1. The Council's own appraisal identifies significant adverse effects

The Regulation 19 Sustainability Appraisal identifies substantial adverse sustainability effects associated with STR.2. These include significant adverse effects for climate change and landscape, alongside adverse effects relating to flood risk, biodiversity, pollution and natural resources.

Importantly, these effects are identified even after proposed mitigation has been taken into account. The issue for the Examination is therefore not simply whether mitigation is technically possible, but whether the scale and location of STR.2 remain justified once those residual effects are properly weighed.

2. Did sustainability actually inform the choice of STR.2?

Sustainability Appraisal is intended to inform the preparation of the Plan and the choice between reasonable alternatives. The evidence should therefore show a clear chain from the sustainability characteristics of alternative locations, through assessment of their effects, to the eventual selection and scale of STR.2.

The Council's methodology confirms that reasonable alternatives were considered. This makes the comparative evidence particularly important. Where STR.2 has significant environmental disadvantages, the Examination should be able to see why those disadvantages were considered acceptable compared with the alternatives.

There is also a concern where mitigation is used to reduce the apparent disadvantages of the preferred location, while equivalent mitigation is not given the same weight when comparing alternatives.

3. Proximity does not necessarily mean sustainable accessibility

A major part of the sustainability case for STR.2 rests on its proximity to Stratford-upon-Avon and the potential for walking, cycling and public transport connections.

But geographical proximity is not the same as practical accessibility. STR.2 is separated from the existing urban area by the River Avon, A46 and other strategic roads. For approximately 2,700 homes, the relevant question is whether residents can make everyday journeys to employment, schools, services, the railway station and the town centre conveniently, safely and directly without relying on a private car.

If walking and cycling routes are indirect, require difficult crossings or depend upon infrastructure that has not yet been delivered, the existence of a nominal connection does not necessarily provide a genuine alternative to car travel.

4. Mitigation is not the same as avoiding environmental harm

The Regulation 19 SA identifies significant adverse effects for STR.2 including landscape and climate change, together with effects relating to biodiversity, flood risk, pollution and natural resources.

The evidence proposes a range of mitigation measures, including landscape buffers, green infrastructure, biodiversity measures, sustainable transport and flood-risk measures.

These measures may reduce impacts. But they do not answer the strategic question of whether some of those impacts could have been avoided by choosing a different location in the first place.

This distinction becomes particularly important where the effects arise from the scale of development itself. A development of approximately 2,700 homes changes the character and function of a substantial area of countryside and creates associated infrastructure, movement and urbanisation effects.

5. STR.2 cannot be assessed in isolation

STR.2 forms part of a much wider concentration of strategic growth around Stratford-upon-Avon, including SG18, Long Marston Airfield and associated infrastructure.

The combined environmental consequences may therefore be materially greater than those associated with each allocation individually. This is particularly relevant to the cumulative effects on:

6. The carbon evidence still requires scrutiny

The Council produced additional carbon evidence in May 2026, including Bioregional's assessment of the preferred Scenario Golf strategy. This provides useful additional information about transport-related carbon emissions.

However, the review identifies three important limitations.

• The detailed Bioregional assessment was undertaken for the preferred sites rather than being applied consistently across reasonable alternatives.
• The assessment appears not to include the embodied carbon of major enabling infrastructure such as the SWRR and associated highway structures.
• The transport methodology relies on nationally averaged commuting distances rather than modelling likely destinations from each individual strategic site.

These issues matter because the carbon consequences of STR.2 are closely linked to where residents travel, how they travel and the infrastructure required to make the allocation function.

7. Flood risk is a strategic resilience issue

The latest Level 2 Strategic Flood Risk Assessment identifies material flood-risk constraints affecting STR.2, including both fluvial and surface-water risk.

Although most of the allocation lies within Flood Zone 1, the SFRA identifies Flood Zone 3b within the site and notes that the Flood Map for Planning does not represent fluvial flood risk in the upper reaches of Rush Brook.

Climate change increases the concern. The SFRA estimates that the area affected by surface-water flooding increases under the climate-change scenario and describes STR.2 as “highly sensitive” to increases in rainfall.

Important questions also remain about Rush Brook, existing culverts, safe access and drainage. Further detailed hydraulic modelling is expected at the later Flood Risk Assessment stage.

8. Wastewater capacity is already under pressure

STR.2 would add substantial growth to a wastewater catchment which the Council's latest Water Cycle Study identifies as already under pressure.

The Stage 2 Water Cycle Study forecasts 11,142 dwellings being served by Stratford-Milcote Wastewater Treatment Works during the Plan period. It concludes that the works are likely to be close to or exceed their permitted flow and identifies zero estimated spare hydraulic capacity following planned development.

Water quality is also relevant. The Water Cycle Study identifies the potential for a greater than 10% deterioration in water quality for one or more assessed pollutants under the future-growth scenario and identifies phosphate as an amber constraint requiring further intervention.

The evidence also records an average of 35.7 storm-tank overflow spills per year during 2023–25 at Stratford-Milcote, above the Water Cycle Study's threshold for investigation.

9. A sustainable development cannot depend on infrastructure arriving later

A recurring theme across the evidence is that the sustainability performance of STR.2 depends materially upon future infrastructure. This includes sustainable transport connections, strategic highway infrastructure, drainage and wastewater capacity.

The concern is particularly acute if early phases of development can be occupied before the infrastructure on which the sustainability case depends is operational.

Sustainable development therefore requires more than a list of infrastructure that might eventually be provided. The Plan needs to demonstrate that the necessary infrastructure will be available at the point it is required and that its delivery can be secured alongside growth.

Questions for the Examination