Yes

ID sylw: 108155

Derbyniwyd: 07/03/2025

Ymatebydd: IM Properties Development Ltd (IMP)

Asiant : Turley

The approach laid out in Draft Policy Direction 1 is supported.
This is based on the premise that the South Warwickshire Local Plan (SWLP) will plan for
“at least” the following employment land need in Stratford-on Avon, as documented in
Table 4 of the Preferred Option Paper:
• A residual (net) non-strategic industrial need of 139 hectares between 2021-50.
• A residual (net) office need of 3 hectares between 2021-50.
This in addition to the South Warwickshire wide residual (net) strategic industrial site
need of between 75 and 125 hectares over the period 2021-45. It is noted that the SWLP
will use the upper threshold of the 125 hectares, as recommended by the West Midlands
Strategic Employment Site Study (WMSESS) (2024). This is welcomed.
Figure 8 of the Preferred Options Paper helpfully outlines the evidence used to support
the definition of the employment land need in South Warwickshire. IM Properties
Development Ltd (IMP) consider the scope of evidence relied upon is right with
particular support for the conclusions of the WMSESS and Coventry & Warwickshire
Alignment Paper (2024), which apportions need from the strategic level to the local level.
This approach has been missing in plan-making in Warwickshire for more than a decade,
and its return via the alignment paper is welcomed.
Furthermore, the explanatory text to Table 4 rightly sets out:
“Strategic sites in this context refer to large scale employment sites typically over 25
ha and largely dedicated to units of over 9,300sqm (100,000sqft). Non-strategic (or
local) need refers to industrial (B2/B8 class) uses to meet a local need, generally for
units under 9,300sqm (100,000sqft) but also for units over 9,300sqm (100,000sqft)
where these are located on non-strategic sites (<25 ha)..”
IMP take this opportunity to confirm Stratford 46 - which is subject to a hybrid planning
permission (Ref: 19/01402/OUT) and is allocated under the reference Proposal SUA.2 in
the Stratford-on-Avon Core Strategy, and it is a draft policy in the emerging Stratford-onAvon Site Allocations Plan (SAP) - has the capacity to address both the strategic and local
industrial need.
The above is based on the site area measuring 25 hectares and its spatial layout affording
the ability to deliver a range of unit sizes either below or above 9,300m². This flexibility
should be viewed favourably by Stratford-on-Avon District Council, especially in the
context of the Core Opportunity Area and selection of Major Investment Sites (the Draft
Policy Directions for these are responded to separately).
IMP welcome a discussion with Stratford-on-Avon District Council to explore how
Stratford 46 can better respond to the latest evidence on employment land need,
including that relating to industrial and logistics need.

Other

ID sylw: 108156

Derbyniwyd: 07/03/2025

Ymatebydd: IM Properties Development Ltd (IMP)

Asiant : Turley

It is recognised that Draft Policy Direction 13 – Core Opportunity Area will be the focus
for new employment development in South Warwickshire.
However, Figure 10: Core Opportunity Area does not illustrate Stratford 46 as an ‘Existing
Major Investment Site’ despite it being subject to a hybrid planning permission (Ref:
19/01402/OUT) for employment-led mixed-use development, alongside the allocation
and draft allocation (SUA.2) in the Stratford-on-Avon Core Strategy, and Site Allocations
Plan (SAP) respectively.
The focus for employment development should be in the right places. Stratford 46 is
located directly to the west of Stratford-upon-Avon, which, as a town, is sustainably
accessible in terms of labour market supply. Stratford 46 also lies well within the Core
Area Opportunity (as illustrated in orange) in Figure 10, along the A46 which forms part
of the “A46 Trans Midlands Trade Corridor” as described in section 6.2 on page 72 of the
Preferred Option Paper.
Even more so, Stratford 46 lies within Strategic Growth Location ‘SG18’ which has been
identified as a major location for housing and employment growth. There is an
inconsistency between the Strategic Growth Location, the Core Opportunity Area and
sites identified as Major Investment Sites (MIS).
It is recommended that Stratford 46 forms part of the Core Opportunity Area as it is
capable of accommodating businesses wishing to co-locate in the area and take
advantage of the economies of scale, especially those relating to the industrial and
logistics sectors, where residual need is most acute in South Warwickshire.
IM Properties Development Ltd (IMP) has responded separately in relation to Strategic
Growth Location SG18 and Draft Policy Directions 1 and 14 on matters related to need
and its distribution to Stratford 46.

Other

ID sylw: 108157

Derbyniwyd: 07/03/2025

Ymatebydd: IM Properties Development Ltd (IMP)

Asiant : Turley

It is acknowledged that Draft Policy Direction 14 – Major Investment Sites allocates land
which “will be protected for employment uses and will be the main focus of new
employment development in the plan period”.
The identification of Major Investment Sites (MIS) is welcomed; however, it is recognised
that Stratford 46 has not been selected as a MIS despite its allocation in the adopted
Stratford-on-Avon Core Strategy and despite the draft specific site proposals in the
emerging Stratford-on-Avon Site Allocations Plan (SAP) (i.e. Proposal SUA.2). It also
benefits from an extant hybrid planning permission (Ref: 19/01402/OUT).
Stratford 46 is a strategic employment site (as it measures 25 hectares) which has the
capacity to deliver a mix of employment uses, including light industry, general industrial
and storage and distribution, as well as office and retail space. Its importance to the
South Warwickshire economy is significant, and its delivery timescales as defined by the
emerging SAP extend to 2030-2031, which is well within the plan period for the South
Warwickshire Local Plan (SWLP).
It is therefore requested and recommended that Stratford 46 is identified as a MIS in the
SWLP given its supporting role in growing the local and sub-regional economy, which is
currently defined by the following operational economic benefits in line with the hybrid
planning permission:
1. 1,655 on-site jobs.
2. 1,120 net direct jobs (FTE jobs supported in the West Midlands, including 805 in
Stratford-on-Avon).
3. £100.7 million GVA (output per annum, including £61.8 million in Stratford-onAvon).
4. £28.3 million direct and indirect wages generated per annum
5. A range of managerial, professional, technical, skilled and elementary jobs
supported.
6. £2.1 million in business rates (retained each year by Stratford-on-Avon District
Council).
Draft Policy Direction 14 outlines “in broad terms the type of employment uses that
would be considered acceptable in principle”. Subject to the identification of Stratford 46
as a MIS, the employment uses currently acceptable at the site as per existing allocations
and the hybrid planning permission, include the following:
• Light industry, general industrial and storage and distribution.
• Office and research and development.
• Retail (shop and food and drink).
• Other (i.e. car showrooms).
In general, these uses are still attracting interest at Stratford 46; however, since hybrid
planning permission was secured in 2019, the need and market demand for each use has
significantly changed owing to on-going shifts in the context of macroeconomics i.e. post
Brexit trade patterns, the Covid-19 pandemic, and the cost-of-living crisis. This is
particularly relevant for office space, which the ramifications for that sector are
explained at paragraph 4.3 of the South Warwickshire Employment Land Study (October
2024) in reference to the Coventry & Warwickshire Housing & Economic Development
Needs Assessment (2022).
The above is partly reflected in Table 4 of the Preferred Options which identifies a
residual (net) non-strategic industrial need between 2021-50 in South Warwickshire
amounting to 217 hectares, as well as a 75-125 hectares residual (net) strategic industrial
site need between 2021-45 in South Warwickshire. Whereas there is a small residual
(net) office need of 3ha) between 2021-50 in Stratford-on-Avon (with South
Warwickshire wide possibly having a surplus of 11 hectares of office space between
2021-50).
As a consequence of the latest employment land need position, there is an opportunity
for Stratford 46 to accommodate more space for light industry, general industrial and
storage and distribution whilst retaining a wider retail offer for businesses wishing to
relocate to the district or grow premises in the district.
It is noted Draft Policy Direction 14 states “the exact type and quantum of development
to be allocated at each MIS will be determined in subsequent stages of the Local Plan
process”. It is also noted that the type and quantum of development at existing
allocations such as ‘Gaydon – JLR/AML’ and ‘Long Marston Airfield’, which are identified
as major investment sites, are subject to change from policy requirements established in
the Stratford-on-Avon Core Strategy.
Given the above position, IM Properties Development Ltd (IMP) welcome a discussion
with Stratford-on-Avon District Council around the potential to redefine the type and
quantum of development to be re-allocated at Stratford 46 in the SWLP.

Yes

ID sylw: 108158

Derbyniwyd: 07/03/2025

Ymatebydd: IM Properties Development Ltd (IMP)

Asiant : Turley

IM Properties Development Ltd (IMP) supports the identification of SG18 ‘West of
Stratford-upon-Avon Group’ as 1 of 24 strategic growth locations as outlined in Table 5
of the Preferred Options Paper.
The identification of SG18 aligns with the spatial growth priority areas and emerging
growth strategy options as illustrated at Figure 5 and Figure 6 of the Preferred Options
Paper.
Section 4.1 of the Preferred Options Paper outlines the purpose of the Strategic Growth
Locations which “sets out in broad terms the locations to which large scale and strategic
growth should be directed; and conversely, those areas in which growth should be more
controlled”.
By virtue of IMP’s interests at Stratford 46 - which is subject to a hybrid planning
permission (Ref: 19/01402/OUT) and is allocated under the reference Proposal SUA.2 in
the Stratford-on-Avon Core Strategy, and it is a draft policy in the emerging Stratford-onAvon Site Allocations Plan (SAP) – SG18 is already a strategic location for employmentled mixed use development.
Stratford 46 can provide an anchor to any future surrounding housing growth west of
Stratford-upon-Avon and its capacity to deliver an employment-led mixed-use scheme
will provide a sustainable and accessible location for jobs, services and facilities required
by new residents.
Whilst IMP is supportive of SG18 it remains unclear how the Core Opportunity Area and
Major Investment Sites (MIS) interrelate with Strategic Growth Locations. IMP has
responded separately to Draft Policy Direction 13 and Draft Policy Direction 14
respectively on the matter.