad concerns regarding the approach taken in the IO SA. Firstly, it is clear that the appraisal of the housing numbers has been carried out differently to the appraisal of the other options. For example, the appraisal of the housing numbers has been described as an ‘option assessment’, whereas the appraisal of the other options is described as an ‘evaluation’. This suggests a separate approach has been taken in the appraisal of the housing number options. Similarly, there is also a distinct lack of detail underpinning the specific scoring of each housing number option against the SA Objectives (summarised in section 9.1 of the IO SA) with only a very brief commentary in Chapter 9 stretching to just one and a half pages; whereas the appraisal of other options is presented in considerably more detail in individual appendices (B to E) alongside specific chapters for each category of options in the main report (Ch 4 to 8). In contrast, there is no separate appendix which fully explains the scoring for the housing number options. 6.15 Determining the overall scale of housing growth to be planned for in South Warwickshire is a key requirement of local plan process, a process that should be underpinned by a rigorous testing of all reasonable alternatives. However, no explanation is provided for why a different approach is merited for the housing number options. This again points a lack of consistency and transparency in approach across the various options appraisals, which risks undermining the SA process. 6.16 Secondly, as explained the IO SA has identified and appraised two housing number options. Nonetheless, there is at least one other option for the housing requirement that has not been considered in the IO SA. This additional alternative option relates to a ‘part-return-to-trend’ analysis of projected household change set out in the HEDNA (see paras 5.149 to 5.152) and which is summarised for the Coventry & Warwickshire authorities in Table 5.34 of that document. This is a matter RPS has raised in separate submissions under Issue H1. 6.17 The HEDNA analysis points to different, higher household growth projection for the South Warwickshire authorities which takes into past suppression in household formation and which should be addressed in the SWLP and, as such, supports the wider SA Objective for housing (SA Objective 9). However, these alternative growth projections have not been included in the IO SA report. In RPS’ view, the ‘part return to trend’ projections for the South Warwickshire authorities constitute reasonable alternatives that should be tested through the SA process. RPS recommends that the alternative household growth projections set out in Table 5.34 of the updated HEDNA should be incorporated into the appraisal of reasonable options as part of the next iteration of the SA. 6.18 In terms of the actual assessment of the two housing number options, the IO SA (paragraph 9.1.3) acknowledges that ‘…using the HEDNA figure should more accurately represent local housing needs than the Standard Method and therefore Option I should meet the accommodation needs of the various members of the community more successfully’. RPS broadly agrees with this position. 6.19 Nonetheless, the IO SA claims (at paragraph 9.1.4) that the housing number options could have negative impacts on SA Objectives 1, 3, 6 and 7 including ‘major negative impacts’ on climate change and on biodiversity. However, no account is taken here of the likely positive climate impacts expected once the Government introduces changes to building regulations on carbon emissions from new residential buildings through the Future Homes and Buildings programme by 2025. Nor does the appraisal reflect the implementation of Biodiversity Net Gain (BNG), which will become increasingly important in delivering well-designed and environmentally sensitive housing development over the coming years and decades in South Warwickshire, and across the country. The measures introduced through Future Homes and BNG are likely to place a downward pressure on climate impacts from new development during the plan period to 2050. The SA of housing number options should be adjusted to take these factors into account. 6.20 In addition, the IO SA (at paragraph 9.1.4) does acknowledge that the loss of agricultural land cannot be avoided in addressing future housing growth needs. This is evidenced in the Urban Capacity Study addressed elsewhere in this submission (under Issue S4) however this shows a significant shortfall in land availability within existing urban areas across South Warwickshire. RPS broadly agree with this position. SA of New Settlement options 6.21 RPS has made separate submissions on the seven potential new settlement location options identified in the IO document under Issue S5. Details of the SA assessments of these locations are set out in Chapter 6 and Appendix D of the IO SA. 6.22 Paragraph 3.8.1 of the IO SA states that the seven new settlements locations have been identified by the two Councils. The commentary in the IO document under Issue S5 (on page 49) points to these seven locations being drawn from seven larger areas that are simply based on the rail corridors outside of existing urban areas. These areas and locations are shown in Figure 12 of the IO document. The IO SA (3.8.1) then clarifies that the SA Team has prepared a ‘spatial expression’ of each New Settlement using a ‘crude 250ha area of search in a circular search area’ around the approximate location provided by the Councils in the IO document (which RPS assumes to be taken from the elements shown in Figure 12). 6.23 This appears to be the sum total of information and evidence that has informed the identification and selection of these locations as potential new settlements up to this point. Significant uncertainty remains as to where these locations might be located or their full extent. In this regard, RPS notes a significant lack of progress in developing the evidence base required since the Scoping Consultation in 2021. Therefore, there remain substantial doubts as to the suitability or deliverability of any of these potential locations as being able to deliver a new settlement. Consequently, a significant measure of caution must therefore apply to any of the outputs from the SA process at this stage, until the vacuum in the evidence base to support these new settlement locations is prepared and made available to the public. 6.24 That said, the findings summarised in Table 6.1 of the IO SA indicate that all seven new settlement options would have significant negative effects across a range of sustainability criteria. Added to this the need for a considerable amount of work required to inform a suitable policy framework to guide their development, there is no confidence that any of these locations are capable of being delivered as new settlements based on the current position. SA of Spatial Options 6.25 Details of the SA assessments of the five spatial growth options are set out in Chapter 7 of the IO SA. 6.26 Table 7.1 of the IO SA (and Table 7 of the IO document) provides a summary of the appraisal findings for each option. As stated on page 59 of the IO document, the various growth options are not materially different from one another, with the exception of ‘Dispersal’ option, which scores slightly lower in terms of sustainability performance against some SA Objectives. The IO document also points out detailed locational information has not been taken into account at this stage, which means there is uncertainty regarding the nature and significance of the effects at this stage. It is therefore important that the findings from the SA are considered in the round alongside other relevant evidence regarding the suitability of specific locations and settlements in supporting the delivery of the spatial development strategy. 6.27 As highlighted earlier in this submission, the IO document only considers Quinton (and not even Lower Quinton specifically) under Growth Option 5 – Dispersal. RPS argue that Lower Quinton should be included in a number of other spatial growth options (options 1, 2,3 and 5) and so, on this basis, Lower Quinton represents a reasonable option for consideration through the SA process, in accordance with the Regulation 12 of the SEA Regulations dealing with reasonable alternatives. 17 The Environmental Assessment of Plans and Programmes Regulations 2004 (No. 1633)

Overall Methodology 3.3 As part of the assessment undertaken to inform the spatial growth options to be included in the Issues and Options consultation, the Sustainability Appraisal (“SA”) included an assessment of 32 broad locations for up to 2,000 dwellings at the main settlements. 3.4 It is our view that the methodology adopted in the SA is fundamentally flawed. Indeed, in terms of the reasonable alternatives there is no explanation as to why a figure of 2,000 dwellings from a single location has been applied to the assessment of potential development locations. This seems to represent an arbitrary quantum of development and an arbitrary approach to assessing the merits of one or more locations. Importantly, the methodology also fails to consider the opportunities afforded by smaller land parcels in the main settlements, which cumulatively could provide a total of 2,000 dwellings and would likely lead to faster overall delivery and a better range of housing. 3.5 Taking Southam as an example, there is no justification in the SA as to why sites/locations capable of delivering 2,000 dwellings is the only approach considered for the settlement. For example, why is it so important to include all housing for Southam on a single site? Why have smaller strategic sites (i.e. those capable of delivering 500+ homes) not been considered in Southam, as they have been at other settlements? 3.6 We would also raise that the ‘broad locations’ (BL) are so extensive in size, that to assess them as ‘one site’ is absolutely meaningless. For example, the ‘Southam Northwest’ broad location is some 115ha which could likely support the delivery of c. 4,000 dwellings and arguably therefore should have been divided into two under the SA methodology. However, as it has been considered as one entity, the scores attributed to it through the SA are simply not robust when determining the acceptability of parcels within the BL as being suitable for development. 3.7 In the circumstances, the SA clearly cannot claim to be robust or to have assessed the reasonable alternatives to any level of adequacy. SA Assessment of Southam 3.8 The land parcels controlled by Barwood Land to the west of Southam were assessed under Broad Location B.22 – Southam Northwest. 3.9 As stated above, this BL is some 115ha in size and thus the SA analysis fails to carry out robust assessment of land parcels within this extensive Broad Location. 3.10 The land parcels controlled by Barwood Land form a much smaller part of Area B.22 (although are still capable of delivering some c. 565 dwellings) and have different characteristics and locational merits to the wider areas of land included in the assessment. Consequently, we are of the view that the scores assigned to Barwood’s sites within the SA are completely meaningless and are not grounded in reality. 3.11 Due to the SA’s flawed methodology, the land parcels controlled by Barwood Land should be assessed separately from Broad Location B.22 in order to get a true understanding of the suitability of the site for strategic residential development. We have therefore undertaken this exercise below which emphasises the concerns/negative scoring included in the SA for Broad Location B.22. 3.12 The extent of north-west Southam assessed in area B.22 of the SA is illustrated in Figure 1 below, with our client’s land edged red. 3.13 Figure 2 below comprises an extract from the illustrative masterplan for our client’s land, which demonstrates how a smaller part of Broad Location B.22 could be developed in a sympathetic manner for up to c. 565 dwellings. [see original document in submission attachment for maps] 3.14 We now set out our assessment of the analysis contained in the SA for Broad Location B.22 as it relates to the 13 SA objectives. SA Objective 1: Climate Change 3.15 Whilst the SA highlights a concern about an increase in emissions which could partially be resolved through supporting 20 minute neighbourhoods. This fails to acknowledge the merits of our client’s land in terms of its proximity to the existing primary and secondary schools in Southam alongside the facilities of the town centre. These are all within 1km of the site and consequently can contribute towards this objective. 3.16 Providing for housing allocations to the west of Southam is inherently more sustainable in pedestrian and cycle terms than proposing the eastwards expansion of the town, beyond the A423 which operates as a physical barrier to safe and convenient connections to the town centre. 3.17 Furthermore, development on our client’s land off Welsh Road West would help support the vitality and viability of existing services in the town centre which is also a benefit to existing residents further demonstrating attainment of the principles of the 20-minute neighbourhood. SA Objective 2: Flood Risk 3.18 The SA indicates that flood risk is not a factor which limits development to the north west of Southam. This is acknowledged and therefore not considered further. SA Objective 3: Biodiversity, Flora, Fauna and Geodiversity 3.19 With respect to biodiversity and related matters, the SA identifies potential impacts with respect to Ancient Woodland and Local Wildlife Sites. However, our client’s land is not subject to these designations/constraints and therefore this is not relevant to the assessment of the site. In the circumstances, the land controlled by our client would receive a positive score for this SA objective. SA Objective 4: Landscape 3.20 The SA identifies a number of matters with respect to the impact of this Broad Location on the landscape, including with respect to landscape sensitivity. 3.21 The comparative landscape assessment prepared by Incola in July 2022 which accompanied the response to the consultation by Stratford-on-Avon District Council on its Draft Site Allocations document provided a review of the landscape sensitivity work which the authority relied upon 1. As an updated landscape sensitivity assessment and character assessment is in preparation by the authorities, it is not considered appropriate to rely upon the findings of the earlier appraisal. This is for the reasons as detailed in paragraphs 3.8 to 3.10 of the Incola assessment, which state as follows: Since the publication of the LSA in 2011, there has been a significant amount of new housing permitted and constructed, including that on land adjacent to site SOU.11 at Lilley Meadow to the north / northwest of the town and at Manders Croft, within the Stowe Valley east of site SOU.10. The development at Lilley Meadow lies within parcels assessed by the LSA as being of a High and High / Medium landscape sensitivity to housing development, including parcel SOU10 within which the sites north and south of Welsh Road West being promoted by Barwood Land are situated. It is therefore clear that the Council has not previously considered the findings of the LSA to be an absolute constraint to development at Southam on land assessed as being of a high landscape sensitivity. Importantly, it also highlights that the automatic discounting of sites SOU.10 and SOU.11 from further consideration as reserve housing sites due to landscape sensitivity was fundamentally flawed. 3.22 The Incola Assessment references the draft masterplan previously provided and within paragraph 3.14 states: Land parcel So10 assessed by the LSA is considerably larger than the Barwood Land sites north and south of Welsh Road West, extending westwards into the Itchen Valley. As demonstrated by the masterplan at Appendix 2, there are opportunities to develop land within the sites north and south of Welsh Road West, either individually or together, in a manner which respects the sensitivities associated with the wider views, sloping landform, setting of Holy Well, field pattern and tree and hedgerow cover. 3.23 It is therefore clear that the conclusions of the SA with respect to the north-western quadrant at Southam does not apply to our client’s site. Consequently, having regard to this objective, the land off Welsh Road West would be appropriate. Again, this would be assessed as positive in a refined SA. 1 Landscape Sensitivity Analysis 2011 SA Objective 5: Cultural Heritage 3.24 The SA identifies a number of factors which need to be resolved with respect to heritage impacts. This includes the Grade II Listed Buildings of Holy Well and Stoney Thorpe Hall alongside the Scheduled Ancient Monument of Holy Well. 3.25 It is acknowledged that our client’s land south of Welsh Road West is close to these heritage assets. A planning application for up to 175 dwellings was previously considered by the Council (LPA Ref: LPA ref 17/01254/OUT). The officers delegated report details the assessment of impact upon heritage assets. The assessment (page 13) was: Policy CS.8 states that proposals will be of high quality and sensitive to the historic context. The level of harm will be assessed against public benefit. Considerable importance and weight should be given to the duties set out in the Planning (Listed Buildings and Conservation Areas Act 1990, when making decisions that affect listed buildings and conservation areas respectively. These duties affect the weight to be given to the factors involved. The decision of Barnwell Manor was that decision-makers should give ‘considerable importance and weight’ to the desirability of preserving the setting of listed buildings and when carrying out the balancing exercise. Even when the harm to heritage assets is less than substantial, the balancing exercise required by national policy cannot ignore the overarching statutory duty imposed by Section 66(1). It is considered that “preserving” means doing no harm; there is therefore a strong presumption against granting planning permission for any development which would fail to preserve the setting over heritage assets. Listed Buildings The Conservation Officer has identified two listed buildings near to the site which could be affected by the proposals, namely Stoneythorpe Hall and the Holy Well, which is also a scheduled monument. In respect of Stoneythorpe Hall he has identified only a very minor impact on its setting, and insufficient harm to count as ‘less than substantial’ in NPPF terms. For Holy Well, the northern part of this site, the housing element, would be sufficiently removed to restrict harm to its setting. The restricted harm that is caused would mainly be through noise and lighting from this area. Of greater concern is the southern part of the site, adjacent to the Holy Well, which is identified as being for a Riverside Park. The open agricultural fields surrounding the Holy Well make a significant contribution to its setting and concern is raised at the proposals to replace this without more contrived environment. Notwithstanding this, a riverside park with minimal intervention to the existing setting of the Holy Well is still possible given the outline nature of the application and, the potential harm can be minimised to such an extent as to not trigger paragraph 134 of the NPPF. Conservation Area The application site is approximately 300m from the edge of Southam Conservation Area (375m from the residential element of the proposal). Given this distance and the topography of the land between the two areas, I do not consider that the proposed development would unacceptable impact on the historic setting and importance of the Conservation Area. Archaeology The application site is not identified as within an area of any archaeological sensitivity according to the council’s data. It is considered that the risk posed by this proposed development to archaeological remains is minimal. Notwithstanding this, given the undeveloped nature of the site and proximity to several historic features, it is considered that further archaeological work should be required by condition should the proposal be successful. Having regard to the above, I consider the development complies with Policy CS.8 of the Core Strategy. In this assessment, I have considered the special weight to be given to the desirability of preserving the special interest and setting of historic assets. 3.26 The above detailed appraisal by the Council in determining the previous application confirms that the land off Welsh Road West would not have a harmful impact upon heritage assets. This justifies a more positive SA score for this objective than the current results. 3.27 Our assessment is further supported by the findings of the Archaeology and Heritage Assessment prepared by BSA Heritage (Feb 2023); and the separate Archaeology and Heritage Technical Note, also prepared by BSA Heritage (Feb 2023). 3.28 Paragraphs 1.17 onwards of BSA’s Technical Note reviews the Heritage and Settlement Sensitivity Assessment (“HSSA”) that was prepared by Place Services in support of the draft Local Plan. 3.29 The analysis undertaken by BSA concludes that the findings in the HSSA for the area ‘west‘ of Southam are flawed. BSA’s assessment confirms that development in this location can be accommodated without harming the setting of heritage assets, subject to securing necessary mitigation. On a proper analysis, our client’s site to the west of Southam does not warrant a negative score in heritage terms under this SA objective. SA Objective 6: Pollution 3.30 The SA identifies potential issues for north-west Southam associated with its proximity to the A423 and the watercourse. However, our client’s site is not adjacent to the A423 and therefore no noise or air quality issues impact the site for housing, as confirmed by the previous application relating to the proposed development of land to the south of Welsh Road West. 3.31 It is acknowledged that the southern parcel is adjacent to the River Stowe. However, as evidenced by the previous planning application, the provision of a riverside park in this location will provide adequate mitigation to the existing watercourse. As such, our client’s site would receive a neutral score in the SA. SA Objective 7: Natural Resources 3.32 The SA highlights two matters of concern with respect to natural resources, relating to (1) agricultural land quality; and (2) minerals. Whilst the latter is noted, the appraisal details the mitigation. 3.33 For agricultural land, with respect to the land south of Welsh Road West, the Council’s determination of the earlier outline application for up to 175 dwellings (LPA ref 17/01254/OUT) considered this matter. This is on page 2 of the Officer’s Report which states: The agricultural land classification is Subgrade 3, due to a soil wetness limitation. The site does, therefore, not comprise best and most versatile agricultural land. 3.34 It is clear that natural resources are not matters which limits delivery of our client’s site, especially with respect to the southern part. SA Objective 8: Waste 3.35 The SA notes that the development will increase the amount of waste, although this applies equally to any proposal and therefore it is not considered determinative. SA Objective 9: Housing 3.36 The delivery of housing on the site will achieve the benefits as envisaged in the appraisal. SA Objective 10: Health 3.37 The assessment with respect to health within the SA indicates that it is broadly acceptable, other than access to hospital and the proximity to the A423. This consideration applies to all of the sites being assessed for their suitability for development at Southam. Moreover, access to the hospital in Warwick would be enhanced through improved public transport (as noted in the Appraisal). SA Objective 11: Accessibility 3.38 The SA notes that north-western Southam is accessible, other than to rail. This would be addressed through enhanced public transport. 3.39 It is unclear why the SA considers the south-west of Southam to be the best in accessibility terms, particularly as the Settlement Analysis Topic Paper clearly shows our client’s site (north west Southam) as being the best connected. It received the best connectivity grade (Grade ‘B’) of any location in Southam, with the south-west receiving a ‘C’ grade. 3.40 An extract from Appendix 3 of the Topic Paper is included in Figure 3 below. Our client’s site includes land to the west of Southam marked as ‘8(B)’. [see original submission attachment] SA Objective 12: Education 3.41 With respect to education, the SA identifies the proximity of north-west Southam to schools. Unsurprisingly, the location received the highest scoring from the Broad Locations for this objective. Proximity to education is a substantial benefit of allocation our client’s land off Welsh Road West for housing. SA Objective 13: Economy 3.42 With respect to economic objectives, the SA notes the potential to deliver additional employment floorspace within the wider area. 3.43 Although our client’s land off Welsh Road West has been promoted for residential development, the results of the 2021 Census indicate that 39.5% of over 16 year olds in employment, work at or mainly at home. Whilst this may have been influenced by national policy with respect of measures to contain the Covid pandemic, it nevertheless illustrates the ability of this to continue thereby negating the need for extensive employment land and buildings. The ability for home working is reinforced by the highly skilled and educated workforce in Stratford-on-Avon district with 54.1% of those over 16 in employment within managerial, professional or technical occupations. 3.44 The construction of dwellings can therefore also contribute towards economic growth through home working opportunities, and would also assist in wider objectives of minimising the need to travel and also provide scope for enhanced social interactions. This arises as there is then time available for other activities which would otherwise have been spent commuting. 3.45 The scheme for land off Welsh Road West, Southam therefore can still achieve benefits for the employment objective. Summary 3.46 Our analysis clearly demonstrates that a finer-grained analysis of parcels within Broad Location B.22 (comprising land controlled by Barwood Land north and south of Welsh Road West) would receive positive scores against the SA objectives if assessed separate from the Broad Location. This is of particular relevance to the application of the tests of soundness and the allocation of the most appropriate sites for development. 3.47 In addition, the failure of the SA process to assess site/locations to accommodate less than 2,000 dwellings represent a flawed approach as it fails to consider the reasonable alternatives. 3.48 On a proper analysis, our client’s site would receive positive scores for any of the SA objectives. It is an obvious candidate site to provide for housing growth that would clearly contribute to sustainable patterns of growth. 1 Landscape Sensitivity Analysis 2011

Long Itchington has been assessed within the Sustainability Appraisal (‘SA’) as one of twenty two ‘Small Settlement Locations’ (‘SSLs’) which have been identified using 20 minute neighbourhood principles and scaled accordingly. All SSLs have been identified to be capable of delivering between 50 and 500 new dwellings and significant areas of greenspace to facilitate effective green infrastructure planning. Bellway supports the inclusion of Long Itchington in this assessment and consideration of development being directed to this sustainable location. Bellway also agrees with the SA that the settlement is capable of accommodating over 50 dwellings within the SWLP period. Long Itchington is one of the few sustainable settlements across South Warwickshire which is not constrained by Green Belt, an Area of Outstanding Natural Beauty or Special Landscape Area (‘SLA’). Bellway consider that this should be a key consideration when assessing where housing growth should be directed to. Appendix C of the SA includes a detailed summary of the Long Itchington assessment. Bellway consider that the assessment needs to be undertaken on a site by site basis around settlements as flood risk, Agricultural Land Classification, landscape and biodiversity implications identified in Appendix C may not be applicable to all sites around a settlement. For example, land to the north of Long Itchington was previously assessed as having a higher sensitivity to development as it was within the former Leam Valley SLA designated in the District Local Plan Review (2006). The key reason why this land was not retained as an SLA in the adopted Core Strategy was because the neighbouring districts did not designate any SLAs which made the Leam Valley SLA limited in size, it is considered by Bellway’s Landscape Consultation (IDP Landscape) that the technical considerations that supported the designation of the Leam Valley SLA have not changed. Therefore Bellway considers that the landscape to the south of Long Itchington is no more sensitive to development and should be considered appropriate when allocating sites for development in the SWLP. The SA’s assessment of Long Itchington’s accessibility to health, secondary education and railway stations could be mitigated through improvements to public transport and pedestrian connectivity. Therefore, these should not be used to justify no or limited growth being directed to this sustainable settlement. Consideration should be given by the Council to any Vision Documents and technical work submitted by developers / promoters that confirms how key site constraints could be appropriately mitigated. It is important to note that Figure C.14.1 within Appendix C does not include all of Bellway’s land that has been submitted through the SWLP process for development. The southern part of Bellway’s land interests (SHLAA reference Long.21) is excluded. It is unclear if the boundary within Figure C.14.1 is the only land being considered for potential development but consideration should be given to the southern part of SHLAA reference Long.21 and whether it could be included as part of a future allocation and utilised for community benefits as part of a wider residential scheme.

2.1 Response: It is noted that the SA in the conclusion for the Sustainability Appraisal 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] 2.2 As the Issue and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and not mitigation has not been considered.

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

We fully support the authors of the Sustainability Appraisal (Lepus Consulting) view that it would be useful to undertake a landscape evaluation to better inform the sustainability appraisal process. This should be undertaken and available before sites are selected for inclusion at the Preferred Options stage. In Chapter 7 (page 120) the SWLP states; “There is significant opportunity to enhance carbon sequestration through protection, restoration and appropriate management of green land uses”. We are fully supportive of this statement and suggest the SWLP should include a policy that requires the assessment of the carbon impact on any land used for development. With 30% of the worlds land carbon held in undisturbed grassland, planning approvals should be withheld on such undisturbed grassland sites where other suitable sites are available.

2.1 The NPPF at 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).’ 2.2 It is noted that the SA in the conclusion for the Sustainability Appraisal 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.’ 2.3 As the Issue and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and no mitigation has not been considered.