Preferred Options 2025

4. Meeting South Warwickshire's Sustainable Development Requirements

The primary purpose of the South Warwickshire Local Plan is to meet South Warwickshire's sustainable development requirements. This means meeting the needs of the current generation without compromising the ability of future generations to meet their own needs. As well as providing homes and employment land, the SWLP will ensure that infrastructure is provided to support this development. This includes physical items such as transport facilities and schools, as well as the environmental and social infrastructure that are necessary for healthy and happy communities.

Figures 5 and 6 on the following pages show elements of the emerging Spatial Growth Strategy options which are detailed in subsequent sections of this chapter. These can also be explored in detail on our interactive map.

Figure 5: South Warwickshire Local Plan-Spatial Growth Strategy Priority Areas

Figure 6: South Warwickshire Local Plan-Emerging Spatial Growth Strategy Options

4.1 Spatial Growth Strategy

A Spatial Growth Strategy 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. In practical terms, the chosen Spatial Growth Strategy will help deliver the SWLP's five overarching principles, determine where land is allocated for homes and employment uses, and the infrastructure and open space that supports this growth.

The South Warwickshire Local Plan is being prepared in accordance with the principles of achieving sustainable development as set out in national planning policy. To be truly sustainable, it is important that the strategy is evidence-led, rather than being led purely by the sites which have been put forward. In the SWLP, sustainability is achieved by:

• first utilising available urban brownfield land;
• where greenfield development is needed, concentrating this into fewer, larger areas of strategic growth;
• using locations which are within reach of existing facilities, or providing new facilities on site;
• considering the potential for one or more new settlements;
• allowing for small-scale growth outside of strategic areas;
• building at densities that make efficient use of land.

The chosen Spatial Growth Strategy for the SWLP is "Sustainable Travel and Economy". This was presented as Option 4 in the Issues and Options consultation, and is a hybrid option which incorporates the following elements:

• Urban land;
• Sustainable travel – rail stations and bus stops with good travel times to major towns;
• Enterprise hubs – places where people can earn and spend money, including town centres, employment sites, and neighbouring major settlements;
• Socio-economic factors - areas of deprivation where this could be mitigated by new development.

The Spatial Growth Strategy will accommodate South Warwickshire's housing and employment needs for the period to 2050. The 2022 Coventry and Warwickshire Housing and Economic Development Needs Assessment (HEDNA) provides housing figures based on the 2021 Census, which were considered more robust during the preparation of this Preferred Options document than the 2014-based household growth projections required in the Government's previous "Standard Method" for calculating local housing need. In December 2024, the Government introduced a new Standard Method formula to calculate local housing need via the 2024 NPPF.

As a baseline and given the very recent update to the standard method, the Preferred Options Spatial Growth Strategy accommodates the HEDNA's Census-based housing figures. However the draft policy direction below acknowledges the latest local housing need figures for both authorities and incorporates sufficient flexibility to accommodate these higher figures introduced in the new Standard Method.

South Warwickshire's residual employment need (the net need once the expected employment supply is subtracted from the gross need), is set out in the South Warwickshire Employment Land Study (SWELS) (2024). This Employment Land Study calculated the residual employment need position through using the demand side findings of the Coventry & Warwickshire HEDNA 2022, the West Midlands Strategic Sites Study 2024 (WMSESS) and the Coventry & Warwickshire HEDNA/WMSESS Alignment Paper 2024. The SWELS also recommends locations for directing future employment growth, which is detailed at Policy Direction 13.

What was said in the I&O

The Spatial Growth Strategy brings together a number of sections from the Issues and Options consultation.

Q-S4.1 asked whether growth of some of our existing settlements should be part of the overall strategy. A majority of respondents agreed.

Q-S5.1 asked whether new settlement should be part of the overall strategy. A majority agreed, although amongst landowners, developers and site promotors, the most common response was "no".

Q-S7.2 asked whether each of the 5 growth options were an appropriate strategy for South Warwickshire:

• Option 1: Rail Corridors
• Option 2: Sustainable Travel
• Option 3: Economy
• Option 4: Sustainable Travel and Economy
• Option 5: Dispersed

Option 5 (Dispersed) was the only option which saw a greater proportion of respondents selecting "inappropriate" than "appropriate". Options 1, 2 and 4 were fairly evenly matched, each attracting support from around 50% of respondents. This similarity is to some extent expected, as some options are hybrids of others in the list. A number of written comments around each Spatial Growth Option were put forward. Commonly occurring themes include the potential impact on the Green Belt of most or all of the proposed options; suggestions for using a hybrid option; infrastructure upgrades needed (for example to rail stations); and difficulties in providing new infrastructure to a dispersed population.

Q-H1.1 asked whether the HEDNA provides a reasonable basis for identifying future levels of housing need. 58.4% said "yes" and 32.0% "no".

In Q-H1.2, further detail was provided, including comments around a potential uplift required to meet needs from outside South Warwickshire; a suggested uplift to provide additional affordable housing; a lack of faith in the figures; a view the figures were too high; and a view that the figures should be seen as a minimum baseline.

Issue E1 of the Issues and Options consultation set out the proposed employment land provision for South Warwickshire based on the findings of the Coventry & Warwickshire HEDNA 2022, which has now been largely superseded by the findings of the South Warwickshire Employment Land Study (2024), the West Midlands Strategic Sites Study 2024 (WMSESS) and the Coventry & Warwickshire HEDNA/WMSESS Alignment Paper 2024.

Issue E1 identified the following employment land needs drawing on the HEDNA (2022) as well as the need to consider strategic warehouse and distribution need across Coventry & Warwickshire.

Q-E1.1 asked whether the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire.

The question had a total of 93 responses. Of the responses, 40.9% (38 responses) were 'Yes', 38.7% (36 responses) were 'No', and 20.4% (19 responses) were 'Don't Know'.

However, we are no longer proposing to use the HEDNA (2022) as the main basis for deciding our employment needs, except for office need. This is as the HEDNA had consistent data only to 2019 due to being prepared during the Covid pandemic period and before the headline results of the 2021 Census were released. Therefore, the responses to question E1.1 are less relevant to this Preferred Options version of the SWLP. However, the findings of the HEDNA have been used to inform the South Warwickshire Employment Land Study (2024) and the WMSESS/HEDNA Alignment Paper (2024).

Tables 2 and 3 below illustrate how these figures have been calculated for each housing requirement.

Table 2: Housing calculation using the HEDNA method

Table 3: Housing calculation using 2024 NPPF standard method

Provision for employment land over the plan period will be made for at least the following (note that in Table 4, residual needs are shown in bold as negative figures; existing surpluses are shown in bold as positive figures).

Table 4: Employment land residual needs and existing surpluses

The WMSESS identifies a residual need for 75-125 ha of strategic sites up to 2045, to include 1-2 mixed/B8 sites and 0-1 B2 sites within Road Opportunity Area (ROA) 8 along the M40/A46. It is proposed that the upper threshold of 125ha is used, as recommended within the WMSESS (2024). Strategic sites in this context refer to large scale employment sites typically over 25ha 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).

It should be noted that while ROA 7 overlaps the north of Warwick (and includes existing commitments such as the Sub-Regional Employment Site and Coventry Airport), junction opportunities and further land do not fall within Warwick District; whilst ROA 9 overlaps the western edge of Stratford-on-Avon, however, this will likely be Redditch and Bromsgrove facing. As such, ROA 8 is the primary opportunity area wholly within South Warwickshire.

Figure 7: Road Opportunity Area 8, WMSESS (2024)

South Warwickshire's housing and employment needs will be distributed using the "Sustainable Travel and Economy" Spatial Growth Strategy. Three "priority areas" have been delineated which determine areas of land which fall within this Spatial Growth Strategy, based on proximity to the various elements that form part of the strategy.

South Warwickshire's existing urban areas fall within Priority 1, and full use will be made of suitable urban brownfield land before development is considered elsewhere.

There is insufficient urban brownfield land to accommodate South Warwickshire's housing and employment land needs. The majority of the SWLP's strategic growth needs will be met within priority areas 1-3.

Strategic growth will be accommodated outside of the priority areas only where it is of sufficient scale for significant infrastructure upgrades to be provided on site (for example at the scale of a new settlement).

Small-scale growth to meet identified local needs may be accommodated outside of the priority areas. Neighbourhood Development Plans are considered to be an appropriate vehicle for delivering such sites.

Twenty-four areas have been identified as locations for potential strategic growth. To provide the opportunity to consider reasonable alternatives, the identified strategic growth locations could accommodate well in excess of South Warwickshire's housing and employment needs, and it is not expected that all of the areas will be allocated in the SWLP. Further work will be undertaken, prior to publication of the Regulation 19 Local Plan to identify the sites that are proposed to be allocated. This will include consideration of responses received on the Preferred Options document.

Similarly, the strategic growth locations identified include a mixture of Green Belt and non-Green Belt locations. This will enable a careful assessment of the sustainability of different options, which is necessary to determine whether there are "exceptional circumstances" that would justify releasing land from the Green Belt.The mix of proposed uses within each strategic growth location is not currently determined. Strategic Growth Locations can be explored in detail on our interactive map.

Table 5: Strategic Growth Locations

Note that in addition to the 24 Strategic Growth Locations, potential New Settlement locations may also contribute to South Warwickshire's development needs. See section 4.2 for further details.

The Regulation 19 Local Plan will confirm the development requirements for each proposed allocation, including the required mix of uses, mitigation and enhancement measures and infrastructure (including open space, active travel, education, community facilities, highways, public transport).

Justification

Sustainable development is at the heart of the NPPF. Paragraph 11 sets out the fundamental requirement that plans should promote a sustainable pattern of development, meeting the needs of the area, aligning growth and infrastructure, improving the environment and mitigating climate change.

NPPF paragraph 69 sets out that strategic policy-making authorities should establish a housing requirement figure for their whole area. Paragraph 77 states that new homes can often best be achieved through planning for larger scale development, provided they are well located and designed, and supported by the necessary infrastructure and facilities. Paragraph 124 identifies the need to make effective use of land, including previously developed (brownfield) land.

NPPF Chapter 6 'Building a strong, competitive economy' makes clear at paragraph 85 that the approach taken in local planning policies should allow each area to build on its strengths, going on to recognise that areas with high levels of productivity should be able to capitalise on their performance and potential. Para 86 states that Policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to Local Industrial Strategies alongside identifying strategic sites for local and inward investment. Para 87 raises the need to recognise and address the specific locational requirements of different sectors, which includes making provision for clusters or networks for different industries including the knowledge sector and freight and logistics.

Other evidence

The South Warwickshire Local Plan has incorporated a wide range of evidence which has identified South Warwickshire's housing and employment land needs and assisted in determining the most suitable and sustainable locations for growth. A topic paper: Emerging Spatial Growth Strategy sets out in detail how the Spatial Growth Strategy has evolved to its current state.

The 2022 Urban Capacity Study identified land in urban areas that may be suitable for re-use. The capacity of such land in South Warwickshire is limited; consequently, there is a need to consider sites in other locations. Two Call for Sites exercises have been conducted, and other potential development sites have been identified including existing and draft allocations from other planning documents where these do not have planning permission.

These sites have been assessed using a two-stage Housing and Economic Land Availability Assessment (HELAA). This assessment considered a wide range of evidence from multiple sources, including (but not limited to) flood mapping, heritage, landscape character, Green Belt and transport. HELAA part A ruled out sites subject to severe constraints; part B considered a site's relative merits in the round. The HELAA assessment informed the selection of strategic growth locations.

Comments on specific site submissions, as outlined on the interactive map, and the outcomes of the HELAA Assessment can be made as part of this consultation.

Employment Evidence

There are several different employment evidence documents that fed into the employment strategy in this Preferred Options document. Figure 8 shows the relationship between the below different employment evidence documents that have fed into the South Warwickshire Employment Land Study (2024).

Figure 8: Employment Land Needs Methodology

Ultimately, the results of these evidence documents have then been used within the South Warwickshire Employment Land Study (2024), to calculate and summarise the residual employment need for South Warwickshire.

The Coventry & Warwickshire Housing and Economic Development Needs Assessment (2022)

This provided each local authority with a local industrial and office need for the 2021-41 and 2021-50 periods. In addition, the report also reported a Strategic B8 need to 2050 across the Study region. The HEDNA provided an overall office need for Stratford-on-Avon District of 7.2 ha. to 2050, and for Warwick District of 15.8 ha. to 2050.

West Midlands Strategic Site Study (2024)

Since the publication of the HEDNA, the West Midlands Strategic Sites Study (WMSESS) has identified an overall need for strategic sites across the West Midlands, for B2 and B8 use and identified opportunity areas for strategic sites, assigning them a notional quantum.

In addition to Road Opportunity Areas, where 75-125ha. of strategic employment need is identified in Road Opportunity 8 (located entirely within South Warwickshire), the WMSESS (2024) also identifies a Study-area wide need for 67 ha to 135 ha for rail needs. This indicates a likely need for a new strategic rail freight interchange (SRFI) site within the study period (2022 – 2045)

The WMSESS suggests four broad areas of search for new commercially attractive sites to accommodate an SFRI, namely:

• Stoke / Stafford.
• Lichfield.
• Nuneaton-Coventry; and
• Warwick-Leamington.

However, at this stage the location of this SFRI has not been decided.

Coventry & Warwickshire HEDNA and WMSESS alignment paper

Following the publication of the WMSESS, an alignment paper has been produced to bring together the WMSESS and the C&W HEDNA, address the overlaps between them, and provide aligned outputs on employment land needs over a consistent set of timescales. The alignment paper identifies a local strategic unit need (for units over 9,300 sqm) not captured by WMSESS. The need for offices is not updated and remains the same as forecasted in the 2022 HEDNA.

South Warwickshire Employment Land Study 2024

The Employment Land Study builds on the findings of the Coventry & Warwickshire HEDNA (2022), the West Midlands Strategic Sites Study (WMSESS) (2024) and the Coventry & Warwickshire HEDNA / WMSESS alignment paper (2024). These studies assessed the employment land needs of the South Warwickshire Study Area. The Employment Land Study carries out a supply side assessment to identify quantitative and qualitative gaps in the Study Area's supply, in order to calculate the residual employment needs for South Warwickshire and identify the most appropriate locations for employment growth.

The residual non-strategic employment needs position has been calculated in the South Warwickshire Employment Land Study by taking the need identified in the three studies listed above and netting off existing allocations, employment commitments and vacant land identified on existing employment sites.

4.2 Potential New Settlements

The aim of a new settlement in planning terms is to deliver a new community that can fulfil most of its day to day needs within the settlement itself, limiting the need to travel.

New settlements can provide access to employment opportunities which in turn can create more internalised trips and opportunities to deliver non-motorised infrastructure to create a sustainable environment. Further sustainable credentials can be met through local level service provision and local centres, helping to create 20-minute neighbourhoods. Ensuring education facilities (primary and secondary schools) are provided and accessible by sustainable modes of transport is an important part of reducing car trips.

By virtue of their larger size, new settlements can take a long time to be delivered. Using a combined approach of new settlement designations, along with other strategic and smaller site allocations, will assist in ensuring that the Local Plan has a sufficiently wide range and mix of sites. This will ensure a steady stream of deliverable sites and maintain a 5-year housing land supply.

What was said in the I&O

The Issues and Options document highlighted new settlements (being a minimum 6,000 dwellings and associated infrastructure) as one of several options being considered to deliver the necessary growth required over the plan period. 7 indicative locations for new settlements were shown, along with a high-level sustainability appraisal of the locations.

On the topic of new settlements, the majority of respondents (59%) thought that new settlements should be part of the overall growth strategy, with most of these also noting there should be expansion of existing settlements in conjunction with new settlements.

Potential New Settlements can be explored in detail on our interactive map.

Table 6: Potential new settlements and their suitability

* The Potential New Settlement names have been revised and might differ from the Issues and Options stage document. Whist their names have been revised, there is no change to their boundaries.

** Site boundaries have been revised to reflect known land promoters' interests.

Justification

The NPPF recognises the role large scale development and new settlements can play in the supply of new homes in an area. Paragraph 77 states that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Drawing on examples from around the country, a new settlement has the potential to accommodate approximately 6,000-10,000 dwellings (minimum), as a significant proportion of South Warwickshire's growth needs.

The 12 potential new settlement locations identified since the last round of consultation provide a range of options across both Stratford and Warwick districts, broadly aligned to the preferred growth strategy (Sustainable Travel and Economy). The New Settlement Assessment (as at Preferred Options) paper sets out the approach to assessing the potential new settlement locations, drawing on a range of sources utilised for the assessment. The categorisation of 4 of the 12 potential new settlement locations as more suitable options, rather than less suitable, is based on holistic planning judgement of the evidence collated to date. A key variable between the potential new settlement locations is the proportion of land being promoted in each proposed new settlement's location. Clearly, the infrastructure requirements for any new settlement location will be significant, and therefore are a key factor for measuring suitability. Further work is required to further refine recommendations on the appropriateness of one or more potential new settlements to accommodate a significant proportion of South Warwickshire's required growth in a sustainable manner.

4.3 Small Scale Development, Settlement Boundaries, and Infill Development

It is important to note the contribution that small scale and windfall development can make to the overall development need for South Warwickshire. Smaller sites often have a valuable role to play in delivering community-led housing and providing opportunities for self-build and custom-build housing. Development of small sites often also provides a boost to the local economy as they tend to be more attractive to small and medium local businesses rather than volume housebuilders.

It is also important to define the boundaries between settlements and the surrounding countryside. This provides a distinction between the various scales of settlements and the open countryside, and in so doing enables the clear, unambiguous and consistent application of policies in the management of development within and outside settlements. This approach encourages the efficient use of land within our towns and villages, including the re-use of previously developed land.

It is not the purpose of settlement boundaries to identify land for development; this will be achieved via the allocation of sites in this Local Plan and Neighbourhood Development Plans. Their purpose is to define the extent of a particular town or village in terms of its built development and therefore, the boundaries are unrelated to the administrative boundaries of a town and parish, which serve this particular function.

What was said in the I&O

At the previous Regulation 18 Issues & Options consultation the following comments were made regarding small scale growth, settlement boundaries and the role of infill development:

• General support to follow a threshold approach to allow more small-scale development to come forward over the plan period.
• Support for a limit of 10 dwellings per site for new individual sites across the plan area. However, a lower limit was also sought by some respondents.
• A strong view that a threshold approach was not appropriate in Green Belt areas.
• A view that a single numerical threshold was inappropriate given the wide variety of settlements that may fall outside of the chosen Spatial Growth Strategy.
• Support by individuals suggesting any amendments/revisions to settlement boundaries should wait until Part 2 of the Plan when further details, such as non-strategic allocations, are available although developers and land promoters stated these revisions should be considered earlier on in the plan period.
• There has been some previous support in relation to growth options in the Green Belt being limited to the development of infill sites and the revision of village boundaries to take account of the existing built environment.

Justification

Paragraph 73 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly. Planning authorities should identify land to accommodate at least 10% of their housing requirement on sites no larger than one hectare, unless there are strong reasons why this cannot be achieved. Authorities should also seek opportunities to support small sites to come forward for community-led development for housing and self-build and custom-build housing.

4.4 Accommodating Growth Needs Arising from Outside South Warwickshire

Under the Duty to Co-operate, the Council is obliged to engage proactively with certain prescribed bodies to address strategic cross boundary issues. There may be a need to look to accommodate 'unmet need' from the Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA. While both Stratford and Warwick districts are located within the Coventry and Warwickshire HMA, only Stratford lies within the Greater Birmingham and Black Country HMA.

It is yet to be established to what extent and what uses (e.g. housing and/or employment) there will be any unmet need from elsewhere within these housing market areas. Some of this need will be met by other constituent Local Planning Authorities within both HMA's; however, through Duty to Co-operate discussions; the Councils will commit to continually consider this need and work with those authorities on how this can be achieved.

What was said in the I&O

The Issues and Options Consultation considered the need to meet housing needs (including unmet need arising from neighbouring authorities) within the vision however, it was felt that this should be given greater emphasis.

• Most respondents (62%) felt that the plan should not be contributing to addressing the unmet needs in the Greater Birmingham and Black Country Housing Market Area (GBBC HMA) until 2031.
• Primarily developers and land promoters considered South Warwickshire should provide for neighbouring housing unmet needs, including beyond the proposed allocations in the Stratford-on-Avon District Council's Site Allocation Plan (SOADC SAP). They considered South Warwickshire has a responsibility to help address the unmet needs through the Duty to Cooperate (DTC). Some mentioned that, given South Warwickshire's size, it is acceptable to accommodate some unmet needs of other Local Authorities within the HMA.

Justification

The National Planning Policy Framework (NPPF) provides guidance on the duty to cooperate and meeting cross boundary housing need that cannot be met within neighbouring areas.

The Coventry and Warwickshire Housing and Economic Development Needs Assessment (HEDNA) 2022 identifies likely housing requirements for South Warwickshire in relation to neighbouring authorities, however unmet needs figures (e.g. from Coventry) are not yet known.

For the Greater Birmingham and Black Country HMA, there is evidence of a significant shortfall between housing requirements and land supply, but the overall scale of the shortfall has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study (2018). A study refresh is required to re-evaluate the housing shortfall considering more recent evidence and policy. Council officers meet regularly with counterparts from other Councils and with various stakeholders in both the Coventry & Warwickshire and Greater Birmingham & Black Country Housing Market Area to discuss cross boundary issues. Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites. The latest evidence and further discussions with neighbouring authorities will inform the Regulation 19 Submission policies on unmet housing need. If reserve housing sites are needed, the SWLP process will consider suitable sites which may include draft reserve housing allocations in Stratford-on-Avon District Council's Site Allocation Plan (SOADC SAP).

4.5 Infrastructure Requirements and Delivery

Infrastructure is essential to support growth in a sustainable manner. The South Warwickshire Local Plan aims to ensure that there is sufficient and appropriate infrastructure to meet future needs. The Local Plan and supporting evidence base will identify strategic infrastructure that is required to support development in the SWLP area. This section discusses infrastructure requirements and delivery but should be read in conjunction with other parts of this document that relate to specific infrastructure topics, including Section 6.5 on Airfields, Section 6.9 on community facilities, 7.10 and 7.11 in relation to flood risk and sustainable drainage and Section 10 relating to a well-connected South Warwickshire.

The Local Plan will also be supported by an Infrastructure Delivery Plan (IDP). The IDP is being prepared alongside the Local Plan to help identify key infrastructure necessary to deliver the vision of the plan and support its proposed growth and to understand how current and future infrastructure will be planned, funded, and delivered.

The IDP will also have a role in helping to coordinate delivery of infrastructure and reflect the outcomes of discussions on infrastructure needs, including any cross-boundary issues under the Duty to Cooperate.

The IDP will help demonstrate that the objectives of the South Warwickshire Local Plan are realistic, viable, and can be delivered over the Plan period. Informed by the wider evidence base and development requirements identified in the Local Plan, the IDP will identify the priorities, timing, and phasing of infrastructure provision.

Part 1 of the IDP is being published alongside the Preferred Options document. It considers the performance of existing infrastructure, existing planned investment and the infrastructure implication of future growth across a number of topics and themes, including transport, community facilities, green and blue infrastructure and flood risk. It draws on existing plans and strategies, the wider evidence base and responses to the consultation on the Issues and Options Local Plan (January 2023).

The IDP will need to be updated as the Local Plan progresses to submission and other elements of the Local Plan evidence become available, including transport modelling and a Viability Assessment for the Local Plan.

Once finalised, the IDP will include an Infrastructure Delivery Schedule for each district that provides details of specific infrastructure requirements identified in the Local Plan. This IDP remains 'a live document' and the Local Planning Authorities will continue to work with infrastructure providers and other stakeholders to refine its contents up to submission of the Local Plan.

What was said in the I&O

The I&O document asked if the Part 1 Local Plan should set out infrastructure requirements for all scales, types and location of development or if it should just focus on the strategic infrastructure relating specifically to the growth strategy.

• 67% of respondents indicated that the Part 1 Local Plan should set out the infrastructure requirements for all scales, types and locations of development.
• There were a few concerns raised including a point suggesting that the plan is going to be led by infrastructure provision as opposed to infrastructure provision being plan led and stronger wording around 'when needed' as this could be interpreted incorrectly.
• It was also felt that a list of required infrastructure in the plan could help with any uncertainty and that the plan should acknowledge that infrastructure is sometimes the responsibility of other authorities (County Council, Local Health Authority, Central Gov etc.) which should be identified in the plan.
• There were concerns that a Transport Assessment or Strategy had yet to be concluded in support of the plan with regard to traffic and transport.
• With regards to the delivery, importance was placed on infrastructure requirements and how it should be identified via appropriate evidence as well as identified geographical locations, timescales and funding sources including commitment to providing infrastructure prior to development.
• The source of funding was also addressed with comments stating that infrastructure contributions as part of developments should be proportionately related to the scale of proposals and that developers should not be bearing the burden of overly expensive infrastructure projects.

The I&O document asked if a South Warwickshire Community Infrastructure Levy (CIL) should be established or if each district should produce its own levy.

62% of respondents said that each district should produce its own levy.

Where new development creates a need for new or improved site-specific infrastructure, provision of such infrastructure or contributions will be sought from developers (through Section 106 and Section 278 legal agreements) to make the development acceptable in planning terms.

The IDP and supporting evidence base will identify how strategic infrastructure requirements to support the spatial growth strategy will be delivered.

Where development creates a requirement for new or improved infrastructure beyond existing provision, including specific development requirements identified in the Local Plan, developers will be expected to provide or contribute towards the additional requirement being provided to an agreed delivery programme.

In certain circumstances where proven necessary and viable, the LPA may require that infrastructure is delivered ahead of the development being occupied.

Detailed specifications of the site-specific contributions required will be included in the site allocation policies.

Development proposals should seek to make provision for all the land required to accommodate any additional infrastructure arising from that development that needs to be accommodated on site.

Planning Legal Agreements (Section 106 of the Town and Country Planning Act, 1990) will be used to provide a range of site-specific mitigation, including any potential cumulative effects, in accordance with the Section 106 tests, which will normally be provided on site but may where appropriate be provided in an off-site location or via an in-lieu financial contribution.

In some cases, separate agreements with utility providers may be required. Where necessary S278 agreements will be used to secure mitigation in connection with existing highways.

The Community Infrastructure Levy (CIL) will continue to be used, with each district maintaining its own CIL charging schedule to secure contributions to help fund the strategic infrastructure needed to support the sustainable growth proposed in South Warwickshire set out in the Infrastructure Delivery Plan and Infrastructure Funding Statements. CIL rates will be reviewed to reflect the position of Stratford-on-Avon District Council and Warwick District Council and latest changes in development costs and land/floorspace values across the two districts in line with viability evidence.

Infrastructure schemes that are brought forward by service providers will be encouraged and supported, where they are in accordance with other policies in the Local Plan. New residential and commercial development will be supported if sufficient infrastructure capacity is either available or can be provided in time to serve it and proposals are in accordance with other policies in the Local Plan.

In planning for new development, appropriate regard will be given to existing deficiencies in services and infrastructure provision and the extent to which new development will impact on these. Development proposals must demonstrate that existing deficiencies have been taken into account when determining the infrastructure requirements for the new development. The provision of infrastructure should be linked directly to the phasing of development to ensure that infrastructure is provided in a timely and comprehensive manner to support new development.

Where an applicant advises that a proposal is unviable in light of the infrastructure requirement(s), open book calculations verified by an independent consultant approved by the Council will need to be provided by the applicant and be submitted to the LPA for its consideration.

The Councils will support enhancements to public transport and opportunities for modal shift, including new park and ride facilities (which will be identified in the Local Plan) and enhancements to the rail network, including improvements to services from Stratford-upon-Avon and services from Coventry to Leamington, including dualling of the railway line and a new rail stop at University of Warwick, where practical and viable. Enhancements to services on the rail corridor from Warwick / Royal Leamington Spa to Nuneaton via Coventry (the Elephant and Bear Line, previously known as NUCKLE), will also be supported.

The Councils will support opportunities for active travel, including the enhancement and extension of existing routes and the restoration of HS2 haul routes for this purpose, where it is appropriate.

Schemes and initiatives that address local issues, such as flood risk attenuation, community transport, road safety, parking, congestion and air quality will be supported subject to assessment.

The Councils will work in partnership with infrastructure providers and other delivery agencies in updating the Infrastructure Delivery Plan to ensure an up to date evidence base regarding infrastructure requirements and costs is maintained, for example in relation to upgrades to the rail network and upgrades to the A46 corridor and junctions along the M40 and M42.

Justification

In order to be found sound, the South Warwickshire Local Plan will need to demonstrate that there is sufficient infrastructure to meet future needs in accordance with paragraph 20 of the NPPF.

The delivery of infrastructure is dependent on effective collaboration with other stakeholders, including Warwickshire County Council (with responsibilities in relation to schools, public transportation and highways) and the Department for Transport, West Midlands Rail Executive, NHS Coventry and Warwickshire Integrated Care Board and South Warwickshire University NHS Foundation Trust.

In order to identify the required infrastructure an Infrastructure Delivery Plan (IDP) will be produced, building on the Part 1 document that accompanies the Preferred Options document.

The IDP will include the strategic infrastructure identified in the Local Plan and supporting evidence base that is critical or essential to deliver the growth aspirations and requirements of the Plan to 2050. It will also identify desirable infrastructure requirements which support the sustainability objectives of the Local Plan but can be prioritised according to funding availability and overall net benefit. Standards will be presented in relation to other infrastructure, e.g. in relation to open space provision.

Although the production of the IDP is an iterative process as infrastructure is continually being delivered through the development management process, it is crucial that items of infrastructure are identified as early as possible in the process to better plan for the required growth to be delivered over the Local Plan period.

Figure 9 provides an overview of the transport context for the SWLP area, including existing green and blue infrastructure, the existing road and rail network and airfield. It also shows proposals for enhanced rail services and areas of search for park and ride. Existing new settlements and Major Investment Sites are shown for context. The M42/A46 Opportunity Area is also shown for context as that will have implications for the strategic road network. Wider infrastructure needs associated with the SWLP will be set out in the Regulation 19 Local Plan.

Figure 9: Transport Context

4.6 Funding for Infrastructure

The Part 1 IDP identifies a number of different ways infrastructure can be funded and provided for, some of which can be made via a financial contribution, in kind or in lieu, from a developer, through Government capital funds, district or county capital funds and a range of funding streams open to organisations like Homes England, DEFRA, Department for Transport (DfT).

Another avenue of funding is through CIL. Both Stratford-on-Avon District Council and Warwick District Council operate a CIL and have introduced a bespoke charging schedule, and this has been very successful in providing funding to deliver infrastructure in South Warwickshire to date. Both councils support a coordinated approach to the use of CIL that relates to the South Warwickshire Local Plan. It is anticipated that the districts will maintain their own charging schedules but will work together to consider operationally how this will work across the two local authority areas.

Under Section 106 (or s106) of the Town and Country Planning Act 1990, any person interested in land in a local planning authority may, by agreement or unilaterally, enter an obligation (commonly known as a S106 planning obligation). These are another important source of funding.

S106 contributions must be:

1. Necessary to make the proposed development acceptable in planning terms;
2. Directly related to the development; and
3. Fairly and reasonably related in scale and kind to the proposed development.

A Section 278 agreement (or s278) is a section of the Highways Act 1980 that allows developers to enter into a legal agreement with WCC (in its capacity as the Highway Authority) to make permanent alterations or improvements to a public highway, as part of a planning approval, e.g. a new or changed access into a development site or improvements close to the development site.

4.7 Viability and Deliverability

Paragraph 35 of the NPPF states that Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan.

Proposed site allocations will be identified in the Regulation 19 version of the Local Plan, along with a suite of policies. A Viability Assessment will be undertaken of the draft Local Plan, prior to consultation.

Proposed allocations will also be examined to ensure that the contribution they can make to housing and/or employment land supply within the plan period and beyond is understood and reflected in the housing trajectory.

4.8 Safeguarding land for transport proposals

Local plans can use a statutory mechanism to safeguarding land for transport, preventing development from compromising the provision of future infrastructure projects. Safeguarding for transport infrastructure relates to the identification and ‘saving’ of land required to deliver transport infrastructure that may be required now or in the future. Where new and undecided planning applications either encroach or abut the area of land ‘saved’ by a safeguarded scheme, the local planning authority and local highway authority are required to consider the implications of the planning application on the future delivery of the safeguarded transport scheme.

An example would be if a proposed development encroaches or abuts a safeguarded transport scheme it will need to either provide a corridor to allow the safeguarded scheme to come forward or deliver (or partly deliver) the safeguarded transport scheme.

The Council or planning inspector can refuse the planning application if they believe that the development would prejudice the possibility of the safeguarded transport scheme coming forward, either through obstructing its route or restricting access for construction and maintenance works of the future infrastructure scheme.

What was said in the I&O

The I&O document asked if the SWLP should include a policy to safeguard specific infrastructure schemes.

80% of respondents supported inclusion of a policy that safeguards infrastructure across the plan area. However, there was a view that Warwick district is being somewhat ignored in the current suggested infrastructure proposal.

Stratford-on-Avon District

• Road improvements associated with the A46 within Stratford-on-Avon District at:
  • Junction of A46 and A422 Alcester Road (Wildmoor)
  • Junction of A46 and A3400 Birmingham Road (Bishopton)
• M42 Widening – land either side of Junction 3a to help reduce congestion where the M40 joins the M42
• Portabello Crossroads – improvements to this junction between the A429 Fosse Way and the B4035 to the west of Shipston-on-Stour
• Stratford to Honeybourne former railway – safeguarding the route of the former railway south of Stratford-upon-Avon to Honeybourne to facilitate re-opening
• Western Road to Birmingham Road, Stratford-upon-Avon – proposal for new crossing of the canal and creation of a new route between the A3400 Birmingham Road and A422 Alcester Road
• Bridgeway Gyratory Improvements – widening of key town centre route that takes traffic from town centre/A439 onto the Clopton Bridge and south across the River Avon
• West of Shottery Relief Road – currently under construction as part of the West of Shottery development connecting B439 Evesham Road with the A46 at Wildmoor
• Stratford South Western Relief Road – a third crossing of the River Avon to the south-west of Stratford-upon-Avon, connecting A3400 Shipston Road with B439 Evesham Road (alternative routes and options to be investigated).
• Land safeguarded for the possible provision of a railway station at Long Marston Airfield site, adjacent to the former Stratford to Honeybourne line.

The draft Site Allocations Plan also proposes to safeguard land at the Bishopton and Wildmoor junctions to facilitate improvements to the A46 should they be deemed necessary and further consideration will be given to these and any other reasonable alternatives.

Warwick District

• Broad Locations for Park & Ride facilities to serve commuters travelling into Coventry and the Warwick / Leamington / Kenilworth areas including:
  • a Public Transport Interchange to serve Coventry South and the University of Warwick (including provision for Park and Ride and associated bus services, an active travel hub, very light rail and a new heavy rail station); and
  • A Park and Ride facility to serve the north of Leamington Spa (two areas of search are currently allocated on land near Bericote roundabout and Blackdown roundabout).
• Safeguarding of land to deliver transport schemes to alleviate congestion and address deficiencies in sustainable transport provision in specific locations (e.g. potential delivery of a multimodal transport corridor to alleviate local road congestion and deliver modal shift in the south of Coventry area).

A proposed policy direction is to include the safeguarding of land to facilitate widening of rail corridors (e.g. to 'double track' the section of line between Coventry and Leamington).

Both Districts

The Secretary of State for Transport issued revised safeguarding directions in relation to HS2 on 16 August 2016. It is not intended to reflect these on the policies maps but they can be viewed https://www.gov.uk/government/publications/hs2-phase-2b-safeguarding-maps-warwickshire-staffordshire-leicestershire.

Further land may be required for safeguarding where this can be justified, for example where latest Infrastructure Delivery Plans provide a more up-to-date list of programmed transport schemes.

Justification

The NPPF (paragraph 111 (c)) states that "Planning policies should identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development."

Figure 9 shows the existing transport context, including a broad indication of safeguarded areas referred to in the policy direction. Options in relation to future provision of the south western relief road for Stratford-upon-Avon are still under review and will be subject to further technical work, including transport modelling and consideration of reasonable alternative through the Sustainability Appraisal. The emerging evidence base includes work on the Transport Vision (Part 1 and Part 2, January 2023 by Vectos and a Feasibility & Viability Assessment in May 2024 by Jacobs) and further work will inform the option that is taken forward.

4.9 Green Belt

Parts of South Warwickshire fall within the West Midlands Green Belt, whose fundamental aim is to prevent the sprawl of the West Midlands conurbation, by keeping land permanently open.

Some of South Warwickshire's most sustainable locations fall within the Green Belt. For example, all of our train stations are either in or close to the Green Belt. This means that to deliver a truly sustainable pattern of growth, the SWLP needs to consider all options, including Green Belt options. A topic paper "The Green Belt in South Warwickshire" presents an introduction to the purposes of Green Belt, and choosing sustainable locations for growth.

The 24 strategic growth locations and 12 new settlement locations put forward in the SWLP Spatial Growth Strategy (sections 4.1 and 4.2 in this document) include a mixture of Green Belt and non-Green Belt locations. Further work will be carried out to determine which of these areas can be considered the most sustainable; and consequently, whether there is an argument that "exceptional circumstances" exist which would justify releasing some Green Belt land for development.

A key part of the evidence which will inform this argument is a Green Belt Review. This assesses the contribution that different areas of land make to the five purposes of Green Belt:

1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

So far, Stage 1 of the SWLP's Green Belt Review has been completed, which assesses parcels of land around settlements which are adjacent to the Green Belt or "inset" within the Green Belt designation; and broad areas of land between these parcels. Stage 2 of the Green Belt Review will assess the performance of specific sites, where these are being considered for development. It will also assess villages which are currently "washed over" by the Green Belt designation to consider whether the built up areas of these villages should be removed from the Green Belt designation. Stage 2 will be available after the Preferred Options consultation.

The recently published 2024 NPPF has made some significant changes to how Green Belt is handled in national policy. One of the most notable changes is the introduction of the concept of "Grey Belt" land, which relates to areas of Green Belt which are previously developed and/or do not strongly contribute to Green Belt purposes a), b) or d) as referred to above. These changes were only just introduced prior to the Preferred Options consultation and so it is not possible to state with certainty how this will affect the SWLP's consideration of Green Belt.

What was said in the I&O

At the previous Regulation 18 Issues & Options consultation, no specific question was asked around Green Belt. The following comments were made regarding Green Belt:

• Not enough emphasis on Green Belt at the Issues and Options stage of the Local Plan
• General opposition to development within the Green Belt.
• Green Belt is highly valued in the area, providing benefits for both physical and mental health.
• Developers see Green Belt as a significant material consideration, and it is likely that the policy-off approach will need to be revisited during the next stage of plan making.
• Landowner and developer/site promoter responses generally agreed with the necessity of a Green Belt Review in Part 1 (of the Plan).
• Some Parish Councils and individuals argued that the release of Green Belt land would be unjustified and in contradiction to recent government policy.

Justification

The National Planning Policy Framework (NPPF) places great importance on the Green Belt which is covered in paragraphs 142 to 156.

Paragraph 144 establishes that new Green Belt should only be designated in exceptional circumstances, where normal planning policies would not be adequate, and when major changes in circumstances make this necessary.

Paragraph 145 allows for Green Belt boundaries to be altered when exceptional circumstances are fully evidenced and justified. Paragraph 147 details the sequential process that must be followed before concluding that exceptional circumstances exist. Paragraph 148 highlights the importance of using previously developed land, then grey belt land prior to other Green Belt locations. Alongside this, the need to promote sustainable development patterns should be used to determine whether a site is appropriate.

Paragraph 149 allows for the identification of areas of safeguarded land between the urban area and the Green Belt to meet longer-term development needs beyond the plan period. Safeguarded land within a Local Plan is not allocated for development at that time, and planning permission should only be granted following an update to a plan. Within the adopted Warwick District Local Plan, there is an area of safeguarded land to the south of Westwood Heath Road. The decision to designate safeguarded land related to transport modelling at the time indicating that the local highway network was unable to accommodate more than the 425 dwellings allocated, based on other proposed developments within Warwick District and Coventry, without significant improvements to transport infrastructure within the area. Key evidence such as the strategic transport assessment, Green Belt review and infrastructure delivery plan will inform decision making on designation of safeguarded land.

Paragraph 150 indicates that villages whose open character contributes to the openness of the Green Belt should remain within the designation; but that other villages should be excluded from the Green Belt.

Paragraph 154 establishes that new buildings are considered inappropriate in the Green Belt, with a number of exceptions.

An exploration of Green Belt locations and sustainability is set out in the topic paper "The Green Belt in South Warwickshire".

A two-stage Green Belt Review is being undertaken that provides an objective, evidence-based and independent assessment of how the Green Belt in South Warwickshire contributes to the five purposes of Green Belt set out in the NPPF. Stage 1 of the Green Belt Review has been published alongside this Preferred Options consultation. Stage 2 will be published in 2025. The findings of Stage 1 have provided an initial understanding of which areas of land contribute most strongly to the five purposes; Stage 2 will provide greater granular detail about specific sites being considered for development.

4.10 Density

Density refers to how much built development there is in any given area. It is commonly presented as the number of dwellings per hectare (dph). Density considerations are important for determining how a place functions and looks, as well as influencing site, locality, and wider area long-term sustainability.

Densification (sometimes referred to as intensification) is one way of optimising density, by increasing the number of homes within existing urban areas. For example, this could be by infill, mews developments on back streets, or additional storeys on buildings.

Optimising density can provide social, economic, and environmental benefits, and plays a pivotal part in place-making and tackling climate change, as well as supporting vitality and viability and linking to the principle of 20-minute neighbourhoods.

Current policy approaches across Warwick and Stratford-on-Avon differ, with Warwick specifying a minimum density of 30 d.p.h (with opportunities to increase from that minimum), and Stratford-on-Avon having no overarching minimum.

Existing densities vary significantly across South Warwickshire, noting its large proportion of rural areas. When identifying appropriate new densities, these will need to reflect considerations such as existing context, character, setting and densities.

What was said in the I&O:

Density

The Issues and Options consultation asked about the inclusion of a policy on density and density requirements.

The most favourable option overall (31.3% respondents), which included the majority of developer/landowner responses, was to include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. Individuals generally preferred including specific policy for appropriate minimum density ranges and setting out density requirements.

Densification

The Issues and Options also asked a specific question on densification (which was referred to as intensification in that consultation).

Overall responses (61.5%) indicated a preference for identifying areas which are considered particularly suited to intensification development, and to produce a design code for each character area/area type, with a supporting policy for this.

Justification

The "Guide to existing housing densities in South Warwickshire" illustrates a range of local neighbourhood types, and how different densities look and feel on the street.

Density is one of the design parameters which is considered an essential component of design codes for their effective use. Guidance from the National Model Design Guide, in conjunction with evidence from the SWLP Urban Capacity Study, will be used to agree appropriate density ranges for the different area types across South Warwickshire.

As density itself is not a measure of how appropriate a particular development will be within a given 'Area Type', density must be considered amongst other design parameters including building types, building forms, and whether buildings join. This will be used to identify areas which are suited to densification.

An advantage to densification, and optimising density in particular areas, is that more dense developments have a range of services and facilities being provided together. The close-proximity of the services and facilities enables the '20-minute neighbourhood' principles, and the associated benefits of this, to be more easily achieved. Benefits include the promotion and accessibility of active travel, which subsequently reduces private car dependence and associated transport-related emissions, whilst also providing health and wellbeing benefits to individuals, promoting healthy lifestyles.

4.11 Using Brownfield Land for Development

Brownfield land is that which has been previously developed. Reusing vacant or derelict land and buildings reduces the need to build on greenfield land, which is a finite resource and often of higher quality in terms of landscape and biodiversity.

Urban brownfield development is essential for urban regeneration and, if designed to a high standard, brings homes, jobs and services closer together, reduces dependency on the car, and strengthens communities.

As detailed in the Spatial Growth Strategy in section 4.1, the SWLP will utilise urban brownfield land first, before other locations are considered for development. However, not all brownfield land is located within urban areas, so a balance must be struck between the benefits of re-using this land and directing development to the most sustainable locations.

What was said in the I&O

At the previous Regulation 18 Issues & Options consultation, Q-S3.2 asked whether brownfield development should be prioritised irrespective of its location, or only when it is sustainably located. Responses were fairly evenly matched, with a slight preference for prioritising only sustainably located brownfield land.

Other comments about brownfield land include that brownfield land should be used first as per the government pledge; considerations regarding the viability of developing on brownfield land and remediation; and that there should be a policy encouraging the redevelopment and re-use of our town centres to allow them to diversify.

Justification

The National Planning Policy Framework (NPPF) paragraph 124 emphasises the need to make as much use as possible of previously developed or 'brownfield' land. Paragraph 11 sets out the fundamental requirement that plans promote sustainable patterns of development.

The SWLP Urban Capacity Study identified land in urban areas that may be suitable for re-use. The capacity of such land in South Warwickshire is limited; consequently, there is a need to consider sites in other locations.

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