Issue and Options 2023
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New search2 THE SITE AND PROPOSALS 2.1 It is acknowledged that the Part 1 SWLP is unlikely to allocate sites of the scale of Kings Meadow Phase 2, however for information set out below is a brief summary of the emerging proposals for the site, with further detail set out in Appendix A. The site has previously been identified as a reserve site in the emerging Site Allocations Plan being prepared by Stratford-on-Avon District Council. 2.2 The site is adjacent to the northern settlement edge of Bidford-on-Avon, less than 1 km from the village centre and adjoins Miller Homes Phase 1 site which is currently being built out for 200 new homes. Bidford-on-Avon is situated approximately 10 km to the west-south-west of Stratford-upon- Avon, 6 km to the south of Alcester and 10 km to the north east of Evesham. Bidford-on-Avon is located immediately north of a meander on the River Avon and to the East of the River Arrow Valley. 2.3 The site consists of a single field, currently in agricultural use, that is adjacent to an unnamed track to the northern boundary of the site, that links to Victoria Road / Bidford Road to the west of the Site. A watercourse, Small Brook, runs adjacent to the track and is a tributary of the River Avon. An established hedgerow separates the track from the Small Brook. The southern boundary of the site adjoins the Miller Homes Phase 1 site currently under construction. The western boundary adjoins the edge of a recently completed residential development at Jacksons Meadow. The eastern boundary of the site adjoins the garden of a residential property. The site is shown below and its relationship to the development at Jacksons Meadow and its relationship with the Miller Homes Phase 1 development to the south. Figure 2.1 - The site and relationship to phase 1 Miller Homes development to south [see submission document] 2.4 Development has built up along the B439 Stratford Road that runs east-west, just north of the town centre. Development is also situated along two roads running north from there: Victoria Road to the west and Waterloo Road to the east. The Site sits between these two roads. Existing residential development at Bidford-on- Avon is situated on land between 25m AOD and 52m AOD. 2.5 As set out in the accompanying vision document (Appendix A) the vision for the Site is to deliver an attractive development offering a choice of high quality affordable and market new homes to meet local needs and being fully integrated with, and complementary to, the village of Bidford-on-Avon. Miller Homes has developed an illustrative concept masterplan which reflects the opportunities and constraints that have been identified through the evidence base for the application on the land to the south, and subsequent further technical work on landscape and highways. It is intended that the illustrative masterplan shown below is used as a starting point to inform discussions on the Site and that the plans will evolve further following consultation with the local community, the Council and any other key stakeholders. Figure 2.2 - Illustrative Masterplan [see submission document] 2.6 Vehicular access would be provided towards the south eastern corner of the Site, linking directly into the wider Miller Homes site to the south, ultimately linking the site to Waterloo Road to the east. The illustrative masterplan shows how access to the land to the east of the Site, which is outside of the control of Miller Homes, could be provided through the Site linking it to the larger Miller Homes site to the south. 2.7 The illustrative concept masterplan demonstrates that a significant amount of green infrastructure could be provided within the Site as part of the proposed development. In particular areas of green, open space, are shown within the illustrative masterplan to the eastern and southern boundaries of the Site that would enable the development to seamlessly integrate with the approved development to the south. The scheme has taken account of the work undertaken as part of the Landscape and Visual Assessment and substantial hedgerow and tree planting would be provided across the Site, within both public areas and private gardens, to ensure a high-quality form of development that reflects its location. Whilst further details would be provided at the application stage, the proposals allow for a strong landscape barrier to the north of the site to ensure that a strong, defensible barrier, can be created. 2.8 The illustrative concept masterplan demonstrates that the site can accommodate up to 90 dwellings at a density of approximately 30 dwellings per hectare. This ensures that the development would reflect the general character and density of development within the surrounding area and that it would protect the residential amenity of the occupiers of existing and proposed residents alike.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? 3.1 No. 3.2 It is noted that under the heading ‘Meeting South Warwickshire’s Sustainable Development Needs’ there is an objective relating to ‘delivering homes that meet the needs of all our communities’. However, this objective only relates to addressing local housing need but does not include any reference to addressing development needs from neighbouring areas. This is despite the accepted position that South Warwickshire straddles two market areas; Greater Birmingham and the Black Country, and Coventry & Warwickshire. Both of these market areas have a history of unmet need which, in Birmingham’s case, has never been fully addressed and which is now worse (c. 78,000 dwellings) compared to the shortfall in adopted Plan (37,500). In Coventry, it is likely that their future needs will not be accommodated in full within their area due to its tightly-drawn boundary and so support will be required from neighbouring areas within the wider market area, including South Warwickshire. Notably, the IO document makes reference to two options for contributions towards these wider needs; 5,000 and 10,000 homes. 3.3 On this basis, RPS recommends that the objectives of the SWLP should be updated to reflect the emerging position regarding future (unmet) need across the wider market areas within which South Warwickshire is located and which make a clear commitment to assisting in addressing those needs.
Issue S2: Intensification Q-S2: Please select all options which are appropriate for South Warwickshire 4.1 Under this issue, the IO document does not pose any specific questions, but instead identifies three options for developing a policy to support the intensification of existing areas. 4.2 National policy provides advice on achieving appropriate densities as part of the overall objective to make efficient use of land1 or for optimising the density of development in city and town centres and other locations that are well served by public transport2. This includes taking into account the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change3, as well maintaining the viability of development4. It is also advised that it may be appropriate to set out a range of densities that reflect the accessibility and potential of different areas, rather than one broad density range5. 4.3 In this context, it is clearly the case that some localities more central to existing built-up areas may be more predisposed to accommodate more intensive development than other locations. Nonetheless, delivering development at increasingly higher densities will inevitably lead to potential impacts on the prevailing character and setting of existing settlements. Therefore, whilst increasing densities could increase the supply of housing, this should not be seen as the only option. In this context, there is clearly a role for development that is brought forward on the edge of existing settlements that can be designed in order to integrate with existing areas but also help to create distinctive places in their own right. 4.4 Consequently, RPS recommends a design-led approach to establishing strategies on density. Density is a function of good design and there is no reason to take an alternative approach when devising local policy through the SWLP. On this basis, any policy approach should be informed by an assessment of the character of different areas because character is not uniform across the plan area. This is in preference to any blanket or an ‘in-principle’ approach. Similarly, there should not be any overarching priority to intensify or densify existing urban areas because other evidence, principally the Urban Capacity Study, shows that the development needs of the SW area will not be met through urban-focused / brownfield growth alone. This is discussed in the response to Issue S3 below. 4.5 RPS therefore would favour Option S2a, which would direct any policy response to localities where intensification is considered to be appropriate, but which recognises that less intensive or development at relatively lower (but compatible or complimentary) densities are also acceptable if designed sensitively. 1 NPPF2021, paragraph 124 2 Paragraph 108 3 Paragraph 124d 4 Paragraph 124b 5 Paragraph 125b Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 4.16 Yes. 4.17 There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire. 4.18 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 4.19 At the local level, RPS notes Table 2 of the IO document which lists a number of existing settlements identified in adopted plans across South Warwickshire. These include Bidford-on-Avon. The settlement has been subjected to separate connectivity, accessibility and density analysis, which RPS responds to question Q-S4.2 under section 6 of this submission. Sustainability Appraisal (SA) has also been carried out on the broad locations within which the settlement is situated, and a response to the SA is provided in section 5 of this submission to question Q-I1. 4.20 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). However, in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements (see Issue S5).” 4.21 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire District in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites are concerned these can deliver a steady quantum of development over a period of time in order to help maintain delivery against the targets in the SWLP. 4.22 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, including Bidford-on-Avon, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives. Issue S5: The potential for new settlement(s) 4.23 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 specify 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 (see RPS responses under Issue I1) and Climate Change Emissions Estimation modelling. 4.24 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-S5.2: Do you think new settlements should be part of the overall strategy? 4.30 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 2022 7. 4.31 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 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. 7 Stratford-upon-Avon Authority Monitoring Report 2021-22, Table 13 Issue S6: A review of Green Belt boundaries 4.32 RPS notes that the IO document does not include any specific question regarding potential for changes to the Green Belt in South Warwickshire. Nevertheless, national policy8 makes provision for alterations to existing Green Belt boundaries through the updating of plans where the need for changes to Green Belt boundaries is established in the strategic policies. This is normally done through a Green Belt review to inform the development of the spatial strategy and identification of site allocations. 4.33 In this respect, the IO document makes clear that to achieve a growth strategy that addresses the vision and strategic objectives for the Plan, a Green Belt study to review the existing Green Belt boundaries would inform and help to refine the growth options that are set out within the issues and options consultation to enable a preferred approach for South Warwickshire to be established. 4.34 Nevertheless, regardless of whether any Green Belt is released is taken forward, there are opportunities outside the Green Belt where growth can be directed, this includes at Bidford-on-Avon, which is identified as one of the eight ‘Main Rural Centres’ in the adopted Stratford-on-Avon Core Strategy. Bidford-on-Avon therefore can make a valuable contribution towards meeting the housing land supply requirements of South Warwickshire. 8 NPPF 2021 paragraph 140 Issue S9: Settlement Boundaries and infill development 4.60 Under this issue, the IO document indicates that there may be a need to alter existing settlement boundaries to take account of a new growth strategy up to 2050. National policy provides limited assistance to local planning authorities or stakeholders in how to deal with setting or amending settlement boundaries. 4.61 The IO document presents two options. Option S9a would save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b would review, within this Part 1 Plan, which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 4.62 The IO document makes clear that this plan review relates to part 1 strategic policies only, including strategic allocations and / or new settlement locations, and not non-strategic policies and allocations. On this basis, RPS would favour Option S9a – settlement boundaries should be reviewed at the Part 2 review stage. Given this option refers to the ‘emerging SAP’ RPS assumes that the SAP is still likely to be progressed and adopted including alterations to some settlement boundaries, prior to an immediate review of those boundaries in short order in the Part 2 SWLP. This is logical as the Part 2 SWLP will need to ensure the settlement boundaries at for example Bidford-on-Avon is suitably robust to allow growth to be accommodated up to 2050, as opposed to the SAP which only addresses development needs up to 2031 (and only for Stratford-upon-Avon district). 4.63 RPS have previously submitted responses on behalf of Miller Homes to various consultations on the emerging SAP in relation to their interest in the site, most recently in July 2022 in response to the Revised Preferred Options Consultation. Whilst it is noted that the IO consultation is not considering boundaries in detail RPS maintain the position set out in those representations that the entirety of the site has development potential. 4.64 Furthermore, in order to provide sufficient clarity and to reduce the risk of ambiguity in the Part 1 version, the next iteration of the SWLP (the preferred option draft plan) should make clear which settlement boundaries will need to be reviewed in light of the quantum of growth to be directed to each respective settlement (to deliver the spatial development strategy) and the capacity of those settlements to suitably accommodate that growth within the existing boundaries. Issue S10: Any other development strategy issues Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire: 4.65 The preamble states that Chapter 4 of the IO document sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 4.66 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO document moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 4.67 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7). 4.68 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified.
4.6 An Urban Capacity Study for South Warwickshire, dated October 2022, has recently been undertaken to inform the Local Plan. Its purpose is to identify the potential for residential development on brownfield land within the settlements in South Warwickshire. As pointed out in section 1.1 of the study report, a review of housing capacity has been undertaken in order to minimise the amount of development outside of existing urban areas. 4.7 The IO document goes on to state that the study has been undertaken as a theoretical exercise and is not intended to conclusively establish the urban capacity of South Warwickshire over the period to 2050, but rather to indicate potential untapped urban capacity within these identified settlements, subject to the application of policy and the conclusions of more detailed subsequent evidence work. That said, there are some important conclusions in the study that need to be emphasised at this stage as the study will form part of the evidence to underpin the development strategy in the SWLP. 4.8 The study has applied a number of important assumptions, as listed here: • The base date for the study and the conclusions around potential urban housing capacity is 1st April 2021 • The study assumes that all of the sites considered will be developed as ‘conventional’ dwellinghouses in Use Class C3 (not specialist housing i.e. student accommodation or older persons housing). • Capacity was measured on sites located in 23 settlements across the SW area, including Main Rural Centres defined in the Stratford-upon-Avon Core Strategy, and Growth Villages as defined in the Warwick Local Plan. This includes sites located in Bidford-on-Avon. • The Urban Capacity Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice. 4.9 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 4.10 The study therefore identifies a significant shortfall in the potential for new housing to be accommodated on previously developed land. The shortfall is currently 10,800 dwellings. This should be taken as a minimum shortfall, as not all sites with potential will actually be deliverable or developable once a full assessment has been carried out. 4.11 Based on these findings, the study concludes that: “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.” 4.12 Furthermore, the shortfall is set against the standard method housing need figures (1,230 dpa across the whole area over 25 years). However, the IO document advocates for the use of an alternative ‘trend-based need for South Warwickshire, which gives a need for 1,679 dpa. Against this figure, the total need between 2025-2050 increases to 41,975 dwellings, thus increasing the shortfall to 22,025 dwellings. This clearly demonstrates that the focusing policy objectives on previously developed land will not deliver anywhere close to the projected needs of the SW area, and therefore planning for development on greenfield land in sustainable locations must form part of development strategy for the SWLP. 4.13 In addition, under the assessment of sites by settlement, the study identified one possible employment area in Bidford-on-Avon that merited consideration for housing development, namely Waterloo Industrial Estate / Bidavon Industrial Estate. However as set out in Table 9 on page 27 of the study it is noted that given high levels of occupancy, away from a small area currently being redeveloped for housing adjacent to Waterloo Road, potential for further residential development is limited. No other unconsented or unallocated potential development sites have been identified within the settlement boundary. Consequently, it is inevitable that additional growth at Bidford-on-Avon will need to be allocated on the edge of the settlement. 4.14 The suitability of the site for development has already been identified in the emerging Site Allocations Plan, which has identified the site as a reserve site, indicating that both further development at Bidford-on-Avon is appropriate and also that the site itself is suitable for development. 4.15 The IO document presents three options under this issue. On the basis of the current evidence provided on housing capacity, RPS would recommend that development on previously-developed land is supported only where sites are shown to be viable and deliverable, as well as being sustainably located. However, given the paucity of the overall supply from sites within urban areas, notably Bidford-on-Avon, it is not considered reasonable to prioritise brownfield development ahead of other, greenfield locations as a matter of principle as this would put at grave risk the ability of the SWLP to meet the identified needs of the area. On this basis, RPS would not support Option S3.2a or S3.2b (and thus supports Option S3.2c).
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
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.
