Issue and Options 2023

No answer given

Issue T1: 20 Minute Neighbourhoods 5.1 At the local level, RPS notes Table 2 of the IO document which lists a number of existing settlements that have been identified that have been subjected to connectivity, accessibility and density analysis, in order to assess whether there is the potential to deliver 20-minute neighbourhoods. RPS notes that Quinton (and Lower Quinton) has been excluded from the settlement analysis. As explained in this submission, the exclusion of Lower Quinton from consideration in the IO document has not been adequately justified and is premature. 5.2 Furthermore, the rejection of sites and settlements on the grounds that they would not deliver the 20-minute neighbourhood principle could result in limited growth and isolation of these areas. RPS considers this to be an unsustainable approach to development and would invite the Council to consider this principle moving forward. 5.3 Following this, RPS considers the omission of Quinton from the IO settlements to be ill founded. The methodology for determining these sites have been founded on Connectivity, Accessibility and Density. Without discounting the selected sites, RPS has considered that there is some inconsistency with the settlement selection and has applied the three categories in order to demonstrate that Quinton should be included within this assessment:

6.1 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 Regulations17 (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. 6.2 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. 6.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) has provided 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 6.4 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. 6.5 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. 6.6 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. 6.7 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. 6.8 Similarly, the SA Framework is highlighted in some chapters as being used to appraise the 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. 6.9 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. 6.10 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 nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potential mitigation 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. 6.11 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 as not appraised any such contribution, or undertaken any appraisal of possible locations where such unmet could be accommodated. 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 suitable a policy response should also be presented in the draft (preferred options) version of the SWLP. SA of housing number options 6.12 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). 6.13 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. 6.14 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. 6.15 Determining the overall scale of housing growth to be planned for in South Warwickshire is a key requirement of 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 a lack of consistency and transparency in approach across the various options appraisals, which risks undermining the SA process. 6.16 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. 6.17 The HEDNA analysis points to different, higher household growth projection for the South Warwickshire authorities which takes into 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. 6.18 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. 6.19 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. 6.20 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 addressed elsewhere in this submission (under Issue S4) however this shows a significant shortfall in land availability within existing urban areas across South Warwickshire. RPS broadly agree with this position. SA of New Settlement options 6.21 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. 6.22 Paragraph 3.8.1 of the IO SA states that the seven new settlements locations have been identified by the two Councils. The commentary in the IO document under Issue S5 (on page 49) points to these 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). 6.23 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 apply 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. 6.24 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 6.25 Details of the SA assessments of the five spatial growth options are set out in Chapter 7 of the IO SA. 6.26 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 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. 6.27 As highlighted earlier in this submission, the IO document only considers Quinton (and not even Lower Quinton specifically) under Growth Option 5 – Dispersal. RPS argue that Lower Quinton should be included in a number of other spatial growth options (options 1, 2,3 and 5) and so, on this basis, Lower Quinton represents a reasonable option for consideration through the SA process, in accordance with the Regulation 12 of the SEA Regulations dealing with reasonable alternatives. 17 The Environmental Assessment of Plans and Programmes Regulations 2004 (No. 1633)

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.

8 GROWTH AT LOWER QUINTON 8.1 This section explores Lower Quinton as a whole, as well as providing more details about the proposals RPS and RH will be providing through the masterplanning process. Lower Quinton 8.2 Lower Quinton is a civil parish in Stratford-on-Avon and resides in close proximity to settlements named throughout the document such as Meon Vale and Long Marston. For the purpose of this plan, Lower Quinton has been paired with the smaller hamlet of Upper Quinton, recognised under the collective title of ‘Quinton’. As we have noted, Quinton has been outlined as an Option for Dispersal in Chapter 4 of the Issues and Options Document. 8.3 Lower Quinton is well served by local facilities including a village hall, public house, medical practice, a primary school and a post office. As well as hospitality services such as a hotel and a bed and breakfast. Beyond the settlement, the village is close by to the neighbouring settlement of Meon Vale. This recently expanded settlement contains further services, including a convenience store, education and a leisure centre. Importantly, Meon Vale also supports an area of substantial employment through the Business Park, and is also adjacent to the Quinton Rail Technology Centre. 8.4 Getting beyond the village, Lower Quinton is well served by Bus Routes. Main Road running west in Lower Quinton connects to the B4632 which provides a direct link into Stratford-on-Avon. These roads are served by a bus service that runs approx. every hour, Monday to Saturday daytime. As well as this, the B4632 to the south and the Main Road to the west are served by a bus service that completes one return journey or more daily Monday to Friday. Collectively, RPS considers that Lower Quinton supports a number of day to day services, but also benefits from a number of overlapping features which highlight the sustainability of the settlement for growth. 8.5 As previously mentioned in Chapter 4, the settlement would be justified in a number of spatial development options. Going forward, RPS considers that the Councils should reconsider the role of Lower Quinton in relation to the spatial development options 1, 2, 3 and 5, and consider the role that the settlement can make as part of the emerging Local Plan.