Q-S7.1: Please provide any comments you have on the emissions estimation modelling for the five growth options

I'm not sure that emissions is the basis for driving this as the existing poor infrastructure can barely cope and with the level of roadworks taking place then are going to be skewed by the level of stationary vehicles - quite often from ill thought out planning and permission of works and narrow things down to a single option of daft as no one solution will work across the whole area

It is clear that the 5th growth option should be discarded. There is not that much between the others options, and there is presumably a margin of error in the projections. They may however be of use to the Councils in identifying what is good with each approach. With that in mind, it is interesting that the 4th growth option, for sustainable travel and economy, which would seem designed to select the best of both worlds, is the worst performing of the 4 serious approaches (excluding the 5th). Unfortunately the emissions estimation does not explain why this is - what, specifically, is the danger the Councils should be looking to avoid here? The emissions estimation seems to be based on current government policy. However, we might hope that government policy will be improved, e.g. with regard to provision of insulation and subsidisation of public transport. It would possibly be helpful for the Councils in choosing between the different options, to work with a national environmental organisation like Friends of the Earth, to identify a range of national policies that might make a big difference to the existing trajectories, and then to model the 5 different growth options again with those policies in mind. That would allow the Councils to assess each growth option against both pessimistic and optimistic scenarios for national leadership, and might (or might not) provide for a clearer distinction between some of the options.

Q-S7.1: Please provide any comments you have on the emissions estimation modelling for the five growth options Concerned that NOT reviewing the green belt hasn’t been considered as a clear option, in line with Sustainability Appraisals requirements. This key designation retains open areas for wildlife, stops settlements joining and works with designations outside of S Warks. With more people working from home, we also consider that other services rather than just the transport network should be included in the assessment. Greater weight should have also been given to impact on biodiversity and LWS’s and PLWSs.

The emissions data does not appear to accurately reflect the environmental benefits of rail transport over road. Road traffic currently accounts for 72% of total greenhouse gas (GHG) emissions from transport (73% of passenger-kilometres), aviation accounts for 14% (8% of passenger-kilometres), and rail accounts for less than 1% (6% of passenger-kilometres).* * European Environment Agency (2019), ‘Share of transport greenhouse gas emissions’, data visualization.

We note that a Climate Change Emissions Testing Assessment has been carried out of each strategy option, and that the assessment found that the peak emissions associated with the dispersal strategy are lower than those associated with the sustainable travel and economy option, and in the long term, are no higher than the other options. While there is an expectation that the dispersal options would perform poorly against the other options, it is important to note that in the long term this is not the case, and therefore, the dispersal option should not be discounted on the basis of this assessment.

We note that a Climate Change Emissions Testing Assessment has been carried out of each strategy option, and that the assessment found that the peak emissions associated with the dispersal strategy are lower than those associated with the sustainable travel and economy option, and in the long term, are no higher than the other options. While there is an expectation that the dispersal options would perform poorly against the other options, it is important to note that in the long term this is not the case, and therefore, the dispersal option should not be discounted on the basis of this assessment.

We note that a Climate Change Emissions Testing Assessment has been carried out of each strategy option, and that the assessment found that the peak emissions associated with the dispersal strategy are lower than those associated with the sustainable travel and economy option, and in the long term, are no higher than the other options. While there is an expectation that the dispersal options would perform poorly against the other options, it is important to note that in the long term this is not the case, and therefore, the dispersal option should not be discounted on the basis of this assessment.

We agree that the emissions modelling is a useful element of the evidence base to inform the Local Plan. However, it is important to note that reducing emissions is only a small element of achieving sustainability and this needs to be balanced against building a strong, responsive and competitive economy, supporting strong, vibrant and healthy communities and significantly boosting the supply of homes. Warwick District Council and Stratford on Avon District Council, as plan-makers, need to take into account the emissions model along with the full evidence base to ensure the plan meets the test of soundness including being positively prepared, justified, effective and consistent with national policy.

One of the Team has commented to us “ You will notice that the graph does show the differences (between the Growth Options) to be minimal”. We agree and without being expert consider that predicting the future is so difficult that the Plan should not give too much weight to this factor. We are concerned at the apparent weight being given so far.

Neutral

3.47 RPS has highlighted a number of issues with the CCEE study at a broad level in responses to Issue S5, which are applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) having the highest emissions. 3.48 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050 (or 2055).

We note that as part of the evidence to inform the Local Plan a carbon model has been developed to assess the carbon emissions at a strategic level for each option which is part of the Sustainability Appraisal’s Objective 1: Climate Change. We note that the dispersal option (Option 5) has been deemed to have negative impact on climate change, however, it is clear on Figure 15 that by 2050 Option 5 is at the same level of annual emissions as any other option. As such we believe that Option 5 should not be discounted due to its impact on climate change.

Issue 7 Refined Spatial Growth Options QS7.1 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: Option 1 – We consider it appropriate to consider rail corridors as part of refined spatial growth options. Rail has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage 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. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 2 – We consider it appropriate to consider sustainable travel as part of refined spatial growth options. Sustainable travel has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage 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. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 3 – We consider it appropriate to consider economy as part of refined spatial growth options, however we are less supportive of this option – especially in relation to strategic scale development sites which are likely to bring forward their own suite of employment opportunities and as such would be less reliant upon existing employment opportunities. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage 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. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 4 – We consider it appropriate to consider sustainable travel and economy as part of refined spatial growth options, however as per Option 3 we are less supportive of this option – especially in relation to strategic scale development sites which are likely to bring forward their own suite of employment opportunities and as such would be less reliant upon existing employment opportunities. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage 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. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 5 – We consider it appropriate to consider a dispersed approach as part of refined spatial growth options. This has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. It is to be noted that the current development plans for the two Districts are founded upon a strategy of ‘balanced dispersal’ which has been an effective and deliverable strategy, it is therefore a strategy which has been successful in the past and should be given serious consideration in the SWLP. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage 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. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted.

Concerned that NOT reviewing the green belt hasn’t been considered as a clear option, in line with Sustainability Appraisals requirements. This key designation retains open areas for wildlife, stops settlements joining and works with designations outside of S Warks. With more people working from home, we also consider that other services rather than just the transport network should be included in the assessment. Greater weight should have also been given to impact on biodiversity and LWS’s and PLWSs.

Claverdon does not have access to the expert advice to enable us to respond.

RPS has highlighted a number of issues with the CCEE study at a broad level in separate responses to Issue S5, which are equally applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) has the highest emissions. 3.37 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050

With regards to transport, ‘Rail Corridors’ was assessed as equal best for the reduction in car trips and equal on EV uptake. ‘Rail Corridors’ scored lower on the uptake of 20- minute neighbourhoods. Given that most of the new settlement options are located along ‘Rail Corridors’ it is not clear whether this has been correctly assessed. New settlements have a greater potential to deliver on site infrastructure and therefore 20- minutes neighbourhoods because of their scale. The South Warwickshire authorities are encouraged to progress the emissions estimations further prior to developing the Preferred Options consultation document for the SWLP.

Issue S7: Refined Spatial Growth Options 4.35 The IO document now proposes five ‘spatial growth’ options, which are as follows: • Option 1: Rail Corridors • Option 2: Sustainable Travel • Option 3: Economy • Option 4: Sustainable Travel and Economy • Option 5: Dispersed 4.36 RPS notes that 38% of respondents to the previous Scoping stage consultation in 2021 indicated a preference for a ‘hybrid’ approach, which broadly correlates with the preference set out by RPS in submissions made as part of that consultation. This has resulted in a reduction in spatial options down from seven to five. The move to five spatial options is supported by Sustainability Appraisal and analysis set out in the Climate Change Emissions Estimation (CCEE) study. Q-S7.1: Please provide any comments you have on the emissions estimation modelling for the five growth options 4.37 RPS has highlighted a number of issues with the CCEE study at a broad level in separate responseto Issue S5, which are equally applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) has the highest emissions. RPS note that Bidford-on-Avon is identified in the indicative list of settlements and locations that may feature in Option 4. 4.38 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050.

There is very little difference between them.

The emissions analysis is high level and shows relatively little difference between the alternatives. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. Assuming mitigation could be put in-place under each of the options then other considerations should have greater weight.

Issue S7.1 - see comments above [Issue I1]. I do not agree with the conclusion that none of the proposed sites have any issues with flooding.

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

The emissions analysis is high level and shows relatively little difference between the alternatives. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. Assuming mitigation could be put in-place under each of the options then other considerations should have greater weight.

RPS has highlighted a number of issues with the CCEE study at a broad level in separate response to Issue S5, which are equally applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) has the highest emissions. 3.37 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050.

It is apparent that growth will have an impact on emissions. Growth in areas which have the provision to accommodate sustainable transport infrastructure would assist in reduction of car journeys undertaken by residents and users, would therefore have the potential to have impact in reducing emission levels. The SA acknowledges that pollution manifests cumulatively rather than at the project scale and in this respect all Growth Options will have a bearing on diffuse pollution associated with development. Air quality is likely to improve from any option that promotes sustainable transport such as Options 1 and 2. Reducing the need to travel by locating employment close to residential areas may also assist in this regard.

We agree that the emissions modelling is a useful element of the evidence base to inform the Local Plan. However, it is important to note that reducing emissions is only a small element of achieving sustainability and this needs to be balanced against building a strong, responsive, and competitive economy, supporting strong, vibrant, and healthy communities, and significantly boosting the supply of homes. Warwick District Council and Stratford on Avon District Council, as plan-makers, need to take into account the emissions model along with the full evidence base to ensure the plan meets the test of soundness including being positively prepared, justified, effective and consistent with national policy.

The emissions analysis is high level and shows relatively little difference between the alternatives. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. Assuming mitigation could be put in-place under each of the options then other considerations should have greater weight.