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 neighborhood. 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 the following comments to make in respect of the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options Consultation draft document. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions The SA testing of 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 allocations on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the Draft Plan policies, growth options and 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 new schools or the contributions that can be made to improve existing facilities. It is appreciated that this is a difficult 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 It is advised at paragraph 2.4.6 of the SA that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses), are likely to increase greenhouse gas emissions in the plan area by more than 1% and adversely affect climate change in the future. Developments of between 50 to 500 dwellings could increase carbon emissions in the plan area by more than 0.1% and have a lesser effect on climate change. As a consequence, it is effectively concludes that larger schemes are likely to result in a greater amount of greenhouse gas emissions than smaller development proposals. 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. That housing requirement will be delivered through various residential developments of different sizes. The greenhouse gas emissions from the construction operation of these properties will have a total accumulative effect based on the total number of houses built. This significance will be broadly the same, regardless of whether the houses are delivered through a larger number of small sites or a smaller number of large sites. The SWLP should consider the most appropriate way of delivering the houses in order to try to reduce greenhouse gas emissions because although larger developments may have relatively bigger higher emissions of greenhouse gases the amount emitted to deliver all the housing need will remain unchanged. 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. It is inappropriate for it to be immediately assumed that the development of greenfield sites can have adverse effects on flooding, drought and storm events. 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 in the SA. However, the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in this 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. That being the case, the conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information 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. Furthermore, it is recognised and recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. Consequently, the landscape appraisal selection of the SA should be treated with caution as the evidence base is not complete. Cultural Heritage It is advised at paragraph 2.8.3 of the SA that 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 must, therefore, be treated with caution. Where site specific heritage information has been provided with our Call for Sites submission, 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. In addition, it is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability impacts due to road related air and noise emissions. These conclusions do not automatically follow as it is possible for sites within the metres of railway lines and main roads to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources We are concerned with the SA 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. 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 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 advises that sites that are more than 400 metres from a bus stop and sites that are 800 metres from the food store will receive a negative rating. 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 these larger schemes to include a local centre. As a consequence, the assessment criteria must be treated with caution as part of the site selection process. 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. Indeed, we would expect 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, in all likelihood, likely to provide employment opportunities as part of the overall proposals. It is, therefore, inappropriate to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision. Initial Identification of Settlements The 30 settlements identified in paragraph 3.5.2 of the report are a combination of the main settlements, that expect to be able to deliver up to 2,000 homes, as well as smaller locations that might be able to deliver between 50 and 500 homes. It is incorrect to exclude Bishop’s Itchington from the list of settlements that were evaluated. Bishop’s Itchington is a sustainable settlement. It has a school, various services and facilities and employment opportunities. It has been identified as a suitable location for the allocation of Reserve Housing Sites through the Site Allocations Plan process. Additional development needs to be directed towards Bishop’s Itchington to support its continued development. It isa significant omission of the plan not to identify Bishop’s Itchington as a broad location or main settlement. This matter should be re-considered.

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Chapter 1 – Introduction A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then, although Part 2 will need to be in conformity with the SWLP, preparation of Part 2 should be undertaken, as far as possible, in parallel with Part 1 in order to expedite its adoption. Even so, it is possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. Every effort should be made to avoid the delays which have resulted in the situation where although the current Stratford on Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not yet adopted. The Plan Period The vision for the Local Plan is set out up to the year 2050. The current National Planning Policy Framework (NPPF) at paragraph 22 states that strategic policies should look ahead over a minimum 15-year period from the date of adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055. As such, we contend that the Plan should have a 30 year horizon and run until 2055. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP, including a Green Belt study. A Green Belt study is absolutely necessary as approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are located within, the Green Belt. All the train stations that will deliver Growth Options 1, 2 and 3 are in the Green Belt. It is inevitable that the emerging plan will need to remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is essential in order to understand the sensitivity of different parts of the Green Belt to development. In order to support this matter our updated Call for Sites representations consider the Green Belt constraints and opportunities associated with BDW’s land interests at Bearley Station.

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Chapter 3 – Vision and Strategic Objectives Q.V3.1: The Vision The Vision outlined in the Draft Plan is appropriate, as are the objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities. Delivery of the SWLP should be achieved in a sustainable way that responds to the climate emergency and meets the five overarching objectives. This will ensure that the right development will be delivered in the right places. The Strategic Objective A number of the Strategic Objectives identified in the Draft Plan are appropriate and should be translated in to policy in the following way. • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. There is the opportunity to include allocations in the SWLP that will deliver infrastructure that supports not just the proposed development, but also delivers facilities that can benefit the local area as a whole. For example, the introduction of a primary school as part of a wider development next to a village that has limited primary school capacity, or no primary school at all, is an example of how this objective could be met. • Developing opportunities for jobs is an entirely appropriate objective – Delivering employment opportunities alongside new residential development proposals is an important way of creating job opportunities in sustainable locations. Furthermore, making residential allocations in locations that have easy access to employment opportunities by sustainable transport modes, such as rail and bus, should be the preferred approach in planning to support economic development. Residential and mixed use sites that can provide facilities to help and encourage people to work close to home should be supported. • Delivering homes that meet the needs of all our communities –Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. While the focus should be on larger strategic allocation that can make meaningful contributions to the housing need, smaller allocations will still be required to allow smaller settlements to meet their needs. • Contributing towards a net zero carbon target – Development opportunities that can provide significant amounts of green infrastructure and have access to services and facilities by sustainable means, such as train stations, and which can incorporate Active Travel should be preferred locations for allocations. • Connecting people to places – This is an important objective that will increase and improve access by sustainable and active travel modes. Allocations that are located close to public transport opportunities, educational facilities, green spaces and employment opportunities, or can provide these opportunities on site, should be preferred. • Protecting and enhancing environmental assets – The SWLP should look to support allocations that can provide significant biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.

The Sustainability Appraisal has been very broadly applied and as such does not accurately reflect the sustainability of land around the settlements. At Bearley, for example, the appraisal does not accurately assess the land in the vicinity of the station (Site 243) or the deliverability of the sustainable transport Growth Options at the site. Attached to these representations at Appendix 1 is a response to the Sustainability Appraisal for the land at Bearley Station which shows why site specific appraisals should be undertaken. If this is not done then sites which are entirely appropriate as allocations may be excluded from consideration.

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