Issue and Options 2023

Although we support the intention of this sustainability appraisal, the implementation has too many issues to be used with confidence. The methodology used in the Sustainability Assessment (SA) is not sufficiently clear for the reader to understand the process by which locations are assessed using the SA/SEA approach. There are several parts to the methodology: 1). Selection of 13 SA Objectives which are scored at each location; 2) Assessment of each SA Objective based on a SA Framework (SA vol. 3 Appendix A pages 538-541 pdf pp.580-583) which includes Decision-making criteria – a set of questions – and Indicators used to answer the questions for each SA Objective; 3) Scoring for each SA Objective (and sub-objectives) based on Explanations (assessment of Indicators) using a six category scoring system (SA vol.2 Table 2.1 page 410 pdf p.452) represented by Impact Symbols (--,-,+/-,0,+,++); 4) Evaluation of the performance of different options based on the scoring for SA Objectives, sometimes tabulated, averaged or shown graphically through the use of rose diagrams (e.g. Kenilworth SA vol. 2, 4.5 page 458, pdf p 500). It may be challenging to identify quantitative Indicators for all the SA Objectives but some Indicators are statements of intention or policy rather than factual information For example, SA1 Climate Change is described through six Decision-making criteria that include the question: “Will the option ensure that sustainable construction principles are integrated into developments including energy efficient building design?” To which, one of the Indicators is listed as “Implementation of adaptive techniques in building design e.g. passive heating/cooling”. This criterion and indicator can’t be addressed in 2022-24 as they depend on future policy. Or, the Decision-making criterion question “Will the option help to reduce reliance on personal car use? Indicator - Encourage active travel to local services and amenities.” This is not an indicator that can be used to judge the performance of an objective for a location now as it represents a future intention or action. Some questions are unclear. For example, SA13 Economy, one of the Decision-making criterion questions is “Will the option provide or improve sustainable access to a range of employment opportunities?” It is not clear what this means: how could it be answered on the basis of locations for housing alone, and what is the appropriate Indicator? It is not clear how the Explanations are arrived at. We might expect to see these based on answers to the Decision-making criteria using the stated Indicators. For Kenilworth North, the Explanation for the scoring of SA1 Climate (SA vol 3. B.5.1 page 565 pdf p.607) only uses one of the stated Indicators (carbon emissions), as in “Large scale residential-led development is likely to result in an increase in GHG emissions. Development in this Broad Location could deliver up to 2,000 dwellings and therefore could increase carbon emissions in the District by more than 1% and result in a major negative impact.” Why are the other stated Indicators not included – and in any case this is contradictory given that one of the Indicators acknowledges future houses (up to 2050) are likely to be low energy/zero carbon. The apparent inconsistencies above potentially undermine the value of the SA methodology. It is not clear how the Impact Symbols are translated into SA Objective Performance scores on the rose diagrams. The rose diagrams are scored 0 to 5 which suggests they map on to the six impact symbols. But this is not the case. For example, SA1 Climate Change for Kenilworth North (SA vol 3. B.5.1 page 565 pdf p.607) is given an Impact Symbol of (--) (most adverse effect) but is mapped on to a score of 1 in the rose diagram – not 0 (zero) (SA vol. 2, 4.5 page 458, pdf p 500). It is not clear how the Impact Symbols are ‘averaged’ for an SA Objective on a rose diagram when there are sub-objectives with different Impact Symbols. For example, SA6 Pollution for Kenilworth North (SA vol 3. B.5.6 page 568 pdf p.610) has five sub-objectives all scored with the same Impact Symbol (-) yet the rose diagram score is 2.2. Or, SA3 Biodiversity (SA vol 3. B.5.3 page 566 pdf p.608) that has eight sub-objectives (+/-, 0, 0, -,--,-,0,-,) and also with an average score 2.2 (a simple mapping of 0 to 5 to these would give an average score of 14/8 = 1.75). Perhaps the different sub-objectives are weighted differently, though this is not clearly stated, or there is an error in the mapping. These concerns are far from trivial. The underlying methodology to the whole exercise is based on simple scores, many of which are contentious because they depend on intention or policy rather than factual information. As a result, the findings are very sensitive to particular scoring values and provide relatively weak discriminatory power (i.e. many of the rose diagrams look very similar). Yet the scores are used to rank locations (e.g. Best Performing Location) as evidence for the Issues and Options report. Minor errors in the scorings, rose diagrams and ‘averaging’ across objectives could result in quite different findings.

No

To tackle the climate emergency and create vibrant local communities, the focus must shift from large road projects to developing active travel options locally. Therefore there should be no infrastructure safeguarding for road projects.

selected

selected

selected

selected

selected

selected

selected

selected

The urban capacity study identifies relatively little room for growth in the number of residential properties in existing urban areas. However, over the life of the local plan, major changes may increase this number. For example, reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites as the feedback from the first consultation and associated commentary in the current consultation document provide compelling reasons to have strong policies to support intensification (issue S2). These include increasing active travel, maintaining local services and reducing the need to build on greenfield sites. Having a policy to support intensification should be used in conjunction with Option T1c about 20 minute neighbourhoods.

Yes

We also agree that the analyses in terms of Connectivity, Landform and Density provide a sound basis for allocating sites. Unfortunately the sustainability appraisal is less compelling due to the highly subjective assessments and lack of clear differences between alternative options.

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

Yes

No

Explanation of response to S5.2: The proposal to build new settlement(s) in south Warwickshire of the ‘large village’ type might enable people to live, study, work and and relax within their communities thereby strengthening them. If carefully designed, these settlements could embody 20 minute neighbourhood principles. Such design should permit high housing density in the centres and exceed the suggested 40 dwellings per hectare, thus protecting the rest of the area from urban sprawl and unnecessary loss of greenfields. Therefore, this is probably the least-worst way to provide for the huge numbers of new homes mandated by central government. Explanation of response to S5.3: It would be ideal to have a railway station in a new settlement, so long as it is part of a broad strategy to encourage its use and so reduce car journeys. However, we are sceptical that this will be effective and it is far more important to design the settlement to provide enough facilities so residents choose to travel/ commute less frequently beyond the settlement.

As described in our response to Issue I1, the Sustainability Appraisal has serious weaknesses and shouldn’t be used to compare the spatial growth options. Equally, the emissions modelling is inadequate and should not be used: see our response to QS5.1.