Q-S5.1: Please provide any comments you have on the emissions estimation modelling for the seven potential new settlement options?

Issue S5: The potential for new settlement(s) 3.33 The IO document now identifies a number of potential locations for new settlements across South Warwickshire. These have been derived from a two-part process; part 1 seeks to identify ‘areas of search’ based on existing or potential access to rail services outside existing urban areas. Based on the approach, seven areas (A-G) have been identified, illustrated on Figure 12 of the document. These comprise broad areas that do not specific sites or specific locations; part 2 applies a ‘very high-level assessment’ of the areas of search, from which seven potential new settlement locations have been identified. A summary of the assessment of each location is shown in Table 6 of the IO document. Each of these seven locations has also been subjected to Sustainability Appraisal (to RPS responses under Issue I1) and Climate Change Emissions Estimation modelling. 3.34 Whilst some assessment work has been undertaken to date, the IO document acknowledges that further detailed work is required before any preferences for any particular new settlement location can be made, or whether a new settlement is suitable, viable and deliverable in principle. RPS broadly agrees with this point. Q-S5.1: Please provide any comments you have on the emissions estimation modelling for the seven potential new settlement options 3.35 As part of the evidence to inform the Local Plan, an operational carbon model has been developed to assess carbon emissions at a strategic level and test how the development of the seven potential new settlement locations. RPS notes the model is based on current Government and existing Local Plan policies. Further information on the modelling work is set out in Estimation of emissions for proposed growth options and new settlements study dated November 2022. RPS has reviewed this study and wishes to raise a number of points on the approach. 3.36 Firstly, paragraph 1.1 of the study states that the options tested in the modelling all assume 35,000 dwellings will be delivered between 2025 to 2050. This differs from the level of growth assumed under the ‘trend-based’ projected need for South Warwickshire, which RPS calculates at 41,975 dwellings over this period (applying the 1,679 dpa taken from Table 9 of the IO document). It should, also be noted that if the plan period extended to 2055, this would further increase the scale of housing need across the Plan area. However, the study does not include any testing against the preferred housing need scenario, or the potentially higher growth based on a longer plan period. Whilst the projected emissions are likely to be sensitive to higher levels of growth, it is nevertheless important that there is consistency across the analysis to ensure the policy choices are properly informed. 3.37 And secondly, chapter 5 of the study provides some commentary on the methodology underpinning the modelling of the options. Sub-section 5.3.2 lists a number of ‘key inputs’ for the site related modelling. This includes specific reference to ‘Energy efficiency benchmarks such as Part L 2013, Interim Future Homes Standard 2021’ (RPS emphasis). However, as outlined by the Government7, from 2025 new homes built to the Future Homes Standard will have carbon dioxide emissions at least 75% lower than those built to current Building Regulations standards, and all homes will be ‘zero carbon ready’, becoming zero carbon homes over time as the electricity grid decarbonises, without the need for further costly retrofitting work. Whilst the study refers to current building regulations standards under interim changes to Part L introduced in 2021, the study will need to reflect on the further tightening of the regulations and the move to the full Future Homes and Future Buildings Standards that are expected in 2025. 3.38 The introduction of the 2025 Future Homes Standards is expected to improve energy efficiency, reducing the demand for energy and so reduce carbon emissions in residential buildings. RPS recommends that the study is updated to reflect projected reduction of emission by 75% compared to current (2012) regulations. 3.39 For these reasons, RPS recommends that the Climate Change Emissions study should be updated to properly reflect the growth aspirations for South Warwickshire as well as reflect the broad direction of travel on tackling carbon emissions regarding future changes to building regulations and the impending implementation of the Future Homes and Buildings standards. 7 The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings Summary of responses received and Government response, January 2021

2.3 Response: It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.’ [emphasis added] 2.4 Therefore, albeit referring to capacity for housing land, the Council(s) evidence base clearly demonstrates the need for the release of greenfield land.

No. We are of the view that new settlements should not be part of the overall strategy for the following reasons; • Due to the level of infrastructure required, new settlements can take years to come forward before housing can be delivered. This can seriously jeopardise the ability of the local plan to deliver both open market and affordable homes across the District for which there is a critical need. A study by Lichfields entitled “Start to Finish” (2016) highlights the problems associated with large scale development and compares them against delivery times for smaller developments. It highlights several examples of new settlements (2,000-3000 dwellings at Cambridge University). On average it took 10 years for the final schemes to be approved following allocation in the Local Plan (following outline and various reserved matters applications). The report did not go on to consider discharge of conditions applications/variations which actually may also delay the ability deliver the approved dwellings. This compares to smaller scale schemes which on average took 8 years. • The report states that large sites, which are not likely to deliver quickly, are also unlikely to be contributing to five year housing land supply calculations. The strategy should include small and medium sites which the Framework acknowledges can make an important contribution to meeting the housing requirement. • The reliance on new settlements within the strategy will also result in an inherently inflexible plan – which relies on the delivery of fewer but larger sites with multiple land owners. Coming to agreement over land value and sequencing of delivery are likely to be other factors which can delay the scheme which ultimately may result in developers having to contribute more to the infrastructure (drainage/highways etc) which will impact on viability, potentially at the expense of affordable housing provision. • It is for these reasons that several plans relying on large new settlements have failed – Uttlesford DC withdrew their plan due to the Inspector not being persuaded that evidence demonstrate the Garden Communities and overall spatial strategy had been justified. North Essex had similar problems with their proposed Garden Communities, which had to be removed from the Joint Local Plan before the Inspector found the Plan sound.

Claverdon does not have access to the competences that would enable it to respond to this question meaningfully.

Wherever possible ensure opportunities for sustainable and active travel are baked into plans

2.34 Climate change mitigation (S5.1 and S7.1) 2.34.1 The evidence in relation to Carbon dioxide emissions requires further justification. The study appears to make assumptions about factors like the take up of electric vehicles (EVs) and the rate of retrofitting of existing buildings under each of the growth options. These assumptions appear to have a significant bearing on the emissions associated with each option. For example, operational building emissions are assumed to decrease at a slower rate under the Rail Growth option but the rational for this is not explained: “Transport and operational buildings emissions slowly decrease in the Rail growth option in line with the decarbonisation of the national grid as shown in Figure 4 and Figure 5, however operational buildings emissions decrease at a slightly slower rate than other growth options.” 2.34.2 As noted above, take up rates for Electric Vehicles also vary by scenario, e.g. “In terms of transport emissions, long and short distance trip car mode share reduction in 2050 was assumed to be 8% (Table 4) compared to 10% in the Rail option, as more new settlements were assumed to still be on the road network, slightly higher private car use is still assumed. With a higher private car reliance assumed, naturally higher EV uptake rates were assumed as shown in Table 4. Ultimately the higher EV rates meant that ‘Car driver’ emissions began to fall in-line with the carbon intensity of the grid which meant that total transport emissions fell at a faster rate despite ‘Car driver’ still taking up the highest percentage of the transport mode split by 2050.” 2.34.3 The assumptions underpinning the evaluation of the options therefore require greater justification.

As part of the evidence to inform the Local Plan, an operational carbon model has been developed to assess carbon emissions at a strategic level to test how the development of the seven potential new settlement locations perform in terms of carbon emissions. RPS notes the model is based on current Government and existing Local Plan policies. Further information on the modelling work is set out in Estimation of emissions for proposed growth options and new settlements study dated November 2022. RPS has reviewed this study and wishes to raise a number of points on the approach. 3.25 Firstly, paragraph 1.1 of the study states that the options tested in the modelling all assume 35,000 dwellings will be delivered between 2025 to 2050. This differs from the level of growth assumed under the ‘trend-based’ projected need for South Warwickshire, which RPS calculates at 41,975 dwellings over this period (applying the 1,679 dpa taken from Table 9 of the IO document). However, the study does not include any testing against the preferred housing need scenario. Whilst the projected emissions are likely to be sensitive to higher levels of growth, it is nevertheless important that there is consistency across the analysis to ensure the policy choices are properly informed And secondly, chapter 5 of the study provides some commentary on the methodology underpinning the modelling of the options. Sub-section 5.3.2 lists a number of ‘key inputs’ for the site related modelling. This includes specific reference to ‘Energy efficiency benchmarks such as Part L 2013, Interim Future Homes Standard 2021’ (RPS emphasis). However, as outlined by the Government6 , from 2025 new homes built to the Future Homes Standard will have carbon dioxide emissions at least 75% lower than those built to current Building Regulations standards, and all homes will be ‘zero carbon ready’, becoming zero carbon homes over time as the electricity grid decarbonises, without the need for further costly retrofitting work. Whilst the study refers to current building regulations standards under interim changes to Part L introduced in 2021, the study will need to reflect on the further tightening of the regulations and the move to the full Future Homes and Future Buildings Standards that are expected in 2025. 3.27 The introduction of the 2025 Future Homes Standards is expected to improve energy efficiency, reducing the demand for energy and so reduce carbon emissions in residential buildings. RPS recommends that the study is updated to reflect projected reduction of emission by 75% compared to current (2012) regulations. 3.28 For these reasons, RPS recommends that the Climate Change Emissions study should be updated to properly reflect the growth aspirations for South Warwickshire as well as reflect the broad direction of travel on tackling carbon emissions regarding future changes to building regulations and the impending implementation of the Future Homes and Buildings standards. Q-S5.2: Do you think new settlements should be part of the overall strategy? 3.29 RPS wishes to reiterate its position that it does not object to new settlements forming part of the development strategy in principle. Nonetheless, RPS suggests that caution should be applied in considering new settlements as part of a broader strategy for distributing growth in South Warwickshire. This is because unforeseen issues can occur that can delay progress on new settlement / strategic allocations, for example in Stratford-upon-Avon. In this case, the Core Strategy allocated two new settlements at Gaydon/Lighthorne Heath (2,300 homes) and Long Marston (2,100 homes), 30% of the adopted housing requirement of 14,600 dwellings. However, since 2011 (the base date of the current plan) these two new settlements have only delivered 343 dwellings, just 3.4% of the total housing delivered in the district up to April 20227 , in contrast to the evidence presented to the Stratford Local Plan Inspector, that provided a trajectory for each site to have substantially more completions at this stage. The distribution strategy should therefore also ensure that the needs of local communities can be met through smaller development directed and brought forward at established JBB8692.C8271 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 11 sustainable settlements that can be delivered relatively quickly, and thus a greater mix of different sized sites should be encouraged to deliver a significant proportion of the required growth in the SW area over the plan period.

The estimation modelling has assumed that each of the new settlement option would deliver 6,000 homes and 30 hectares of employment. Whilst this assists in providing like for like conclusions, it does not provide a true picture of actual potential emissions arising from each location. The overall scale and potential to deliver key infrastructure will significantly impact the overall assessments for emissions. It is noted that some internalisation of trips have been considered as part of the 20- minute neighbourhood considerations. However it is considered that significant further analysis is required in order to fully understand how each of the options performs. Hatton New Community will be designed to keep people within the Site for purposes such as work, education, retail, leisure and socialising, rather than residents having to leave the new community– therefore reducing the number of external trips. An Internalisation and Containment Note has been prepared by Vectos (part of SLR) and is enclosed at Appendix 3. The Internalisation Note demonstrates the potential to deliver a successful and thriving new community at Hatton. Large-scale development prospers when designed in a coordinated manner, with the key placemaking and mobility features providing for truly socially inclusive communities that prosper and retain trips within the Site. In the case of Hatton New Community, local living is placed as the highest priority, followed by a movement hierarchy with convenience of single occupancy vehicular travel at the bottom. This creates an environment wherein local trips are encouraged and the effect of the development on the local highway network is minimised in terms of traffic impact. Development at Hatton New Community will enhance the existing range of shops and services and leisure facilities, and provide additional employment space, primary and secondary education along with mobility hubs, including open space. These all contribute to the internalisation of trips. The following will be provided to encourage internalisation: • Local Employment & Office space; • Home working facilities including broadband and local shops / cafés for lunches; • Co-working Hub providing access to hot-desks, Wi-Fi, and other office equipment. • Education including two primary schools, a secondary school and a Day Care; • Shopping (physical & online); • Supermarkets/Convenience Stores including home delivery; • Health: An on-site pharmacy and surgery; • Leisure: an array of leisure facilities ensuring that the first choice for the majority of recreation and sports activities will be within the village itself. • Greenspaces: parklands, attractive footpaths, jogging routes and places for dog walking; • Pub: A new local pub will be a focal point for socialising, food and entertainment; • Community Hubs / Recreational activities; • Allotments: For residents to grow their own flowers, fruit and vegetables. The south Warwickshire authorities are encouraged to progress the Emissions Estimations further prior to developing the Preferred Options consultation document for the SWLP.

4.25 As part of the evidence to inform the Local Plan, an operational carbon model has been developed to assess carbon emissions at a strategic level to test how the development of the seven potential new settlement locations perform in terms of carbon emissions. RPS notes the model is based on current Government and existing Local Plan policies. Further information on the modelling work is set out in Estimation of emissions for proposed growth options and new settlements study dated November 2022. RPS has reviewed this study and wishes to raise a number of points on the approach. 4.26 Firstly, paragraph 1.1 of the study states that the options tested in the modelling all assume 35,000 dwellings will be delivered between 2025 to 2050. This differs from the level of growth assumed under the ‘trend-based’ projected need for South Warwickshire, which RPS calculates at 41,975 dwellings over this period (applying the 1,679 dpa taken from Table 9 of the IO document). However, the study does not include any testing against the preferred housing need scenario. Whilst the projected emissions are likely to be sensitive to higher levels of growth, it is nevertheless important that there is consistency across the analysis to ensure the policy choices are properly informed. 4.27 And secondly, chapter 5 of the study provides some commentary on the methodology underpinning the modelling of the options. Sub-section 5.3.2 lists a number of ‘key inputs’ for the site related modelling. This includes specific reference to ‘Energy efficiency benchmarks such as Part L 2013, Interim Future Homes Standard 2021’ (RPS emphasis). However, as outlined by the Government6, from 2025 new homes built to the Future Homes Standard will have carbon dioxide emissions at least 75% lower than those built to current Building Regulations standards, and all homes will be ‘zero carbon ready’, becoming zero carbon homes over time as the electricity grid decarbonises, without the need for further costly retrofitting work. Whilst the study refers to current building regulations standards under interim changes to Part L introduced in 2021, the study will need to reflect on the further tightening of the regulations and the move to the full Future Homes and Future Buildings Standards that are expected in 2025. 4.28 The introduction of the 2025 Future Homes Standards is expected to improve energy efficiency, reducing the demand for energy and so reduce carbon emissions in residential buildings. RPS recommends that the study is updated to reflect projected reduction of emissions by 75% compared to the 2013 Building Regulations. 4.29 For these reasons, RPS recommends that the Climate Change Emissions study should be updated to properly reflect the growth aspirations for South Warwickshire as well as reflect the broad direction of travel on tackling carbon emissions regarding future changes to building regulations and the impending implementation of the Future Homes and Buildings standards. 6 The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings Summary of responses received and Government response, January 2021

These should include areas D and G.

The emissions analysis is high level and shows relatively little difference between the options. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. This is because mitigation could be put in-place under each of the options so the contribution each proposal makes overall to the economic, social and environmental strands of sustainable development should be the determining factors and they should stand up, or fall, against the benefits of other options for accommodating growth.

The JPC does not have access to the expert advice to enable us to respond

Q-S5.1: Finding ways to reduce carbon emissions is vital given the climate emergency. Unfortunately this modelling is inadequate, as effective change in lifestyles have not been considered so that all scenarios are predicted to have almost identical emissions.

The emissions analysis is high level and shows relatively little difference between the options. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. This is because mitigation could be put in-place under each of the options so the contribution each proposal makes overall to the economic, social and environmental strands of sustainable development should be the determining factors and they should stand up, or fall, against the benefits of other options for accommodating growth.

No weight given to the impact of wood burner emissions, or how these will be prevented in future developments. Councils could make their own property much greener and more able to catch emissions - eg trees and shrubs around and within car parks

Within the Issues and Options document Table 5 show the estimated emissions for new settlements and the associated growth options. Growth Option 4 - Sustainable Travel & Economy which includes site F2, performs better in terms of reduced carbon emissions overall. Lone Star Land Ltd consider that further work will need to be undertaken in respect of emissions modelling for New Settlements. It is unclear how the estimated emissions both cumulatively and annual in 2050 lack any variation in emission estimations between the proposed new settlement site locations and their growth option scenarios. The provision of a new railway station and associated infrastructure which site F2 has the scope to accommodate, alongside the delivery of a comprehensive and coherent network of internal routes for pedestrians and cyclists together with new walking/ cycling infrastructure. This would encourage future residents and users to utilise a wider range and more sustainable forms of transport, reducing the need to travel to meet daily needs, seeking to reduce transport-related emissions and would support the concept of 20-minute neighbourhoods. Paragraph 105 of the NPPF states that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health.

The emissions analysis is high level and shows relatively little difference between the options. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. This is because mitigation could be put in-place under each of the options so the contribution each proposal makes overall to the economic, social and environmental strands of sustainable development should be the determining factors and they should stand up, or fall, against the benefits of other options for accommodating growth.

more congestion on the roads and fumes

The emissions analysis is high level and shows relatively little difference between the options. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. This is because mitigation could be put in-place under each of the options so the contribution each proposal makes overall to the economic, social and environmental strands of sustainable development should be the determining factors and they should stand up, or fall, against the benefits of other options for accommodating growth.

Table 5 lists the new settlement locations and associated estimations of emissions from the Model for each Growth Option. However, there is very little numerical difference in emissions estimations, suggesting that additional work or refinement of the model is required in order to differentiate between each Growth Option. 3.24 Nonetheless, the fact that Long Marston Airfield (New Settlement Reference E1) has been identified as a location for development within each of the five Growth Options is supported. This clearly demonstrates its suitability for growth, irrespective of which Option is adopted.

The Parish Council does not have the emissions estimation modelling expertise to respond