Issue and Options 2023

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Q-T1 – Please select the 20 minute neighbourhood option which is most appropriate for South Warwickshire Option T1b: Include reference to the principles of a 20-minute neighbourhood or other similar design approach (e.g. Building for a Healthy Life) within a broader overarching policy. National policy does not currently require all developments in all locations to achieve Building for a Healthy Life accreditation or endorse the principles of a 20 minute neighbourhood. The connectivity and context of developments can be determined on a site by site basis.

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RESPONSE TO SUSTAINABILITY APPRAISAL (NOVEMBER 2022) Barratt David Wilson Homes (Mercia) (“BDW”) have a series of comments on the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options consultation draft document. These are set out below on a topic basis in the same order that matters are raised in the SA. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions The SA testing of the Growth Options against the 13 criteria identified in paragraph 2.21 of the report is appropriate. These criteria reflect the objectives of the SWLP and the topics identified in Annex 1(f) of the SEA directives. The outcomes of the assessment process, however, needs to be treated with caution. The SA is a snapshot in time. It assesses the sustainability of the Growth Options and potential locations for allocation on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the potential locations for development against Matter 11 – Education, regard has been had to existing education provision in the locality. It does not, however, consider how new development could improve local education facilities through the provision of a new education infrastructure such as a new school that would be of benefit to the local area generally. Sustainability appraisals are an iterative process, until the current Call for Sites consultation is completed and responses reviewed, the local authorities will not have a clear understanding of what services and facilities are being promoted with the various development opportunities being presented. However, in due course this should be a key consideration for the local authorities in determining the preferred strategy, growth options and allocations within the SWLP. Climate Change While the assessment of the proposals against climate change objectives is required, there are concerns with the way in which this has been applied in the SA. Paragraph 2.4.6 of the SA states that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses) are likely to increase greenhouse gas emissions by more than 1% and adversely affect climate change. Developments of between 50 to 500 dwellings could increase greenhouse gas omissions by more than 0.1% and have a lesser effect on climate change than the larger sites. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have a set housing requirement. The greenhouse gas emissions from the construction of these properties will have a total accumulative impact based on the total number of houses built. The total amount of greenhouse gas omitted as part of the construction of these houses will be broadly the same, regardless of whether the houses are provided on a larger number of small sites or a smaller number of large sites. Larger scale developments are unlikely to have a greater impact on greenhouse gas emissions than smaller schemes. Large scale developments are more likely to provide onsite infrastructure, such as schools, places to work, local services and facilities than small scale developments. In terms of the Rail Corridor Growth Option, development near existing stations will help facilitate sustainable commuting patterns. Smaller schemes of 50 to 500 dwellings are less likely to provide onsite infrastructure or have the benefit of close proximity to a train station. It is, therefore, inappropriate for the climate change appraisal to penalise larger sites in comparison to smaller sites due purely to their size. It is also suggested that development of greenfield sites for housing has a potential to lead to local, long term significant adverse effects in the form of increasing flooding, drought and storm events. This is not necessarily the case. Indeed, it is not uncommon for new development to introduce flood risk and drainage control measures that improve the flood risk and drainage situations locally. New developments must achieve greenfield run off rates and can often be used to address localised problems associated with flood risk. Biodiversity and Geodiversity The impact of development on biodiversity and geodiversity is a clear consideration in the SA process. However, the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in the report (paragraph 2.6.14) and detailed ecology surveys and assessments will determine, on a site by site basis, the presence of priority species and priority habitats (paragraph 2.6.12). The SA has, therefore, made assumptions about the sensitivity or otherwise of potential development options from an ecological basis linked to their proximity to identified assets. The SA’s conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information is available from the Call for Site submissions this should be actively considered in the site selection process. Landscape The SA advises at paragraph 2.7.2 that detailed designs for each development appraisal are uncertain at this stage of the assessment. The landscape assessment is a desk based exercise which has not been verified in the field. Therefore, the nature of potential impacts on the landscape is uncertain. Indeed, the SA recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. The landscape appraisal selection of the SA must be treated with caution as the evidence base is not complete. Paragraph 2.7.6 states that large scale residential-led development is likely to adversely impact the countryside and urban area where the various reasonable alternative development locations are located. This is a broad brush conclusion. Whilst development may impact on the landscape, impacts are not automatically negative or unacceptable. Indeed, well designed and high quality landscaping could potentially enhance the landscape character of a development area. Cultural Heritage Paragraph 2.8.3 of the SA confirms that the impacts on heritage assets will largely be determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. At this stage, the risk of substantial harm to the significance of the heritage asset has been assessed based on the nature and significance of, and proximity of sites to, the heritage asset in question. It is also advised that whilst the Heritage and Settlement Sensitivity Assessment is being prepared, this assessment was not available for use at the time of undertaking the SA process. The conclusions of the SA on cultural heritage impact must be treated with caution. Where site specific heritage information has been provided with Call for Sites submissions this should be considered in the site selection process. Environmental Pollution There is concern about some of the assessment criteria used within the environmental pollution section. Development proposals that are within 200 metres of a railway station are negatively scored. Development proposals located over 200 metres from a railway station have a neutral score. Given the need for increased use of sustainable travel it is ironic that development proposals which would help to reduce the use of railway transport by being located further away have a positive score. The SWLP correctly recognises that there are significant benefits in a Rail Corridor Growth Option and that providing access to a train station reduces the need for people to travel using the private car. The approach of the SA in this regard directly conflicts with the Rail Corridor Growth Option. It is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability credentials due to road related air and noise emissions. This conclusion does not automatically follow as it is possible for sites within 200 metres of a main road to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources The SA has a flawed approach towards assessing the agricultural land implications of development. Development proposals that include over 20 hectares of Grade 1, 2 or 3 agricultural land score a ‘double negative’ while development proposals that include an area of land of less than 20 hectares of Grade 1, 2 or 3 agricultural land have a ‘single negative’ impact. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have to allocate land to deliver a set amount of housing. This will be from a combination of brownfield and greenfield sites. The amount of agricultural land developed in the plan area as a whole is likely to be fixed, as the housing requirement will be fixed. However, the approach of the SA means that it favours the allocation of a large number of smaller sites (less than 20 hectares) rather than a small number of large sites (more than 20 hectares) whilst the total amount of agricultural land developed is likely to be the same. Health Impact Development options are scored down if they are more than 800 metres from an area of green space, or 600 metres away from a public right of way or cycle path. Development proposals, especially larger one with more space, will, in all likelihood, provide onsite green space to meet their needs, and may be able to provide connections to nearby footpaths/cycle paths. Accessibility The SA accessibility assessment criteria for proximity to bus stops and food stores gives a negative sustainability rating to potential development locations that are more than 400 metres from a bus stop and more than 800 metres from a food store. Whilst this is a sensible starting point, large scale developments will, in all likelihood, provide new bus stops and convenience stores. Indeed, we would fully expect the local authority to require larger schemes to include a local centre. Similarly, development options that are located over 800 metres from a primary school have a negative rating. Large scale sites are likely to provide primary schools. Primary school provision to be a key component of any scheme providing 800+ dwellings. Economy The SA assessment criteria for economic opportunities penalises schemes that are more than 5km from a “key employment location” whilst positively scores sites that are within 5km of a key employment location. Large scale residential sites are likely to provide employment opportunities as part of the overall proposals. It is inappropriate for the SA to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision.