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.
5. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 6. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. There are other settlements, such as Stockton, which should be included on the list. 7. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 8. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 9. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 10. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
Please see attached form for detailed comments on this.
7. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 8. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. Having said this, Richborough Estates is fully supportive of Wellesbourne being a chosen Small Settlement Location for growth. 9. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 10. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 11. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 12. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
7. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 8. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. Having said this, Richborough Estates is fully supportive of Kineton being a chosen Small Settlement Location for growth. 9. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 10. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 11. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. At Paragraph 5.6.5 the SA states that “The location at Kineton has the potential to also adversely impact the Cotswolds AONB and therefore this location is worst performing overall”. However, factually it is hard to understand this assessment given the AONB is some 4 kilometres from Kineton and for a large part MOD Kineton is in between the settlement and the boundary of the AONB. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 12. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
5. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 6. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. Having said this, Richborough Estates is fully supportive of Hampton Magna being a chosen Small Settlement Location for growth. 7. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 8. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 9. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 10. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
5. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 6. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. Having said this, Richborough Estates is fully supportive of Bidford-on-Avon being a chosen Small Settlement Location for growth. 7. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 8. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 9. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 10. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
The Beaudesert and Henley-in-Arden JPC have informed us that the SWLP are considering 500-2000 houses in Henley-in-Arden. Why is this the case when the sustainability appraisal has identified Henley as a small settlement location for between 50-500 homes? There is nothing in the sustainability appraisal which supports Henley being singled out for growth comparable to a broad location. On a map from a distance Henley looks to have good connectivity with access to bus stops and railway station but these services are poor with infrequent and unreliable train and bus service. Henley has been shown to actually have poor connectivity (5.13.4) thus car usage would increase on the already very congested road. Due to the local topography, railway, river, and listed buildings there is little opportunity to improve the road layout. SWLP has no apparent plans to improve infrastructure, leaving this on a local level or to the developers which is not adequate. Henley is the only small settlement shown to have more that 50% of land within flood zone 2. (5.4.2). Being in a valley, Henley already flash floods with the roads becoming impassable frequently in winter months. Risk of flooding will likely increase due to global warming with more extreme weather events. The heavy clay soil bakes hard in summer and completely saturates in winter with a high-water table, creating perfect conditions for increased surface run off year-round. Development would increase surface run off, particularly development of proposed site currently used for growing Christmas trees which of course creates natural flood defence. How would developers prevent increased flood risk? Existing drainage is not sufficient to accept further volumes, the river frequently bursts its banks already and use of soakaways is ineffective due to the nature of local heavy clay soil and high water table, retention ponds would fill in winter and then be ineffective. Increasing building in Henley will certainly contribute to adverse events. 2.9.7 Acknowleges water quality will be affected if infrastructure is not put in place and yet the SWLP has no plan to put infrastructure in place. This is at odds with your vision and objectives. 2.6.10 Protected species survey information has not been used and there is no plan to assess this in more detail until after the plan has been adopted. How then does the SWLP think it can decide where to build the most houses in the most sustainable way for biodiversity if it had no information of where endangered species are. 2.9.6 admits development near watercourses will potentially impact the banks and water quality with the suggestion in 2.9.7 that developers can voluntarily provide additional measures to protect water quality. Given developers focus on profit this is not good enough. The river Alne which runs through Henley has a population of endangered white-clawed crayfish. Sustainability appraisal has failed to recognise Henley has a local nature reserve 5.5.4 – Henley sidings nature reserve would likely be impacted by some of the proposed sites for development. Based on the evidence Henley is not suitable for growth over 500 houses. More information is needed about the local services and environment to establish appropriate lower numbers of proposed development. I am concerned that NOT reviewing the green belt hasn’t been considered as an option.
Issue 11; Sustainability Appraisal. QI-1. At this stage of the plan process and given a lack of more detailed evidence base on some relevant matters the Chamber does not support or endorse a specific growth option. However as set out the Chamber does favour adoption of growth options that promote sustainable development across the whole plan area and options which give prominence to the importance of developing the local economy of the sub region.
The South Warwickshire authorities state that “at this stage is it is difficult to identify stand out best performing options because they all perform best for different SA Objectives and rarely does one option emerge as a best overall option”. It should however be noted, that at this stage the assessment does not consider any mitigation which could have the effect of minimising any adverse impacts. Potential New Settlement Locations Figure 11, below, sets out how each of the potential new settlement locations performed within the Sustainability Appraisal (SA). The reference for Hatton is B1. Paragraph 6.16.1 of the SA provides a summary of findings for the potential new settlement locations and states that “the assessment of each indicator cannot be ‘added’ to create an overall score as this would be give a misleading indication of the level of impacts and the potential for mitigation. The summary table illustrates the worst performing indicator under each Objective.” Whilst Hill Residential support the overall approach to the SA, it is considered that the area of search identified in grey at section D.3 for Hatton is relatively small and should be increased in order to assess the correct scale of development required for a new settlement – this in turn would incorporate all land being promoted at Hatton New Community. We note that the mitigation potential for Hatton for the majority of the objectives and subsequent receptors state that mitigation is possible (M) or not required (-). The exception to this is ‘SA Objective 7: Natural Resources’ where the mitigation potential has been identified as “mitigate(M)/not possible (X)”. The proposed mitigation within the full assessment for Hatton for SA Objective 7 is generally supported and it is considered that any proposed locations for growth would score the same in relation to Agricultural Land and Mineral Safeguarding areas. Further work is now required to fully consider the potential mitigation for each of the new settlement locations and re-run the assessments. This will allow for further decisions to be made regarding the most appropriate location for a new settlement. This stage of works should be underpinned by suitable evidence-based documents and should be completed ahead of the Preferred Options consultation.
5.1 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 Regulations15 (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. 5.2 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. 5.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) and provide 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 5.4 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. 5.5 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. 5.6 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. 5.7 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. 5.8 Similarly, the SA Framework is highlighted in some chapters as being used to appraise some 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. 5.9 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. 5.10 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 (see IO SA Appendix E) nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potentialmitigation 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. 5.11 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 has not appraised any such contribution, or undertaken any appraisal of possible locations where such unmet could be accommodated. This brings into play consideration of other locations which are located in close proximity to the local authorities with the Greater Birmingham and Black Country HMA, notably on the edge of Redditch. 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 a suitable policy response should also be presented in the draft (preferred options) version of the SWLP. SA of Housing Number Options 5.12 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). 5.13 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. 5.14 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. 5.15 Determining the overall scale of housing growth to be planned for in South Warwickshire is a key requirement of the 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 to a lack of consistency and transparency in approach across the various options appraisals, which risks undermining the SA process. 5.16 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. 5.17 The HEDNA analysis points to different, higher household growth projection for the South Warwickshire authorities which takes into account 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. 5.18 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. 5.19 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. 5.20 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, which RPS has been commented on elsewhere in this submission (under Issue S4). It is worth reiterating again that the published evidence shows a significant shortfall in land availability within existing urban areas across South Warwickshire that will need to be tackled as the SWLP process moves forward. RPS broadly agrees with this position. SA of Small Settlement Locations 5.21 Chapter 5 of the IO SA appraises 22 alternative Small Settlement Locations where between 50 and 500 homes could be directed. RPS notes that locations around Bidford have been identified as reasonable alternative small settlement locations, which is welcomed. As shown in Figure 5.1 of the IO SA and in more detail in Appendix C of the IO SA in Figure C.3.1 which is shown below, the site is included within the area identified as potentially suitable for development. Appendix C of the IO SA provides an individual appraisal of all of the land identified as being potentially suitable as a small settlement location at Bidford, with the approximate location of the Kings Meadow Phase 2 site indicated by a red star 5.22 Whilst RPS recognise that the IO SA is an early stage in the overall SA process it is not clear, apart from reducing the workload of the team preparing the SA, what the value is of ‘lumping together’ for the purposes of assessment various potential sites at locations considered potentially suitable for accommodating small settlement locations. In particular, the performance of individual parcels of land will differ against the SA objectives. Notably the Settlement Design Analysis document included within the Technical Evidence for the IO consultation considers individual sites on a more granular basis. 5.23 Specifically in relation to the Kings Meadow Phase 2 site and the assessment of all potential sites at Bidford-on-Avon a number of the conclusions drawn for the wider area are not applicable to the site in isolation. Furthermore, RPS contend that in some aspects the scoring of the general options is inaccurate. Set below is further commentary on each objective. SA Objective 1: Climate Change 5.24 It is unclear that the general assessment for this objective has taken into account the forthcoming introduction of the Lifetime Homes Standard in 2025. RPS suggest that when this is considered that rather than scoring as a minor adverse affect that new developments should be assessed as being neutral. RPS note as well that in principle the delivery of new homes built to the updated standards is preferable to the alternative of potential overcrowding of existing homes built to less stringent standards in the past that perform poorly in terms of energy efficiency. SA Objective 2: Flood Risk 5.25 RPS note that settlements where all of the land considered falls within Flood Zone 1 have been assessed to have a positive impact on flood risk, whereas locations where some land falls within Flood Zones 2 or 3 are considered to have a negligible impact on flood risk. The Kings Meadow Phase 2 site is solely located in Flood Zone 1 and so on this basis when assessed alone should score as having a positive impact on flood risk. 5.26 On page 15 of the Officers Report for the phase 1 scheme to the south of the site in relation to flood risk it states: “The site is located within Flood Zone 1 (lowest risk of flooding) where residential development is considered acceptable in principle by the NPPF in relation to flood risk.” 5.27 The NPPF continues to support residential development on land within Flood Zone 1. SA Objective 3: Biodiversity 5.28 The assessment for Bidford-on-Avon set out in Appendix C to the IO SA highlights that there are Local Wildlife Sites within the wider area assessed as a potential Small Settlement Location. RPS have reviewed the digitally mapped Local Wildlife Sites available as additional information on the interactive ‘Call for Sites’ map16. There is a Local Wildlife Site that is associated with Small Brook, which runs along the northern boundary of the site. It is clear that development of the site could be undertaken in such a way as to not adversely impact on this Local Wildlife Site, and in fact could offer opportunities for it to be improved. 5.29 The other factor cited under this objective set out in Appendix C to the IO SA relates to priority habitats. RPS have used DEFRA’s magic maps17 service to undertake a desktop assessment of whether there are any priority habitats identified on the site. As is shown below, there are no priority habitats identified on the site. 5.30 RPS consider that the development of the site in isolation should be assessed against this objective as a minor positive. SA Objective 4: Landscape 5.31 As set out in the accompanying vision document (see Appendix A) the Council’s 2011 Landscape and Visual Impact Assessment indicates that “…Housing development could be accommodated south of Small Brook in order to be screened from the wider landscape and to be consistent with the existing housing edge...” 5.32 In this regard, the Kings Meadow Phase 2 site is located to the south of Small Brook and in a location which has therefore been assessed as being able to accommodate future growth without further landscape evidence being required. This is in contrast to other sites assessed collectively as the Small Settlement Location which include areas of land that have been assessed as being of ‘high -medium’ landscape sensitivity, and which could lead to coalescence if not developed sensitively. Given that this does not apply to the Kings Meadow Phase 2 site RPS suggest that a neutral assessment against this objective is appropriate. 5.33 The Officers Report for the planning application for the phase 1 development states on page 12: “I concur with the findings of the Landscape Sensitivity Assessment that long distance views of the site are limited and that development of the land will have limited impacts on the landscape character of the area with medium scale visual impacts, subject to appropriate structural landscaping along boundaries of the site, which the submitted Parameters Plan achieves. I also take note of the comments of the MADE Design review Panel who consider that if there is to be more development in Bidford it makes sense to build in the gap formed by the ribbon developments of Waterloo Road and Victoria Road, and that the proposals would have the advantage of creating a much better northern edge to the settlement.” (RPS emphasis) 5.34 It is suggested that these comments on landscape are also relevant to the site. SA Objective 5: Cultural Heritage 5.35 The Small Settlement Location at Bidford-on-Avon includes land that if developed could have impacts upon: • A Grade I Listed Building • A Grade II Listed Building • A Conservation Area • A Scheduled Ancient Monument 5.36 However, the development of the Kings Meadow Phase 2 site would not have any adverse impacts on any of the designated heritage assets as they are screened from the Site by intervening built development and the local topography. The development of the land to the south of the Site has further lessened any potential impacts on the Listed Buildings and Conservation Area to the south. RPS consider that a neutral assessment against this objective is appropriate for the Kings Meadow Phase 2 site. SA Objective 7: Natural Resources 5.37 RPS note that as set out at paragraph 5.9.2 of the IO SA that the loss of more than 20 ha of Best and Most Versatile land would be considered to be a major adverse impact. However, in isolation the development of the site would be just 4.2 ha meaning that it follows that the assessment of the site should be minor adverse against this objective. SA10: Health 5.38 RPS note the variability of assessment of the Small Settlement Locations against this objective. However, it is unclear how Hatton Station, which only have a positive impact against a single criteria can be scored the same as Bidford-on-Avon, which receives a number of minor positive assessments against different sub criteria, as well as a major positive against one sub criteria. It is suggested that Hatton Station should not be scored so favourably against this objective. 5.39 Bidford-on-Avon scored three minor positive assessments as well as one major positive and one neutral against the sub criteria for this objective. In contrast it was only given two minor negative assessments. On balance it is suggested that overall a minor positive assessment is a more appropriate assessment of Bidford-on-Avon. SA11: Accessibility 5.40 It is assumed that the Settlement Design Analysis has been used to inform the assessment against the sub criteria for connectivity. As set out earlier the assessment for the Kings Meadow Phase 2 site is contested as it does not account for access via Miller Homes’ phase 1 development to the south. The site has good connectivity when this is taken into consideration. 5.41 It is suggested that a minor positive assessment is appropriate for the Kings Meadow Phase 2 site in isolation. Overall Assessment of Kings Meadow Phase 2 in isolation 5.42 Set out below is RPS’ overall assessment of Kings Meadow Phase 2 in isolation compared to the assessment of the combined sites at Bidford-on-Avon as a Small Settlement Allocation IO SA Of Bidford SA1: Climate Change - SA2: Flood Risk 0 SA3: Biodiversity - SA4: Landscape - SA5: Cultural Heritage - SA6: Environmental Pollution - SA7: Natural Resources -- SA8: Waste - SA9: Housing ++ SA10: Health - SA11: Accessibility - SA12: Education - SA13: Economy + RPS of Kings Meadow Phase 2 SA1: Climate Change - SA2: Flood Risk + SA3: Biodiversity + SA4: Landscape 0 SA5: Cultural Heritage 0 SA6: Environmental Pollution - SA7: Natural Resources - SA8: Waste - SA9: Housing ++ SA10: Health + SA11: Accessibility + SA12: Education - SA13: Economy + 5.43 When considered in isolation the Kings Meadow Phase 2 site performs far more positively than when considered as part of the wider Small Settlement Location at Bidford-on-Avon. 5.44 RPS recommends that a finer grain of assessment should be carried out to inform consideration of the quantum growth to be assigned to each ‘Small Settlement Location’, as well as consideration of potential non-strategic site allocation options at Bidford-on-Avon as part the Part 2 SWLP. SA of New Settlement options 5.45 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. 5.46 Paragraph 3.8.1 of the IO SA states that the seven new settlements locations have been identifiedby the two Councils. The commentary in the IO document under Issue S5 (on page 49) points tothese 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). 5.47 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 be applied 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. 5.48 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 5.49 Details of the SA assessments of the five spatial growth options are set out in Chapter 7 of the IO SA. RPS notes there is no accompanying detailed appraisal in the SA appendices. 5.50 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 that 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. 5.51 RPS has provided a response to the spatial growth options, under Issue S7, in respect of Bidford-on-Avon where Kings Meadow Phase 2 is being promoted by Miller Homes. The submissions highlight that Bidford-on-Avon is identified under the ‘Sustainable Travel’, ‘Economy’ and ‘Sustainable Travel and Economy’ options, as well as the ‘Dispersal’ option. In this context, there is nothing presented in the IO SA which indicates that growth should not be directed to Bidford-on-Avon on sustainability grounds. To the contrary, directing growth to Bidford-on-Avon would support a number of spatial options that are shown to perform relatively well in sustainability terms. 15 The Environmental Assessment of Plans and Programmes Regulations 2004 (No. 1633) 16 https://soadc.maps.arcgis.com/apps/webappviewer/index.html?id=c9f9579706974081a054de1b14a66130 17 https://magic.defra.gov.uk/MagicMap.aspx
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 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.
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.
3.1 NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 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 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.
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 Stratfordon-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 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.
I’m concerned about the HEDNA sustainability process. Broadly this models growth between the 2011 and 2021 and it assumes that areas that have taken higher household growth will replicate this into the future. This disproportionately skews the process for areas that have taken high concentrated growth (such as a new settlement). This is not organic growth. Although some of the HEDNA figures in the proposal will be met within the end of the Core Strategy (up to 2031) this is not clear how much this will account for. The HEDNA identifies a requirement for higher housing provision than the identified housing need to meet unmet needs from both Coventry & Warwickshire and the Greater Birmingham areas. Geographically these needs should be met from Northern SWLP areas (mostly designated as Green Belt) to genuinely meet these needs.
Bellway 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 Stratford upon Avon, Bellway 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. Bellway would also firmly agree with the assertions in section 4.15, which cumulatively at paragraph 4.15.1 point to Stratford upon Avon East (B.25) as being the best performing option out of the five alternatives assessed for the town as it is the least constrained in terms of environmental receptors. Bellway’s land north of Loxley Road, Stratford upon Avon falls within Stratford upon Avon East (B.25).
2.2. Sustainability Appraisal In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives. The Councils should ensure that the results of the SA process clearly justify their policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the South Warwickshire Local Plan’s decision-making and scoring should be robust, justified, and transparent
The SA identifies a list of ‘small settlements’ which could accommodate 50-500 dwellings. The process undertaken to identify these settlements, which is detailed at Section 3.7 of the Sustainability Appraisal is supported and ensures that the most sustainable and suitable settlements, including Kineton, are identified. Appendix C.12 details the Sustainability Appraisal for Kineton. A minor negative impact on the setting of the Cotswolds AONB is identified due to the settlement’s proximity to the AONB. It is noted that the extent of the area identified around Kineton is located 3km away from the boundary of the AONB. This is a significant distance. It is to be a ‘flat’ distance and does not take account of any intervisibility (or lack thereof) between Kineton and the AONB. In any event, any development at Kineton, a minimum of 3km from the AONB will be viewed against the existing built form of Kineton. It is considered that given the closest distance between the AONB and Kinet on, the impact on the AONB should be assessed as neutral . Notwithstanding this, it is noted in the Sustainability Appraisal that any impact would be able to be mitigated against. Kineton is identified as being located 962m from the Feldon Parkland Special Landscape Area (SLA). As such, it is identified simply that there may be ‘potential for minor negative impacts associated with development in this location’ . This is purely a desk-based assessment and does not take account of local topography. Notwithstanding this, it is considered that the distance of the edge of Kineton from the SLA is sufficient that there will not be an adverse impact on its setting. As such, the impact on the SLA should be assessed as neutral . Notwithstanding this, again, it is noted in the Sustainability Appraisal that any impact would be able to be mitigated against. Under access to leisure facilities, a minor negative effect is identified due to the distance between Kineton and Wellesbourne Sports and Community Centre. However, there are other leisure facilities located within Kineton which are not taken into consideration, such as the village hall and the sports hall at Kineton High School which has facilities for hire including badminton, football and netball courts. As such, it is considered that the impact should be assessed as minor positive. Notwithstanding this, it is noted in the Sustainability Appraisal that any impact would be able to be mitigated against. In terms of access to PRoW and cycle networks, the Sustainability Appraisal states that the settlement is located within the target distance for these networks. As such, it is considered that this should be assessed as a major positive impact given that the entire settlement is within the target distance. In terms of education facilities, there is a primary and a secondary school, which also offers post -16 education, located within Kineton. Paragraph 5.14.4 of the Sustainability Appraisal states that Kineton is one of the two best performing small settlements for access to education facilities with ‘good sustainable access ’ to primary, secondary and post-16 facilities. As such, it is considered that the impact should be major positive , as opposed to minor positive as stated in the Sustainability Appraisal. It is noted that for the vast majority of the identified minor and major negative effects at Kineton, mitigation measures are identified.
The SA identifies a list of ‘small settlements’ which could accommodate 50 -500 dwellings. The process undertaken to identify these settlements, which is detailed at Section 3.7 of the Sustainability Appraisal is supported and ensures that the most sustainable and suitable settlements, including Bishop’s Tachbrook, are identified. Appendix C.4 details the Sustainability Appraisal for Bishop’s Tachbrook. The Tach Brook (a tributary of the River Avon) flows along the northern and eastern boundaries of this small settlement location. On this basis, there is potential for surface water run-off associated with new development and a minor negative effect identified. However, any future development would need to be mitigated and national policy sets out that local planning authorities should ensure that flood risk is not increased elsewhere. We therefore consider that this should be assessed as neutral . In terms of natural resources, the Sustainability Appraisal identifies agricultural land classification as a minor negative effect, however, this is based on an assumption that grade 3 land will not be split as 3a and 3b. It is unclear why the Council have assumed a blanket grade 3 approach as there is the relevant information available to identify this site as 3b. We therefore consider that this should be assessed as neutral . Under access to leisure facilities, a minor negative effect is identified due to the distance between Bishop’s Tachbrook and St Nicholas Park Leisure Centre. However, there are other leisure facilities located within Bishop’s Tachbrook which are not taken into consideration, such as the sports and social hall which has an all-weather pitch. As such, it is considered that the impact should be assessed as minor positive . Notwithstanding this, it is noted in the Sustainability Appraisal that any impact would be able to be mitigated against. In terms of accessibility, a minor negative effect is identified for local services. However, there are local services located within the village including a primary school, local shops, doctors surgery and public house. There are also bus links to Leamington Spa, Gaydon, Stratford-upon-Avon and Banbury. As such, it is considered that the impact should be assessed as neutral . Notwithstanding this, it is noted in the Sustainability Appraisal that any impact would be able to be mitigated against. It is noted that for the vast majority of the identified minor and major negative effects at Bishop’s Tachbrook, mitigation measures are identified. As well as the illustrative masterplan at Appendix 2, a whole suite of technical information was also produced as part of the previous planning application (reference: W/16/2076). Whilst some of this information might require updating, it is helpful to demonstrate the site's suitability and deliverability. This previous planning application was refused on the basis of the principle of development not being acceptable (with the site not allocated for development within the emerging Local Plan) and cumulative landscape given the amount of development that has recently been approved (at the time of determining the planning application). In addition to the strong credentials for Bishops Tachbrook to take its fair share of future housing growth, we believe that that Sharba Homes’ site is the next most logical and sustainable candidate for allocation/release for the following reasons. The previous Landscape Sensitivity Appraisal dated 2011 by the Council identified the area of the main housing allocation (H23) south of the village as being within “highly sensitive landscape”, but its designation as such was as part of the large and over-generalised landscape sub-area BT05, which was classified by its most sensitive areas despite containing lower ones. This was re-appraised in more detail to identify that the specific area within it adjacent to the settlement where H23 was proposed was naturally less sensitive than elements further into open countryside, and again the same re-consideration was undertaken for sub-area BT03 to allocate site H49. These precedents are exactly the approach that should be undertaken to allow suitable re-assessment of other overly generalised broad landscape parcels e.g., BT06, that are not overridden by heritage or strategic gap concerns as additional constraints e.g. parcels BT01 and BT02, in order to identify the least sensitive and thus most appropriate areas for future growth. The Council’s latest Landscape sensitivity appraisal from 2011, at paragraph 4.14 states that landscape should be protected, “particularly those areas identified as highly sensitive to future housing development”. The Site should be re -assessed now that site H23 has been developed, as it now contains very similar characteristics to the developed site H23 itself on the opposite side of the road and is now much more urban in its backcloth with the adjacent and elevated development of H23, and thus is naturally reduced in landscape sensitivity. Parcels H23 and H49 were re-assessed and released in exactly this way on the more detailed approach suggested. No other site in the village is either constrained by landscape alone, or had its sensitivity reduced in this way, and thus we believe it to be the least sensitive/constrained site that should logically be considered the next preferred option for an allocated / reserve site for sustainable growth in the village in line with NPPF paragraph 11 and NPPG paragraph 009. Landscape issues were cited, but the site now lies between housing to the north and a new raised housing development to the west completed by Bloor Homes. Bishop's Tachbrook is one of only 3 of the 8 major villages in Warwick District Council that is not in Green Belt and should play a role in accommodating future housing need. Every direction around Bishop's Tachbrook is sensitive to landscape, heritage and strategic gap issues. This site is the only direction that only has landscape as a constraint, which is locally diminished by the new Bloor Homes development, and is therefore the most sustainable location for the next phase of housing growth in the village.
Reasonable Alternatives: The reasonable alternatives do not consider developments less than 50 dwellings. This appears to be an arbitrary and an unreasonably high threshold apparently excluding proper consideration of the potential offered on smaller sites such as that at Chessetts Wood Road, Lapworth.
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.
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
Issue I1 - I do not feel that the sustainability appraisal goes far enough, as the flood impact assessment only includes the impact of flooding at new sites, it does not address the impact of flooding from new development at other sites. This is particularly concerning since several of the proposed development areas are in the watershed of the Finham Brook, which already causes issues with flooding locally.
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 Plan and Sustainability Appraisal use the term Mitigate as a solution to lessen the impact of particular effects. In a number of cases, this term seems to have been used without a solution in mind, and in the TTG’s view, in several cases mitigation would not be possible, or would be economically unviable. In the TTG’s view, the focus should be on good planning including transport planning, which would deliver a comprehensive Local Plan, and therefore not need mitigation.