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.

Vistry Group (“Vistry”) have a series of comments on the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options consultation draft document. These are set out below on a topic basis in the same order that matters are raised in the SA. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions We support the SA testing the Growth Options against the 13 criteria identified in paragraph 2.21 of the report. These criteria accurately reflect the objectives of the SWLP and the topics identified in Annex 1(f) of the SEA directives. The outcomes of the assessment process should, however, be treated with a degree of caution. The SA is a snapshot in time. It assesses the sustainability of the Growth Options and potential locations for allocation on the basis of the current services and facilities that are available and existing constraints. For example, when assessing the potential locations for development against Matter 11 – Education, regard has been had to existing education provision in the locality. It does not, however, consider how new development could improve local education facilities through the provision of new education infrastructure such as a new school that would be of benefit to the local area generally. Sustainability Appraisals are an iterative process, until the current Call for Sites consultation is completed and responses reviewed the local authorities will not have a clear understanding of what services and facilities are being promoted with the various development opportunities being presented. However, in due course this should be a key consideration for the local authorities in determining the preferred strategy, growth options and allocations within the SWLP. Climate Change Whilst we fully support the assessment of the proposals against climate change objectives, we have concerns with the way in which this has been applied in the SA. Paragraph 2.4.6 of the SA states that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses) are likely to increase greenhouse gas emissions by more than 1% and adversely affect climate change. Developments of between 50 to 500 dwellings could increase greenhouse gas omissions by more than 0.1% and have a lesser effect on climate change than the larger sites. Whilst this may be the case in principle, it is somewhat misleading and does not reflect the reality of the way in which the SWLP will deliver housing. The SWLP will have a set housing requirement. The greenhouse gas emissions from the construction of these properties will have a total accumulative impact based on the total number of houses built. The total amount of greenhouse gas omitted as part of the construction of these houses will be broadly the same, regardless of whether the houses are provided on a larger number of small sites or a smaller number of large sites. Larger scale developments are unlikely to have a greater impact on greenhouse gas emissions than smaller schemes. Large scale developments are more likely to provide onsite infrastructure, such as schools, places to work, local services and facilities than small scale developments. In terms of the Rail Corridor Growth Option, it will help facilitate sustainable commuting patterns. Smaller schemes of 50 to 500 dwellings are less likely to provide onsite infrastructure or have the benefit of close proximity to a train station. It is, therefore, inappropriate for the climate change appraisal to penalise larger sites in comparison to smaller sites due purely to their size. It is also suggested that development of greenfield sites for housing has a potential to lead to local, long term significant adverse effects in the form of increasing flooding, drought and storm events. This is not necessarily the case. Indeed, it is not uncommon for new development to introduce flood risk and drainage control measures that improve the flood risk and drainage situations locally. New developments must achieve greenfield run off rates and often can be used to address localised problems associated with flood risk. Biodiversity and Geodiversity The impact of development on biodiversity and geodiversity is a clear consideration in the SA process. However, we note that the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in the report (paragraph 2.6.14) and detailed ecology surveys and assessments will determine, on a site by site basis, the presence of priority species and priority habitats (paragraph 2.6.12). The SA has, therefore, made assumptions about the sensitivity or otherwise of potential development options from an ecological basis linked to their proximity to identified assets rather than on an evidential basis. The SA’s conclusions reached regarding the ecological sensitivity of the development option needs to be treated with a degree of caution. If more detailed site specific ecological information is available from the Call for Site submissions this should be actively considered in the site selection process. Landscape The SA advises at paragraph 2.7.2 that detailed designs for each development appraisal are uncertain at this stage of the assessment. The landscape assessment is a desk based exercise which has not been verified in the field. Therefore, the nature of potential impacts on the landscape are, to an extent, uncertain. The SA recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. The landscape appraisal selection of the SA should be treated with some caution as the evidence base is not complete. Paragraph 2.7.6 states that large scale residential-led development is likely to adversely impact the countryside and urban area where the various reasonable alternative development locations are located. This is a broad brush conclusion. Whilst development may impact on the landscape, impacts are not automatically negative. Indeed, well designed and high quality landscaping could potentially enhance the landscape character of a development area. Cultural Heritage Paragraph 2.8.3 of the SA confirms that the impacts on heritage assets will largely be determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. At this stage, the risk of substantial harm to the significance of the heritage asset has been assessed based on the nature and significance of, and proximity of sites to, the heritage asset in question. It is also advised that whilst the Heritage and Settlement Sensitivity Assessment is being prepared, this assessment was not available for use at the time of undertaking the SA process. The conclusions of the SA on cultural heritage impact must be treated with caution. Where site specific heritage information has been provided with Call for Sites submissions this should be considered in the site selection process. Environmental Pollution We are concerned with 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. Development proposals which would help to reduce the pressure on railway lines by locating further away have a positive score. The SWLP correctly recognises that there are significant benefits in a Rail Corridor Growth Option and that providing access to a train station reduces the need for people to travel using the private car. The approach of the SA in this regard directly conflicts with the Rail Corridor Growth Option. It is suggested that schemes within 200 metres of a major road may have adverse sustainability credentials due to road related air and noise emissions. It does not automatically follow that because the site is within the 200 metres of a main road that a suitable noise and environmental air quality cannot be achieved. This assessment criteria should be reconsidered. Natural Resources The SA has a flawed approach adopted 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’. 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. The SWLP will have to allocate land to deliver a set amount of housing. This will be from a combination of brownfield and greenfield sites. The amount of agricultural land developed in the plan area as a whole is likely to be fixed, as the housing requirement will be fixed. However, the approach of the SA means that it favours the allocation of a large number of smaller sites (less than 20 hectares) rather than a small number of large sites (more than 20 hectares) whilst the total amount of agricultural land developed is likely to be the same. Health Impact The health SA criteria consider the proximity of development to a GP surgery and leisure facilities. Development locations that are closer to GP surgeries and leisure facilities are preferred to those rather than those that are removed. Whilst we support this approach it does not necessarily follow that a site is in close proximity to a doctor’s surgery there will be available spaces for patients. Furthermore, some schemes will be able to provide doctor’s surgery and leisure facilities on site. Similarly, the 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 gives a negative sustainability rating to potential development locations that are more than 400 metres from a bus stop and more than 800 metres from a food store. Whilst this is a sensible starting point, large scale developments will, in all likelihood, provide new bus stops and convenience stores. Indeed, we would fully expect the local authority to require larger schemes to include a local centre. Similarly, development options that are located over 800 metres from a primary school have a negative rating. Large scale sites are likely to provide primary schools. Primary school provision to be a key component of any scheme providing 800+ dwellings. Economy The SA assessment criteria for economic opportunities penalises schemes that are more than 5km from a “key employment location” whilst positively scored sites that are within 5km of a key employment location. Large scale residential sites are likely to provide employment opportunities as part of the overall proposals. It is inappropriate for the SA to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision. Evaluation of Broad Locations at the Main Settlements Southam Vistry control land within the north east of Southam search area. The Southam appraisal, includes at paragraph 4.13.1 of the plan, includes a series of inaccuracies regarding the development potential of this area. It is advised that Southam north west is located in close proximity to Thorpe Rough Ancient Woodland, and development here could have adverse impact on the woodland. Whilst this may be the case, the land in Vistry’s control that forms part of this area is significantly smaller than the Southam north east appraisal area. It will not result in development in close proximity to Thorpe Rough Ancient Woodland. There are no ecology constraints to the development of the site. A Phase 1 of the ecology survey report of the site has been undertaken. There are no ecological constraints that cannot be overcome and the site can provide 10% biodiversity net gain. In terms of landscape impact, Vistry’s land interest at Southam have previously been identified as part of a potential Reserve Housing Site in the Preferred Options Site Allocations Plan. Detailed representations have been submitted to the Site Allocations Plan consultation that demonstrated that the site is entirely deliverable from a landscape perspective. This is confirmed in the Vision Statement that accompanies our Call for Sites submission. The Council have previously ruled out all development options to the west of Southam on the basis of landscape impact. Paragraph 4.11.9 of the SA advises that the Broad Locations to the west of Southam would result in the development of high/medium and high sensitivity landscape parcels. This is clearly a significant constraint to development meaning that the land to the east of Southam should be favoured. Furthermore, and significantly, the conclusions table for Southam in the SA does not reflect the assessment work in the SA. It is suggested by the table at paragraph 4.13.1 that Southam south west is “best” for education provision, however, paragraph 4.12.1 advises that Southam north east is the best performing in terms of education provision. If this error is corrected it means that Southam north east scores “best” for four criteria. Southam north west has “one” best result, Southam east has “two” best results and Southam south west has “three” best score. The SA for Southam should have concluded that Southam north east is the most appropriate location for further development.

We generally support the approach of the November 2022 Sustainability Appraisal (SA) in its identification of a range of alternative growth options from broad distribution scenarios down to small settlement growth locations [E5]. In shaping the reasonable alternative options the councils have been guided by the 20-minute neighbourhood concept which aims to minimise carbon emissions by guiding development to locations where there is sustainable access to every day services and facilities as well as travel options other than the private car [section 3.1]. We consider this to be a sound basis for framing the alternatives explored. In terms of the Broad Locations (BLs) identified at Alcester, we would agree with the conclusions that the BLs identified for this settlement are logical as they avoid strategic constraints whilst being favourably located in respect of established services and facilities. We would broadly agree with the assertions in section 4.3, which cumulatively point to Alcester Northeast being the best performing option out of the three alternative assessed for the town. The identified Small Settlement Locations (SSLs) include a wide range of settlements with very different attributes and sustainability credentials. Unlike the BLs which are a shortlist of logical future growth directions based on the 20-minute neighbourhood concept amongst other considerations, the SSLs have been sorted and assessed purely at the entire settlement level, with weighting applied equally across the sustainability objectives. We are not sure how helpful this approach is because every settlement will have its constraints and opportunities, but the wider SWLP is clear that sustainable access is the priority and the “golden-thread” running through this plan-making exercise. The SA has identified BLs on this basis at the main settlements, so we would suggest the same approach is applied SSLs. We would note that some SSLs such as Kingswood have been identified as potential new settlement locations on the basis of their railway services or potential to provide railway services. If large-scale strategic growth might be apportioned on the basis of access to rail travel, then all locations which offer similar attributes should be considered not necessarily for strategic-level growth, but for smaller scale development in locations that can offer residents a genuine choice of travel options. In this respect, we consider that the availability of such locations should drive the selection of reasonable alternatives within the SSLs just as they have when looking at new settlements and Broad Location options, to refine the alternatives available on the basis of a finer-grained identification of growth directions within SSLs.

Appendix A. SA Framework. The SA objective is similar to the objectives set in our Wilmcote and Pathlow Neighbourhood Development Plan 2017-2031. This was developed after extensive consultation with residents in our Parish and supported by the majority at Referendum and also agreed at SDC Cabinet. Appendix C. Comments on this Appendix are as follows: • The Wilmcote and Pathlow Neighbourhood Plan (NDP) contains a number of objectives and Policies. This Appendix C is subject to meeting these Policies. • Wilmcote is embedded within the Green Belt and contains extensive Conservation areas. Wilmcote is considered as part of the Shakespeare heritage area. Any development will need to not only be sympathetic to this but also agreed by the Shakespeare Trust. • Assumption made that Wilmcote could deliver 500 dwellings, doesn’t say the date when the count starts, some have already got permission/built. Currently there are around six hundred dwellings in Wilmcote so adding a further five hundred would seriously change the nature of the area and extensive infrastructure would be needed prior to building commencing. • It states a twenty-minute neighbourhood located to local services. This would mean building in the Conservation Area which would mean extensive discussions with Conservation Officers, The Shakespeare Trust as well as residents. • Mentions the Grade I and II listed buildings and says the negative impact on these could be mitigated through layout and design. There would likely be fierce opposition from residents, some of whom have lived in the village all their lives, in and around these listed buildings. • Mentions the Conservation Area and that mitigation could be minimised through layout and design. • Mentions proximity to a main road, does not acknowledge that Wilmcote includes the settlement at Pathlow which is sited along the A3400. • Mentions the potential increase in household waste, and potential for 75 dwellings. Housing provision has been assumed could deliver maximum of 500 dwellings. Not sure how this is compatible with 75 dwellings as previously stated. This needs to be clearer. • Access to PROW/cycle path networks; this will have a major impact on health and wellbeing of existing residents and is covered in the NDP Policy WP13. • There is no mention of the problems of parking or speeding. Wilmcote is used as a ‘rat run’ from the A46 to cut through to the A3400. A further five hundred dwellings will exacerbate this further following on from the development also of five hundred dwellings currently under construction along The Ridgeway/Bishopton Lane. This is an opportunity through the SWLP to make provision for parking facilities and introducing a 20 mile per hour speed limit through Wilmcote. • There should be closer liaison with Parish Councils to get impact feedback from local people, i.e., the residents. • A desktop study is all well and good, but it does not reflect reality, it just gives a plan that is not necessarily achievable. • The addition of extra houses would not be matched by any available GP services as these are already fully subscribed with Closure of one of the Stratford practices adding to the capacity issues in healthcare. No reasonable expectation of any improvement over the next decade in these. • The timetable of the X20 bus service is not really compatible with employment especially in the hospitality sector which is a significant employer locally. • Houses in the village are desperately needed, but not on the scale of 500, we are already facing a rat run from Bishopton and Shottery on our door step, a larger school would be required, there is no parking for the train station. this kind of development in not accessible in the green belt or on green field sites. Houses are needed but any development should not be of a scale which overwhelms or substantially changes the character of the existing settlement. In this context, 500 is excessive and harmful. There is insufficient infrastructure to accommodate any substantial new development. The railway station has no parking; Featherbed Lane is not provided with a pavement; lighting on this area would increase light pollution ad be harmful on the Greenbelt. Public transport is virtually non-existent. Medical and educational facilities are inadequate to accommodate a large increase in numbers 1. Infrastructure: This happens to be a big bug bear of mine with any housing development. We've all seen the promises made by developers/councils to include facilities for doctors, dentists and schools but nothing seems to appear or is followed up. I don't think this can go on much longer and when referring to Section 10 of the SA Framework it states "improve access to local health....". Well it goes without saying that building more housing without the other infrastructure being in place is not going to work. The school is another example. Section 12 of the framework mentions "education provide and improve access...." I don’t know what the full capacity number is for our local infant/junior school but there cannot be much room left for any extra so parents will be using their cars to transport the children to other schools which again goes against the ethos of 'proximity access etc'. 2. Railway/train links: If the railway is to accommodate more passengers/travellers at Wilmcote then another big priority must be to sort out the issue of parking. We all know that the village as a whole has a big parking problem and it’s something that needs to be sorted. I know it’s not an easy issue and cannot all be solved at once but in this case the station is priority. We know from the SWLP they want to encourage residents (new or old) to use the rail links but as was highlighted at the meeting you will still get people living outside of Wilmcote who need to use the train from Wilmcote. I see on a daily basis the 'illegally' parked vehicles on the road/bridge by the station and suggest that this could be solved by a small car park sited as near to the station as possible. I appreciate that this would require British Rail to purchase a small piece of land. It amazes me that quite often you will actually have a rail network van parked on top of the bridge lights flashing for some time, and yes some would argue this might be another 'slowing down mechanism' for the speeders but that isn't the point. 3. Speeding: I agree that speeding is not mentioned in the SWLP along with parking but I personally think a 20mph throughout the whole village would enhance everyone’s wellbeing - how many times have we all witnessed excess speeds along Aston Cantlow Road. The cars parked outside the grey cottages do sometimes slow vehicles down but a) most of these cars are parking on the pavements and causing damage but there are also b) vehicles trying to pass (i.e wont give way) these parked vehicles and not being courteous to those coming in the opposite direction. 4. Housing: When referring to the "Appendix A of the SA Framework" I'm quite sure that there will be more answers available as time goes on but they have stipulated themselves in Section 9 that there will be an option/proposal of a suitable mix and tenure of housing including affordable homes and homes for first time buyers. Let’s hope they act on their own words. My answers to the other areas in Appendix A are no different than above and rather than repeat myself none of this is going to work until item 1 above is considered/acted upon before another brick is laid.

It seems to us that the Plan lacks a “moderate positive impact” key likely impact as you only have two positives and effectively three negative impacts so we believe that the chart is deficient and should be amended.

It seems to us that the Plan lacks a “moderate positive impact” key likely impact as you only have two positives and effectively three negative impacts so we believe that the chart is deficient and should be amended.

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.

As currently drafted the SA has not considered all reasonable alternatives (section 3), particularly in terms of ‘small settlements’ (section 5 and Appendix C) new settlement locations (section 6 and Appendix D). Land off Rumbush Lane, Earlswood has not been considered, despite its sustainability credentials and excellent location adjacent to Earlswood station. Based on the consultation document and the previously promoted scale of development, it would appear that the site has perhaps fallen between the ‘new settlements’ category of sites proposing a minimum of 6,000 new homes, and ‘smaller settlements’ comprising 50-500 homes. The plan provides no justification as to why sites between 500 and 6,000 new homes have not been considered, particularly as IM Land’s previous proposals for circa 750 new homes at the site is proportionally no more significant in terms of infrastructure requirements than sites for 500 homes. This is also despite the Council’s own evidence base, the Greater Birmingham and Black Country HMA (GBBCHMA) Strategic Growth Study (2017) (which we discuss further in response to Q S10 below) identifying the site as a broad area with the potential for a new settlement. Notwithstanding the above, IM Land’s proposals for the site are now 500 homes, therefore they would represent a ‘small settlement’. Going forward the Council must consider IM Land’s proposals as a reasonable alternative as a ‘small settlement’ proposition.

We make comments specifically on the ‘Stratford-upon-Avon Northeast’ (reference B.26) site assessment within the Sustainability Appraisal (SA) which includes land under our control at Clopton Quarter and is identified as a Broad Location for growth. Whilst we do not disagree with the SA impact key (with a traffic light system) and general approach to the SA, we have significant concerns about the presumptions made in coming to the SA conclusions. The site assessed is larger than that under our control and states it could deliver up to 2,000 units, however much of the land particularly to the east / southeast (outside of our control) has heritage and landscape constraints which means it is unrealistic to assess this larger site for the delivery of 2,000 units. Instead, the land under our control at Clopton Quarter is capable of coming forward for 700 units without any technical constraints and will be able to enhance connections to the public footpaths and wider countryside in a sensitive manner, respecting the = heritage and landscape consdierations further east.. Appendix 2 of this response sets out a true SA assessment of the land under our control and we request that the SA is updated to reflect this new assessment. [see submission attachment - not possible to replicate table without formatting]

5. The Site partially sits within the north eastern portion of Broad Location: B.16 Royal Leamington Spa Southwest. Overall, the assessment is positive about the sustainable effects of this area, including the potential for provision of a mix of uses, reducing the need to travel, provision of jobs and homes and avoiding settlement coalescence. However, the following comments should be considered for the next iteration of the SA. 6. SA4 should be reconsidered as it is stated that B.16 is not in proximity to a Country Park. The Site is immediately adjacent to Tachbrook Country Park, which is already informally used and subject to improvements. Furthermore, Land East of Europa Way could substantially extend the Country Park. 7. SA5 notes the proximity of Grade II Listed Buildings, and recognises that detailed heritage assessments can ensure the setting of heritage assets. It is questioned therefore whether this should be deemed to have a major negative effect. 8. A number of the spatial assessments in relation to SA Objectives 10 to 13 should be reconsidered in relation to committed development and that currently under construction. In particular, the land uses at the Asps should be considered, including primary school, park and ride and a local centre. SA12 also suggests B.16 is outside of the target distance to a secondary school. This does not take account of Oakley School, which is within walking distance of the Site.

[NB references to the HEDNA below appear to actually refer to the Sustainability Appraisal] I have been reviewing the plans for South Warwickshire and I am particularly concerned about the plans for Wootton Wawen-(W.W.) My concerns are: 1) The section of the HEDNA, page 899 onwards suggests up to 500 houses could be built in Wotton Wawen. Firstly this contradicts the overall plan, set out at: (https://southwarwickshire.oc2.uk/document/124/3728#d3728) Which sets out 5 options (page numbers taken from .pdf version). 1) Page 64, Rail Corridors: Shows W.W. with a growth of 50 to 100 dwellings. 2) Page 66, Sustainable Travel: Shows W.W. with zero growth. 3) Page 68, Economy (jobs & homes co-located): Shows W.W. with a growth of 50 to 100 dwellings. 4) Page 70, Sustainable Travel & Economy: Shows W.W. with zero growth. 5) Page 72, Dispersed growth: Shows W.W. with a growth of 50 to 100 dwellings. So why does HEDNA, (Section C22) page 899 onwards suggests up to 500 houses could be built in Wotton Wawen. Is this a typo? 2) Housing estates should not be placed on the side of a valley where the development will be visible from across the valley. Such valleys have a number of vantage points that people use to admire the view and do not want to be faced with any development. In Wootton Wawen that would particularly include the areas to east of the Alcester road (in the south of the village), and to the east of the A3400 (In the north of the village) as both of these look out across the Alne valley. 3) Wootton Wawen's Station to Birmingham and Stratford is sited as a major reason this village would be suitable for development. But the vast majority of people in this village use cars, increasing the number of houses is NOT going to increase the percentage of people that commute by train, it will still be insignificantly small. For example, the bus service has been reduced because it is not used sufficiently. 4) Landscape Character (Re HEDNA, page 901 Section C.22.4). In the SA Objectives it is pointed out that that a small settlement location could be discordant with the features of these local character areas and a minor negative impact on landscape could arise" This is an understatement. Wootton Wawen has significant local character created by the very old church, large mansion house, old mill, the weir and bridge and the wide valley of the river Alne, Along with a significant number of characterful buildings it makes Wootton a very popular route and destination for walkers. Any development in this area will reduce this appeal and SO this section should definitely be scored as a double negative, not single negative as it is at present. 5) Special Landscape Area (SLA) (Re HEDNA, page 901 Section C.22.4): Wootton Wawen is right in the middle of the Arden Special Landscape area, Any development will adversely affect the SLA. The mitigation sited is to design it through 'Landscape lead design' It is very difficult to hide housing estates in broad open valleys. This should lead the planners to consider the long term effects very carefully, again this should be scored as double negative, not single negative as it is at present. 6) Walkers using the public footpaths are very common in this area, the view from such foot paths should be maintained at all costs. In particular, the Monarch's Way long distance footpath passes through Wootton along the bottom of the valley, and large housing estates built within sight of it would significantly reduce it attractiveness to walkers. Re HEDNA, page 902 Section C.22.4, 'Views from the PRoW Network' this section should definitely be scored as a double negative, not single negative as it is at present. 4, 5 & 6) Further comment: The above issues are particularly significant because any development which detracts for the beauty and character of this location will be a permanent blot on our landscape which will have been done, fundamentally, for financial gain and will be be regretted always. 6) Current planing concerns: in many places in the HEDNA it is suggested that developments could be more acceptable if they are well designed. However, on the A3400 between Henley & Wootton Wawen a number of new houses have been squeezed into gardens and 2 houses with character have been demolished to make way for bland new houses, It has ruined the appearance of the road and is a good example of planners not getting a grip of the situation. I cannot expect these new developments to more considerate.

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 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 2 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 is separate to the plan accommodating a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry – which we comment on elsewhere. Growth options 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 has also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam (in particular), 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. Certainly in relation to Southam the land at Home Farm has consistently been assessed as being suitable for new housing – both by the Council and on appeal – to the extent that it has previously been identified as a draft allocation in the SAP. 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 should be ruled out at this stage.

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

Q-I1: Sustainability Appraisal – please add any comments you wish to make about the SA, indicating clearly which element of the appraisal you are commenting on. 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 Stratfordon-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 2 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 is separate to the plan accommodating a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry – which we comment on elsewhere. Growth options 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 has also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratfordupon-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 should be ruled out at this stage.

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.

5. The NPPF Paragraph 32 states: “Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 6. 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] 7. As the Issues 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.

5. The NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 6. 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] 7. 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.

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

2.4 NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 2.5 The conclusion for the Sustainability Appraisal it states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ 2.6 At this early Issues and Options stage, the findings included in the SA have to be heavily caveated. No mitigation measures have been considered which may impact assessment conclusions. As set out in section 1.82, as the Local Plan progresses, a further series of Technical Reports will be commissioned to underpin the decision-making process. 2.7 Frampton Town Planning, on behalf of Ellis Machinery, reserve the right to comment further at a later stage, once the Sustainability Assessment has advanced following the outcome of key evidence base documents.

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.

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

The 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 assessment appropriately discusses the need for carefully considered development.

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.

Stratford-on-Avon Site Allocations Plan (SAP): Sustainability Appraisal (SA) Our client’s site was assessed as part of the Stratford-on-Avon Site Allocations Plan (SAP): Sustainability Appraisal (SA). In Appendix VIII: SA of Options for Reserve Housing Sites by Settlement, the site is assessed in some detail. This confirms that: a. There are five ‘neutral’ effects – i.e. impacts of the site which are neither positive nor negative when considered. b. There are six ‘minor positive effects’ – i.e., development of the site would have minor positive effects on Ettington. These include not resulting in the loss of public open space or green infrastructure, confirming that an existing footpath running through the site could be incorporated into any proposed development, being located within 400m of the nearest bus stop and within 400m of the nearest services/facilities (Post Office and Schools), not creating any conflicting neighbouring land uses, and largely following the existing settlement pattern. c. There are only 2 ‘major negative effects’ identified: the heritage issue discussed below, confirming that the concern relates to the Grade II listed building Ryepiece Barn on Rogers Lane; and the site’s location within the Feldon Parklands Special Landscape Area (SLA). However, on this latter point, it is notable that the 2021 SHLAA shows that every site in Ettington, including the site identified in the NDP, and the site identified in the 2022 SAP for Self-Build housing are affected by this designation. Both the SHLAA and the SA make the point that impacts can be mitigated through restricting development to the northern part of the site and through extensive landscaping. Finally, our client’s site was included as a reserve housing site in a previous iteration of the SAP, which demonstrates that officers recognised the future development prospects and suitability of this site in accommodating housing development. To summarise, Ettington is a Category 3 LSV with a number of sustainability characteristics which make it particularly suitable for some further housing development. Our client’s site, Land south of Rogers Lane (middle) (ref. ETT.11) has been assessed through iterations of the SHLAA, and the Sustainability Assessment of the SA as having many positive factors, and the negative impacts identified can be effectively mitigated.

2.5.17 As noted above, more information is required on the locations that are being assessed as locations for new settlements to confirm their suitability. The assumptions about the capacity of sites promoted by landowners/developers should also be made clear in the evaluation of any location. This also applies to the locations for growth considered around settlements that are discussed in later sections of the SA (Sections 4, 5 and 6). Where locations are not being actively promoted, they should not be treated as reasonable alternatives unless it can be demonstrated that they are developable. Sites that do not meet the criteria in Annex 2 of the NPPF should not be treated as reasonable alternatives.

More information is required on the locations that are being assessed as locations for new settlements to confirm their suitability. The assumptions about the capacity of sites promoted by landowners/developers should also be made clear in the evaluation of any location. This also applies to the locations for growth considered around settlements that are discussed in later sections of the SA (Sections 4, 5 and 6). Where locations are not being actively promoted, they should not be treated as reasonable alternatives unless it can be demonstrated that they are developable. Sites that do not meet the criteria in Annex 2 of the NPPF should not be treated as reasonable alternatives.

There should be a presumption against development on land liable to flooding.(see the Landform Analysis P.45) The SFRA highlights that Henley is one of the most sensitive areas in SDC to the fluvial impacts of climate change. There is a contradiction between the HSA and development plans for Henley. The assessment outlines the need for carefully considered development and not that Henley should absorb significant urban expansion as suggested in the Plan

The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. The SA prepared in support of 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. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA: The principle and broad approach of the SA is supported but the alternatives it considers are limited in scope and do not assess specific sites. Catesby Estates' land interests fall within two of the Broad Locations in the SA, Kenilworth South and Kenilworth West. The Site itself sits across the eastern edge of Kenilworth West and western edge of Kenilworth South and as such, applying a blanket 'area' approach to the land is not appropriate. Rather, a site specific approach should be undertaken when pursuing the Plan further. 3.7. An assessment of the Site against the SA Objectives shows that it could positively deliver development in a sustainable manner. SA Objective 1 Climate Change: The site would deliver 300 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs with regard to the development surrounding. SA Objective 2 Flood Risk: The site is within Flood Zone 1 at a low risk of fluvial flooding. Some small areas at risk of surface water flooding within the site could be accommodate within a sensitive design response. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: Hedgerows and tress along field boundaries provide ecological value and create opportunities for sheltering and foraging wildlife as well as green corridors to allow the movement of animals and will be retained where possible. Surface water attenuation features can increase overall habitat diversity and mitigation measures to protect species on Site will be developed should the site come forward for development. A landscape and green infrastructure strategy could provide an increase in the biodiversity values of the Site, in line with the mandate of the Environment Bill. The Masterplan has embodied such principles and Catesby Estates are committed to the delivery of at least 10% biodiversity net gain as part of the development of this site. SA Objective 4 Landscape: The site is within immediate context of urbanising influences such as residential development along Rounds Hill (north) and properties off Hunt Paddocks (adjacent to eastern part of site). Existing mature trees and hedgerows help define the site and its boundaries and will be retained and strengthened where appropriate. Proposals can come forward (as set out in vision Framework) with a strong green infrastructure and multifunctional open space framework to provide a sensitive transition between urban and countryside. A positive green infrastructure and open space strategy would also inform an emerging Green Belt boundary to the west. SA Objective 5 Cultural Heritage: No archaeological heritage is evidently present on site. The site is within 1km of an Ancient Monument and the curve of Rouncil Lane to the south east forms part of the Wedgenock Old Park (nearly 500m away), a Medieval Deer Park that was attached to Warwick Castle. Similarly, there are no built heritage assets present within the site. A Heritage Assessment has been undertaken to support the proposed development of the Site and has principally considered assets including Kenilworth Castle Grade I listed building, Kenilworth Castle Registered Park and Garden and Oak Farmhouse Grade II listed building. Matters relating to heritage do not comprise a major constraint to the deliverability of the site for the proposed development. Importantly, the site is beyond the Registered Park and Garden and has limited intervisibility with the castle. The setting of the castle and RPG assets is not considered to be a major constraint to the deliverability of the site. Likewise, the setting of the Grade II Listed Oaks Farmhouse is not considered to be a major constraint to development within the site, which is little visible from the asset, views from which are focused to the west of the site. SA Objective 6 Pollution: It should be noted that mitigation is achievable for air quality impacts, including for example additional tree planting, installation of electric vehicle charging points and increased use of public transport through sustainably located development, such as at this Site. SA Objective 7 Natural Resources: The site is shown on Natural England mapping as Grade 3 agricultural land of good to moderate quality and immediately adjacent to land the is predominantly in urban use, being Kenilworth urban area. SA Objective 8 Waste: A development of 300 houses would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. SA Objective 10 Health: The site is accessible by modes of transport other than the private car which provide sustainable access to health services and facilities. There would be open space on site, and retention of the existing public right of way and enhancements for pedestrians and cyclists would be incorporated. SA Objective 11 Accessibility and 12 Education: The site is accessible by all forms of transport and development of the site could support and enhance bus services. There are also various local services and facilities in the immediate surrounds as referred to. Oaks Farm would be within 1km of facilities including two primary schools, a sixth form, local retail facilities including a post office and allotments. There would also be opportunities to enhance connectivity by bus to and from the site, which will be explored as part of preapplication discussions with the Local Authority and relevant operators, which may include the diversion of existing bus services into the site. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Kenilworth in the immediate vicinity and also beyond through transport links.