Issue and Options 2023

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Local Housing Need 4.69 As part of the emerging evidence, the IO document refers to an updated Housing and Economic Development Needs Assessment (HEDNA) that has been produced for the whole of Coventry and Warwickshire Housing Market Area (C&WHMA) using the latest information from the 2021 Census. As rightly stated, the HEDNA uses as the starting point for assessing housing need the standard method set out in Planning Practice Guidance (PPG). 4.70 The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. Nonetheless, the HEDNA has modelled an alternative approach based on the Census 2021 early data releases from June 2022, based on apparent issues with estimating and projecting the population in Coventry, particularly relating to potential discrepancies in the estimates of the population that have informed the 2014-based household projections. The alternative need figure is 4,906 dwellings annually across the sub-region. 4.71 Table 9 of the IO document (and Table 15.1 of the HEDNA) shows a breakdown of the overall housing need for each constituent local authority. 4.72 RPS notes that under the alternative ‘trend-based’ (‘revised standard method’) projection the need is higher for both SW authorities compared to the standard method need figures (1,679 dpa under the alternative projection, versus 1,239 dpa using the standard method), an extra 440 homes per annum across the SW area. The trend-based projection is also higher in Rugby, but lower in North Warwickshire and Nuneaton & Bedworth, and substantially lower in Coventry. 4.73 The HEDNA goes to great lengths to explain why an alternative approach to the standard method for estimating local housing need across the sub-region is justified on the basis of ‘exceptional circumstances’, which is required to meet the policy test set out at paragraph 61 of the NPPF. In a nutshell, when looking at population change over the preceding period (2011-2021) the HEDNA claims that a discrepancy exists between the population (mid-year) estimates devised by ONS, and those derived from the Census 2021 population count. 4.74 Table 5.2 and 5.3 of the HEDNA seeks to illustrate this discrepancy. These tables show that population across the sub-region was substantially lower in the Census (942,100) compared to the mid-year estimates (963,173), largely as a result of an over-estimate in the population for Coventry. However, it is also notable that the Census output shows a higher population for both Stratford-upon- Avon and Warwick districts, a total difference of 6,316 extra people residing in South Warwickshire in 2021. This additional number of people will clearly have an impact on future population estimates for the SW area when properly accounted for in future projections. 4.75 On this basis, paragraph 5.105 explains the HEDNA proposes a trend-based projection taking account of the 2021 Census, more recent data around fertility and mortality, analysis of recent migration trends, from which household estimates are then derived (using the 2014-based household formation rates). The remodelled household projections are then fed back into the standard method through the application of the affordability adjustment, to generate the overall housing need figures for each area. 4.76 The local housing need derived from the trend-based projections is provided at Table 5.33 of the HEDNA. Whilst the overall approach is broadly understood, reference is made at paragraphs 5.149-5.150 of the HEDNA to a ‘further adjustment to deal with any suppression of household formation within the projections’ and ‘part return to trend’ analysis based on a refinement of the 2014-based household representative rates (HRRs). The results from the adjusted HRRs are shown in Table 5.34. The figures show an increase in household growth across the sub-region (by +3,000) compared to baseline trend-based projection, and increased household growth for Stratford-upon- Avon and Warwick districts. However, the HEDNA does not consider any further what implications this adjustment might have for the estimate of overall housing need across the sub-region, or for the SW area specifically. 4.77 RPS recommends that the adjustment for household suppression presented in the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in the SW area.

4.78 Chapter 8 of the HEDNA includes an analysis of affordable housing need in Coventry & Warwickshire, which is claimed to follow the methodology set out in the PPG12 . Table 10 of IO document summarises the assessment of need for the SW authorities. 4.79 It is recognised in the published evidence base that affordable housing need is ‘high’ relative to the overall housing need across the C&WHMA (paragraph 4.4 of the HEDNA). RPS agrees. Table 8.14 of the HEDNA illustrates this point when comparing affordable need (rented need only) to the trendbased projections for each authority, including Stratford-upon-Avon and Warwick. 4.80 The figures show that the rented affordable need as a proportion of the overall need for housing in the SW authorities is between 48-72% (or 60% across the two combined). Across the C&WHMA as a whole, the proportion is 78%. When adding in the affordable home ownership need, the proportions increase from 60 to 82% for the SW area, and from 78 to 91% for the C&WHMA. It is clear that the proposed policy targets will only deliver a fraction of the homes needed even if the policy requirements are met in full (which is unlikely). Affordable housing need therefore represents a significant proportion of overall need which needs to be addressed in the SWLP, and across the HMA as a whole, when considering future housing targets for the area. This is particularly the case in Warwick but is nonetheless still an important factor in Stratford also. 4.81 In addition, the scale of affordable need as a proportion of total need shown above is, to a large extent, due to the need emanating from Coventry, which is 96%. The HEDNA (at paragraph 8.72) recognises that, in setting overall housing targets, the viability of development and the availability of funding are realistically constraints on the level of provision which can be achieved. If Coventry is to make any significant contribution towards meeting its own housing needs, of all tenures, then additional allocations will be needed. This will require a considerable focus on delivering more housing on previously developed sites within the city’s boundaries and the push for higher policy targets. However, the focus on brownfield land and higher policy standards will inevitably raise concerns with the viability and deliverability of lower value housing. This is evident because Coventry has failed to deliver its affordable housing policy targets since 2011, achieving 2,562 affordable homes against a policy target of 3,828 (2011-2022)13, or 232 homes per annum. 4.82 On this basis, in devising an overall housing requirement in the SWLP, if the SW authorities are serious about addressing affordable housing delivery, then consideration should be given to how the delivery of affordable can be maximised across the C&WHMA in order to deliver sufficient affordable homes to meet local needs, in line with national policy 14. The best way to increase the supply of affordable housing across South Warwickshire is therefore simply to allocate more land in sustainable locations within the area. This is best achieved through the development of mixed-tenure private sector-led development in areas where viability is less of a problem, notably in South Warwickshire, relative to metropolitan areas such as Coventry. 13 Coventry City Authority Monitoring Report 2021/22 Published 21st November 2022, Figure 9 14 NPPF 2021, paragraph 20

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4.83 This chapter of the IO document provides a commentary on a range of factors relating to policies for the provision of housing, including the scale (or need), type, size, and tenure of new homes to meet the needs of local communities. 4.84 As a general comment, this chapter is the first point at which the overall growth strategy for housing is considered in any detail in the IO document. This is after the IO document has already considered the spatial options for growth in chapter 4 (under Issue S7). This approach runs the risk of predetermining the distribution of growth before establishing the level or scale of growth that should be planned for. As highlighted in response to Issue S10, RPS recommends that the SWLP considers a different approach to devising the strategic policies relating to planning for the growth needs of the area by presenting the case for growth before considering distribution, rather than the other way round. This will ensure the SWLP is presented in a logical and coherent manner where distribution of development is properly considered in light of the scale of growth needed in the area.

5.1 The Planning and Compulsory Purchase Act requires a sustainability appraisal to be carried out on development plan documents in the UK. Additionally, the Environmental Assessment of Plans and Programmes Regulations15 (SEA Regulations) require an SEA to be prepared for a wide range of plans and programmes, including local plans, to ensure that environmental issues are fully integrated and addressed during decision-making. 5.2 It should also be noted that SA is an iterative process and, as such, should be undertaken alongside development of the SWLP as it moves forward through the various stages in order to maximise its sustainability credentials. This includes taking into account responses made by stakeholders to the SA and SWLP consultations as part of the plan-making process, including those submitted by local and national house builders. In this context, the IO document explains (page 26) that the SA process will take on board any comments on the SA and use them to furnish the next report with greater detail and accuracy. 5.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) and provide a response to the question below. Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on. General Comments 5.4 The IO document explains under Issue I1 that the IO SA has been prepared to support the Issues and Options Consultation which explores the following reasonable alternatives as part of the plan making process: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages; and • 88 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. 5.5 The IO SA also includes an ‘assessment’ of two housing number options, presented at Chapter 9 (Volume 2), but these are not listed in the IO document alongside the alternatives shown above. 5.6 The Sustainability Appraisal Framework and methodology is set out in Appendix A of the IOSA. The SA Framework comprises 13 SA Objectives, decision-making criteria (in the form of specific questions) and indicators used to appraise the sustainability performance of the reasonable alternatives as identified in the IO document. 5.7 Further detailed guidance is then provided in the form of ‘topic-specific methodologies’ for each SA Objective in sections 2.4-2.16 of the IO SA. The IO SA states (at para 2.3.3, volume 2) that these have been established which reflect the differences between the SA Objectives and how each receptor should be considered in the appraisal process. Having reviewed the detailed appraisals in the appendices, it appears that the topic-specific methodologies form the basis for the detailed appraisals of each option. However, none of these methodologies are referred to specifically in the SA Framework. It is therefore unclear how the SA Framework has been devised or how it has been applied in appraising each option, given there is scant reference to it in the evaluation of options or the detailed commentary in the supporting appendices. 5.8 Similarly, the SA Framework is highlighted in some chapters as being used to appraise some options, but not others. This lack of consistency suggests an arbitrary approach has been taken as a basis for the IO consultation and which adds further to the confusion as to how the SA Framework has been devised and then applied in the appraisal of options at this stage. This lack of clarity and consistency in how the SA Framework has been applied undermines the transparency in the SA process, which is critical to ensure the appraisal is both robust and credible. 5.9 This is evident when considering the approach to SA applied across different categories of options. Notably, this is of concern regarding how the housing number options have been assessed and presented in the IO SA, which is explained further in the next section. 5.10 In addition, Schedule 2, paragraph 7 of the SEA Regulations specifies that the Environmental Report (effectively the IO SA report at this stage) must include ‘the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme.’ Section 2.17 of the IO SA provides a brief commentary on how potential offsetting (or ‘mitigation’) of significant effects has been considered at this stage based on a mitigation hierarchy (see Table 22.15 of the IO SA for details). However, whilst some initial mitigations have been suggested for some categories of options, none have been identified for the generic policy options (see IO SA Appendix E) nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potentialmitigation hasn’t been identified for these options. This again points to a lack of clarity and consistency in how the options have been appraised which further undermines the transparency in the process. 5.11 Lastly, the IO document provides a commentary on the potential of the SWLP to accommodate unmet needs from the wider Birmingham and Black Country HMA, under Issue H4. Page 112 of the IO document states that ‘For the purposes of the accompanying Sustainability Appraisal we have tested the effects of an additional 5,000 and 10,000 homes’ as possible contributions towards any unmet need. However, the IO SA has not appraised any such contribution, or undertaken any appraisal of possible locations where such unmet could be accommodated. This brings into play consideration of other locations which are located in close proximity to the local authorities with the Greater Birmingham and Black Country HMA, notably on the edge of Redditch. Consequently, the potential contributions of 5000 or 10,000 dwellings to address unmet need as outlined in the IO document, and the spatial options to accommodate this need, represent reasonable alternatives that should be considered through the SA process for the SWLP. This should be undertaken and presented in the next iteration of SA, and a suitable policy response should also be presented in the draft (preferred options) version of the SWLP. SA of Housing Number Options 5.12 Figure 3.2 of the IO SA identifies two housing number options. These options are derived from the updated Coventry & Warwickshire Housing and Economic Needs Assessment (HEDNA) ‘trendbased’ projection (Option I); and the Government’s standard methodology for calculating housing need in South Warwickshire as set out in the Planning Practice Guidance (Option II). 5.13 The two housing number options are as follows: • Option I: The HEDNA trend-based projections point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. Combined total of 1,679 per annum. • Option II: The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Combined total of 1,239 per annum. 5.14 The extent of the appraisal of these two options is set out in Chapter 9 of the IO SA. RPS raises two broad concerns regarding the approach taken in the IO SA. Firstly, it is clear that the appraisal of the housing numbers has been carried out differently to the appraisal of the other options. For example, the appraisal of the housing numbers has been described as an ‘option assessment’, whereas the appraisal of the other options is described as an ‘evaluation’. This suggests a separate approach has been taken in the appraisal of the housing number options. Similarly, there is also a distinct lack of detail underpinning the specific scoring of each housing number option against the SA Objectives (summarised in section 9.1 of the IO SA) with only a very brief commentary in Chapter 9 stretching to just one and a half pages; whereas the appraisal of other options is presented in considerably more detail in individual appendices (B to E) alongside specific chapters for each category of options in the main report (Ch 4 to 8). In contrast, there is no separate appendix which fully explains the scoring for the housing number options. 5.15 Determining the overall scale of housing growth to be planned for in South Warwickshire is a key requirement of the local plan process, a process that should be underpinned by a rigorous testing of all reasonable alternatives. However, no explanation is provided for why a different approach is merited for the housing number options. This again points to a lack of consistency and transparency in approach across the various options appraisals, which risks undermining the SA process. 5.16 Secondly, as explained the IO SA has identified and appraised two housing number options. Nonetheless, there is at least one other option for the housing requirement that has not been considered in the IO SA. This additional alternative option relates to a ‘part-return-to-trend’ analysis of projected household change set out in the HEDNA (see paras 5.149 to 5.152) and which is summarised for the Coventry & Warwickshire authorities in Table 5.34 of that document. This is a matter RPS has raised in separate submissions under Issue H1. 5.17 The HEDNA analysis points to different, higher household growth projection for the South Warwickshire authorities which takes into account past suppression in household formation and which should be addressed in the SWLP and, as such, supports the wider SA Objective for housing (SA Objective 9). However, these alternative growth projections have not been included in the IO SA report. In RPS’ view, the ‘part return to trend’ projections for the South Warwickshire authorities constitute reasonable alternatives that should be tested through the SA process. RPS recommends that the alternative household growth projections set out in Table 5.34 of the updated HEDNA should be incorporated into the appraisal of reasonable options as part of the next iteration of the SA. 5.18 In terms of the actual assessment of the two housing number options, the IO SA (paragraph 9.1.3) acknowledges that ‘…using the HEDNA figure should more accurately represent local housing needs than the Standard Method and therefore Option I should meet the accommodation needs of the various members of the community more successfully’. RPS broadly agrees with this position. 5.19 Nonetheless, the IO SA claims (at paragraph 9.1.4) that the housing number options could have negative impacts on SA Objectives 1, 3, 6 and 7 including ‘major negative impacts’ on climate change and on biodiversity. However, no account is taken here of the likely positive climate impacts expected once the Government introduces changes to building regulations on carbon emissions from new residential buildings through the Future Homes and Buildings programme by 2025. Nor does the appraisal reflect the implementation of Biodiversity Net Gain (BNG), which will become increasingly important in delivering well-designed and environmentally sensitive housing development over the coming years and decades in South Warwickshire, and across the country. The measures introduced through Future Homes and BNG are likely to place a downward pressure on climate impacts from new development during the plan period to 2050. The SA of housing number options should be adjusted to take these factors into account. 5.20 In addition, the IO SA (at paragraph 9.1.4) does acknowledge that the loss of agricultural land cannot be avoided in addressing future housing growth needs. This is evidenced in the Urban Capacity Study, which RPS has been commented on elsewhere in this submission (under Issue S4). It is worth reiterating again that the published evidence shows a significant shortfall in land availability within existing urban areas across South Warwickshire that will need to be tackled as the SWLP process moves forward. RPS broadly agrees with this position. SA of Small Settlement Locations 5.21 Chapter 5 of the IO SA appraises 22 alternative Small Settlement Locations where between 50 and 500 homes could be directed. RPS notes that locations around Bidford have been identified as reasonable alternative small settlement locations, which is welcomed. As shown in Figure 5.1 of the IO SA and in more detail in Appendix C of the IO SA in Figure C.3.1 which is shown below, the site is included within the area identified as potentially suitable for development. Appendix C of the IO SA provides an individual appraisal of all of the land identified as being potentially suitable as a small settlement location at Bidford, with the approximate location of the Kings Meadow Phase 2 site indicated by a red star 5.22 Whilst RPS recognise that the IO SA is an early stage in the overall SA process it is not clear, apart from reducing the workload of the team preparing the SA, what the value is of ‘lumping together’ for the purposes of assessment various potential sites at locations considered potentially suitable for accommodating small settlement locations. In particular, the performance of individual parcels of land will differ against the SA objectives. Notably the Settlement Design Analysis document included within the Technical Evidence for the IO consultation considers individual sites on a more granular basis. 5.23 Specifically in relation to the Kings Meadow Phase 2 site and the assessment of all potential sites at Bidford-on-Avon a number of the conclusions drawn for the wider area are not applicable to the site in isolation. Furthermore, RPS contend that in some aspects the scoring of the general options is inaccurate. Set below is further commentary on each objective. SA Objective 1: Climate Change 5.24 It is unclear that the general assessment for this objective has taken into account the forthcoming introduction of the Lifetime Homes Standard in 2025. RPS suggest that when this is considered that rather than scoring as a minor adverse affect that new developments should be assessed as being neutral. RPS note as well that in principle the delivery of new homes built to the updated standards is preferable to the alternative of potential overcrowding of existing homes built to less stringent standards in the past that perform poorly in terms of energy efficiency. SA Objective 2: Flood Risk 5.25 RPS note that settlements where all of the land considered falls within Flood Zone 1 have been assessed to have a positive impact on flood risk, whereas locations where some land falls within Flood Zones 2 or 3 are considered to have a negligible impact on flood risk. The Kings Meadow Phase 2 site is solely located in Flood Zone 1 and so on this basis when assessed alone should score as having a positive impact on flood risk. 5.26 On page 15 of the Officers Report for the phase 1 scheme to the south of the site in relation to flood risk it states: “The site is located within Flood Zone 1 (lowest risk of flooding) where residential development is considered acceptable in principle by the NPPF in relation to flood risk.” 5.27 The NPPF continues to support residential development on land within Flood Zone 1. SA Objective 3: Biodiversity 5.28 The assessment for Bidford-on-Avon set out in Appendix C to the IO SA highlights that there are Local Wildlife Sites within the wider area assessed as a potential Small Settlement Location. RPS have reviewed the digitally mapped Local Wildlife Sites available as additional information on the interactive ‘Call for Sites’ map16. There is a Local Wildlife Site that is associated with Small Brook, which runs along the northern boundary of the site. It is clear that development of the site could be undertaken in such a way as to not adversely impact on this Local Wildlife Site, and in fact could offer opportunities for it to be improved. 5.29 The other factor cited under this objective set out in Appendix C to the IO SA relates to priority habitats. RPS have used DEFRA’s magic maps17 service to undertake a desktop assessment of whether there are any priority habitats identified on the site. As is shown below, there are no priority habitats identified on the site. 5.30 RPS consider that the development of the site in isolation should be assessed against this objective as a minor positive. SA Objective 4: Landscape 5.31 As set out in the accompanying vision document (see Appendix A) the Council’s 2011 Landscape and Visual Impact Assessment indicates that “…Housing development could be accommodated south of Small Brook in order to be screened from the wider landscape and to be consistent with the existing housing edge...” 5.32 In this regard, the Kings Meadow Phase 2 site is located to the south of Small Brook and in a location which has therefore been assessed as being able to accommodate future growth without further landscape evidence being required. This is in contrast to other sites assessed collectively as the Small Settlement Location which include areas of land that have been assessed as being of ‘high -medium’ landscape sensitivity, and which could lead to coalescence if not developed sensitively. Given that this does not apply to the Kings Meadow Phase 2 site RPS suggest that a neutral assessment against this objective is appropriate. 5.33 The Officers Report for the planning application for the phase 1 development states on page 12: “I concur with the findings of the Landscape Sensitivity Assessment that long distance views of the site are limited and that development of the land will have limited impacts on the landscape character of the area with medium scale visual impacts, subject to appropriate structural landscaping along boundaries of the site, which the submitted Parameters Plan achieves. I also take note of the comments of the MADE Design review Panel who consider that if there is to be more development in Bidford it makes sense to build in the gap formed by the ribbon developments of Waterloo Road and Victoria Road, and that the proposals would have the advantage of creating a much better northern edge to the settlement.” (RPS emphasis) 5.34 It is suggested that these comments on landscape are also relevant to the site. SA Objective 5: Cultural Heritage 5.35 The Small Settlement Location at Bidford-on-Avon includes land that if developed could have impacts upon: • A Grade I Listed Building • A Grade II Listed Building • A Conservation Area • A Scheduled Ancient Monument 5.36 However, the development of the Kings Meadow Phase 2 site would not have any adverse impacts on any of the designated heritage assets as they are screened from the Site by intervening built development and the local topography. The development of the land to the south of the Site has further lessened any potential impacts on the Listed Buildings and Conservation Area to the south. RPS consider that a neutral assessment against this objective is appropriate for the Kings Meadow Phase 2 site. SA Objective 7: Natural Resources 5.37 RPS note that as set out at paragraph 5.9.2 of the IO SA that the loss of more than 20 ha of Best and Most Versatile land would be considered to be a major adverse impact. However, in isolation the development of the site would be just 4.2 ha meaning that it follows that the assessment of the site should be minor adverse against this objective. SA10: Health 5.38 RPS note the variability of assessment of the Small Settlement Locations against this objective. However, it is unclear how Hatton Station, which only have a positive impact against a single criteria can be scored the same as Bidford-on-Avon, which receives a number of minor positive assessments against different sub criteria, as well as a major positive against one sub criteria. It is suggested that Hatton Station should not be scored so favourably against this objective. 5.39 Bidford-on-Avon scored three minor positive assessments as well as one major positive and one neutral against the sub criteria for this objective. In contrast it was only given two minor negative assessments. On balance it is suggested that overall a minor positive assessment is a more appropriate assessment of Bidford-on-Avon. SA11: Accessibility 5.40 It is assumed that the Settlement Design Analysis has been used to inform the assessment against the sub criteria for connectivity. As set out earlier the assessment for the Kings Meadow Phase 2 site is contested as it does not account for access via Miller Homes’ phase 1 development to the south. The site has good connectivity when this is taken into consideration. 5.41 It is suggested that a minor positive assessment is appropriate for the Kings Meadow Phase 2 site in isolation. Overall Assessment of Kings Meadow Phase 2 in isolation 5.42 Set out below is RPS’ overall assessment of Kings Meadow Phase 2 in isolation compared to the assessment of the combined sites at Bidford-on-Avon as a Small Settlement Allocation IO SA Of Bidford SA1: Climate Change - SA2: Flood Risk 0 SA3: Biodiversity - SA4: Landscape - SA5: Cultural Heritage - SA6: Environmental Pollution - SA7: Natural Resources -- SA8: Waste - SA9: Housing ++ SA10: Health - SA11: Accessibility - SA12: Education - SA13: Economy + RPS of Kings Meadow Phase 2 SA1: Climate Change - SA2: Flood Risk + SA3: Biodiversity + SA4: Landscape 0 SA5: Cultural Heritage 0 SA6: Environmental Pollution - SA7: Natural Resources - SA8: Waste - SA9: Housing ++ SA10: Health + SA11: Accessibility + SA12: Education - SA13: Economy + 5.43 When considered in isolation the Kings Meadow Phase 2 site performs far more positively than when considered as part of the wider Small Settlement Location at Bidford-on-Avon. 5.44 RPS recommends that a finer grain of assessment should be carried out to inform consideration of the quantum growth to be assigned to each ‘Small Settlement Location’, as well as consideration of potential non-strategic site allocation options at Bidford-on-Avon as part the Part 2 SWLP. SA of New Settlement options 5.45 RPS has made separate submissions on the seven potential new settlement location options identified in the IO document under Issue S5. Details of the SA assessments of these locations are set out in Chapter 6 and Appendix D of the IO SA. 5.46 Paragraph 3.8.1 of the IO SA states that the seven new settlements locations have been identifiedby the two Councils. The commentary in the IO document under Issue S5 (on page 49) points tothese seven locations being drawn from seven larger areas that are simply based on the rail corridors outside of existing urban areas. These areas and locations are shown in Figure 12 of the IO document. The IO SA (3.8.1) then clarifies that the SA Team has prepared a ‘spatial expression’ of each New Settlement using a ‘crude 250ha area of search in a circular search area’ around the approximate location provided by the Councils in the IO document (which RPS assumes to be taken from the elements shown in Figure 12). 5.47 This appears to be the sum total of information and evidence that has informed the identification and selection of these locations as potential new settlements up to this point. Significant uncertainty remains as to where these locations might be located or their full extent. In this regard, RPS notes a significant lack of progress in developing the evidence base required since the Scoping Consultation in 2021. Therefore, there remain substantial doubts as to the suitability or deliverability of any of these potential locations as being able to deliver a new settlement. Consequently, a significant measure of caution must therefore be applied to any of the outputs from the SA process at this stage, until the vacuum in the evidence base to support these new settlement locations is prepared and made available to the public. 5.48 That said, the findings summarised in Table 6.1 of the IO SA indicate that all seven new settlement options would have significant negative effects across a range of sustainability criteria. Added to this the need for a considerable amount of work required to inform a suitable policy framework to guide their development, there is no confidence that any of these locations are capable of being delivered as new settlements based on the current position. SA of Spatial Options 5.49 Details of the SA assessments of the five spatial growth options are set out in Chapter 7 of the IO SA. RPS notes there is no accompanying detailed appraisal in the SA appendices. 5.50 Table 7.1 of the IO SA (and Table 7 of the IO document) provides a summary of the appraisal findings for each option. As stated on page 59 of the IO document, the various growth options are not materially different from one another, with the exception of ‘Dispersal’ option, which scores slightly lower in terms of sustainability performance against some SA Objectives. The IO document also points out that detailed locational information has not been taken into account at this stage, which means there is uncertainty regarding the nature and significance of the effects at this stage. It is therefore important that the findings from the SA are considered in the round alongside other relevant evidence regarding the suitability of specific locations and settlements in supporting the delivery of the spatial development strategy. 5.51 RPS has provided a response to the spatial growth options, under Issue S7, in respect of Bidford-on-Avon where Kings Meadow Phase 2 is being promoted by Miller Homes. The submissions highlight that Bidford-on-Avon is identified under the ‘Sustainable Travel’, ‘Economy’ and ‘Sustainable Travel and Economy’ options, as well as the ‘Dispersal’ option. In this context, there is nothing presented in the IO SA which indicates that growth should not be directed to Bidford-on-Avon on sustainability grounds. To the contrary, directing growth to Bidford-on-Avon would support a number of spatial options that are shown to perform relatively well in sustainability terms. 15 The Environmental Assessment of Plans and Programmes Regulations 2004 (No. 1633) 16 https://soadc.maps.arcgis.com/apps/webappviewer/index.html?id=c9f9579706974081a054de1b14a66130 17 https://magic.defra.gov.uk/MagicMap.aspx

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6.1 Alongside the IO document, a ‘Settlement Design Analysis’ evidence base report (referred to here as ‘the report’) has been prepared to help identify opportunities and constraints to growth in and around the edges of a number of settlements and locations across South Warwickshire. The analysis in the report focuses on three factors; Connectivity, Accessibility, and Density. A primary purpose of the report, as stated at paragraph 2.1 of the report, is to aid understanding of the potential to achieve the ’20-minute neighbourhood’ concept in those settlements identified, and is designed to support the development of the spatial strategy for South Warwickshire. Page 44 of the IO document also points to ‘other factors’ outside the scope of this analysis relating to the potential for growth. However, the report does not identify those here or explain how these will be taken into account in determining where growth will be directed. RPS seeks further clarification on this as the SWLP moves forward. Settlement Selection 6.2 The settlements included in the analysis are listed in Table 2 of the IO document. These, the IO document claims, have been selected based on their status in the existing Local Plans and those that fall within certain growth options. Section 3 of the report provides some commentary on the reasoning behind the selection process. RPS notes that Bidford-on-Avon has been included in the report, which is welcomed. 6.3 RPS has reviewed the evidence in relation to Bidford-on-Avon and provides comments on this below. Connectivity Analysis 6.4 The report (at paragraph 2.4) defines ‘Connectivity’ as ‘the physical connectivity of the existing street pattern, and any physical barriers which limit route/connection options’. In this context, the analysis considers the extent to which a particular route is connected to others within the network. To do this, the evidence on Connectivity is further broken down into three sub-elements; Settlement Structure Analysis, Landform Analysis, and Connectivity Grade Analysis. The report states (at paragraph 4.11) that the evidence gathered and analysed enables comparison of different directions for potential growth around settlements, in terms of their ability to connect into the established ‘structure’ of the settlement, and the opportunities and constraints in this respect. Settlement Structure Analysis for Bidford-on-Avon 6.5 Appendix 2 of the report provides summary mapping and supporting commentary to illustrate the findings of the analysis for Bidford-on-Avon settlement on Connectivity. An extract from the report for Bidford-on-Avon is appended to this submission (Appendix B). The Kings Meadow Phase 2 site is identified as area / segment 6 Bidford-on-Avon (emphasis on our area / segment 6 location) 6.6 In summary, the analysis shows that Segment 6 has an overall Connectivity Grade ‘D’. According to Table 5 of the report, a ‘D’ score means there are ‘significant barriers which would be difficult to overcome’. In addition, the segments in this category either connect to green route, loops or cul-de-sacs only, with limited or no potential to connect these into new red route with limited or no potential active links e.g. via green / blue infrastructure or other active links. For Segment 6, RPS notes that under barriers it is suggested that access would have to be via either farm track or extending neighbouring cul-de-sacs. Whilst this is true, what is not acknowledged is that in the specific case of Kings Meadow Phase 2 the cul-de-sacs are being delivered by the same developer and as such in this case there are no barriers whatsoever as access to Kings Meadow Phase 2 will be ‘designed in’ by Miller Homes through land it already controls via their recently completed Phase 1 (as addressed in the site specific section of these representations and the accompanying Vision Document). 6.7 The supporting commentary should also be updated to reflect this specific circumstance. Landforms Analysis for Bidford-on-Avon 6.8 Appendix 3 of the report provides summary mapping to illustrate the findings of the analysis for Bidford-on-Avon settlement on Landforms. The outcome of the analysis is appended to this submission (Appendix C). Under this element, the analysis that no specific landforms of relevance have been identified for segment 6. This indicates that topography in this part of the settlement edge will not impact on the deliverability of development in this location. Accessibility Analysis for Bidford-on-Avon 6.9 Under this element, the analysis measures proximity of each segment to nearby local services and facilities (across five categories of facility) using a threshold of 800 metres to represent a 10-minute journey on foot. The findings for Bidford-on-Avon are appended to this submission (Appendix D). 6.10 The results indicate that out of a score of five, Segment 6 scores five indicating access to all types of infrastructure. On the basis of a revised connectivity score as suggested above, Segment 6 performs well when all analysis is considered in the round and so constitutes an appropriate direction for growth at Bidford-on-Avon. Density Analysis for Bidford-on-Avon 6.11 For this part of the analysis, density maps prepared for each settlement give an indication of the prevailing densities in these locations, which may then inform assumptions about typical density ranges that may appropriately be applied to any growth in the locality if relevant to [preferred] spatial options, and therefore the approximate capacity of different areas of land. A Density Analysis map for Bidford-on-Avon has been produced and is appended to this submission (Appendix E). 6.12 For Bidford-on-Avon, the analysis indicates a general pattern of relatively denser development categorised as ‘Inner Suburb’ (approximately 40 -60 dph) in the centre of Bidford-on-Avon. To the north and west densities are generally lower and primarily classed as ‘Outer Suburb’ (approximately 20 – 40 dph). This includes the phase 1 of Kings Meadow immediately to the south / south east of the site which is being delivered by Miller Homes at approximately 30 dph. Consequently, given the analysis is based on ‘prevailing’ densities, rather than a precise measure of density (paragraph 4.26 of the report confirms this) RPS would recommend that density thresholds being considered in the SWLP should be applied flexibly to specific sites in Bidford-on-Avon, in order that any prescribed standards reflect the accessibility and potential of different areas rather than one broad density range, in line with national policy 18. 18 NPPF 2021 paragraph 125

Nothing chosen

Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? 7.1 The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage. Whilst the IO document has not requested any responses specifically on the HSSA, RPS has nonetheless reviewed the assessment with respect to Bidford-on-Avon, which is set out below. Identifying potential impacts of development – Bidford-on-Avon 7.3 Bidford-on-Avon has been sub-divided into five sub-areas (North-west, North-east, East, South and West). The HSSA provides a table (not numbered in the report) which summarises the scores, based on a ‘RAG’ rating system, broken down by these sub-areas. The full assessment is provided at section 10.21 of the HSAA, alongside a number of supporting plans. 7.4 In summary, the HSSA scores the North-west and South sub-areas as ‘Red’, and the other three sub-areas as ‘Green’. According to the HSSA commentary, for the North-west this is largely related to concerns regarding the potential impact of large scale development on the conservation area and listed buildings at Broom. However, the assessment was undertaken on a desktop basis as set out in section 4 of the report under ‘Data collation’. Furthermore, the urban extent that has been used to apply the buffer does not include the phase 1 Kings Meadow development, despite this being located within the Bidford-on-Avon Village Boundary as defined in the Bidford-on-Avon Parish Neighbourhood Plan, and the report stating that Neighbourhood Development Plans were included in the information sources that informed the assessment. 7.5 It is clear that a very simplistic approach has been taken, without consideration of land form beyond a very cursory reference to the general character of the landscape. Furthermore, what constitutes ‘large-scale’ development is not defined in the report. 7.6 RPS suggest that very little weight should be attached to the findings of this assessment in relation to identifying the development capacity of Bidford-on-Avon. It is also recommended that that when non-strategic scale development opportunities are considered at Bidford-on-Avon in due course as part of the part 2 SWLP, that a more detailed assessment is undertaken. RPS note that the emerging Site Allocations Plan has not identified any heritage concerns in relation to the development of Kings Meadow Phase 2.