Preferred Options 2025

6. Delivering South Warwickshire's Economic Needs

South Warwickshire is the gateway to the West Midlands, benefitting from direct access to London via the M40 and the Chiltern mainline. It is situated only 10 miles from Birmingham, and HS2 will provide direct access to the North. Due to its location, businesses within South Warwickshire are well placed to capitalise on a wide range of economic opportunities, not only from the West Midlands but from the East Midlands, Southeast and Southwest of England. South Warwickshire is traversed by the A46 which is a key strategic route connecting the Humber Ports with the cities of the Severn Estuary. It is therefore important that the SWLP provides appropriate support and protection to existing employment assets and community facilities, as well as create the environment for new economic opportunities to flourish.

Chapter 6 sets out various options as to how we might meet our economic challenges facing us to 2050, as well as capitalise on the variety of economic opportunities, and seek your views on the following key topics:

• Locations for Industrial Employment Growth
• Core Opportunity Areas
• Existing Employment Sites and Major Investment Sites
• Provision of Office Accommodation and Refurbishment of Existing Office Stock
• Airfields
• Regeneration
• A Low Carbon Economy
• Supporting Rural Employment and Diversification
• Supporting a Range of Business Units and Affordable Employment Space
• Protecting Community Facilities
• Supporting our Changing Town Centres
• Arts and Culture

It should be noted that the overall employment need for South Warwickshire is set out within Section 4.1 (Spatial Growth Strategy). In addition, it should be noted that whilst tourism is an important issue that the Local plan will need to address, it is not considered that tourism plays a spatially strategic role and should therefore be addressed in part 2 of the South Warwickshire Local Plan.

6.1 Locations for Industrial Employment Growth

Section 4.1 sets out the employment need for South Warwickshire over the plan period.

Specific site allocations for industrial employment need will be made at the next Regulation 19 (publication) stage of the Local Plan to address this need. The allocation of employment land within the South Warwickshire Local Plan will need to be informed by the employment evidence, potential sites put forward for development, as well as the spatial growth strategy in the Plan. An important consideration will be the alignment of the strategies for homes and jobs. However, at this stage we will set out broad locations that may be considered appropriate for strategic industrial employment allocations (excluding office need, which is addressed in Section 6.3). Strategic need refers to large scale employment sites typically over 25 ha and largely dedicated to units of over 9,300 sqm.

There are several employment evidence documents that have fed into the employment strategy in this Preferred Options document, as summarised within Section 4.1.

Ultimately, these evidence documents have then fed into the South Warwickshire Employment Land Study (2024) which calculates the residual employment need for South Warwickshire and recommended locations for employment growth.

It is also important to plan for 'windfall' i.e. unallocated employment development which may come forward during the Plan period. Whilst we will need a certain amount of rural employment development in order to meet local or community needs (see Section 6.8), it is considered that unallocated employment development should be directed to existing settlements in the first instance.

The Policy Direction for the three operating/formerly operating South Warwickshire airfields at Atherstone, Coventry and Wellesbourne is set out in Section 6.5. There is also a separate Section 6.3 covering employment provision at South Warwickshire's Major Investment Sites.

What was said in the I&O

The Issues and Options document asked if the HEDNA evidence would provide a reasonable basis for identifying future levels of employment need across South Warwickshire. However, since then, updated employment land evidence has been prepared which includes the West Midlands Strategic Sites Study 2024 (WMSESS), the Coventry & Warwickshire HEDNA/WMSESS Alignment Paper 2024, and the South Warwickshire Employment Land Study 2024.

Justification

NPPF

Paragraph 85 of the NPPF states that "Policies… should create the conditions in which businesses can invest, expand and adapt."

Paragraph 86a states that Policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth.

South Warwickshire Employment Land Study (2024)

The Employment Land Study has used economic and commercial research to provide qualitative recommendations on qualitative gaps in the employment land supply profile and how these can be dealt with through Local Plan policy and allocations. This includes recommendation on how the residual strategic and non-strategic employment land need should be distributed across South Warwickshire.

6.2 Core Opportunity Area

South Warwickshire has a diverse economy with many thriving employment clusters covering a variety of sectors which include national and international businesses plus research facilities. When considered spatially, these clusters and research facilities cover a core area across the centre of South Warwickshire which includes the areas five main towns and is connected by the A46 Trans Midlands Trade Corridor and the central section of the M40. A Core Opportunity Area (COA) is proposed which brings these key clusters together as a way of attracting inward investment into South Warwickshire, encouraging businesses to co-locate in this area and take advantage of economies of scale.

What was said in the I&O

The SWLP Issues and Options consultation document posed a specific question about the inclusion of a policy directing employment to the Core Opportunity Area. Over 78% of the 134 respondents to this question felt that the SWLP should include such a policy. Many of the responses went on to name specific sites, a good number of which already fell within the proposed COA. A small number of respondents considered that the creation of a Core Opportunity Area may have a negative effect, as potential employers may see the policy as preventing economic development elsewhere, or that such a policy designation may raise land values in the COA making it less affordable for smaller occupiers.

Figure 10: Core Opportunity Area

NB: the Existing Major Investment Site references have since been updated from those shown in this Figure – please see Draft Policy Direction 14

Justification

National Policy

2024 NPPF Chapter 6 'Building a strong, competitive economy' makes clear at para 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 goes on to state that planning policies should set criteria or identify 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.

The proposed Core Opportunity Areas policy will seek to respond to the needs of the modern economy in South Warwickshire by making provision for clusters of industries to support their growth.

West Midlands Strategic Employment Site Study (2024)

There is broad alignment of the proposed COA with the Road Opportunity Area (Area 8 - A46/M40 Warwick) and potential Rail Opportunity Area (Area 4 – Warwick & Leamington) identified for Strategic Employment Sites in the 2024 West Midlands Strategic Employment Sites Study. This study defines strategic sites as those over 25ha.

The proposed COA also responds to the 2024 South Warwickshire Employment Land Study which identifies that the main clusters of industrial premises are within Leamington, Warwick and around Coventry Airport. As highlighted under Section 6.1, two principal potential strategic site locations are identified: South of Leamington and West of Warwick, with both of these areas falling within the proposed COA. In addition, it is proposed for the allocated JLR 100 ha. site at Gaydon (also within the COA) to be released for strategic manufacturing and small-scale logistics uses.

South Warwickshire Economic Strategy 2023

In 2023, a five-year Economic Development Strategy for South Warwickshire was published, with the main objective of the strategy being to co-ordinate economic growth activities in the area and highlight the area's significance and contribution to the wider regional and national growth plans. The strategy sets out nine objectives, with the following being of particular relevance to the concept of a Core Opportunity Area:

• Objective 3 – To support existing sectors
• Objective 5 - To attract new sectors to South Warwickshire to diversify the local economy
• Objective 8 – To ensure the adequate supply of employment land
• Objective 9 – To work with the West Midlands Combined Authority in the development and delivery of the Proposed West Midlands Investment Zone (WMIZ)

The Economic Development Strategy also goes on to set out a Core Investment Opportunity Area focusing on the towns of Kenilworth, Leamington, Stratford, Warwick and Whitnash, connected by the key roads of the A46 and M40. This area also includes many of the area's key employers and areas for employment growth – the University of Warwick's two campuses (including Wellesbourne Campus), the proposed West Midlands Investment Zone south of Coventry, Long Marston Garden Village and the Porterbrook Long Marston Rail Innovation Centre, Stoneleigh Park, the automotive hub at Gaydon and the proposed Kenilworth Gateway development. The area is also strategically located in proximity to HS2 and the related UK Central development hub nearby in Solihull Borough. The strategy goes on to outline the importance of connectivity in and to the Core Area, with the need for new investment to tackle existing congestion and maximise opportunities for public transport and use rail-based access where possible, and in the future a prospective innovation corridor concept.

6.3 Major Investment Sites

The Major Investment Sites in South Warwickshire include:

MIS.1 - Jaguar Land Rover/ Aston Martin Lagonda

MIS.2 - Long Marston Airfield

MIS.3 - Long Marston Rail Innovation Centre

MIS.4 - South of Coventry Area (including Coventry Airport and National Battery Innovation Centre/Coventry Gateway/ Whitley South)

MIS.5 - Stoneleigh Deer Park/Abbey Park

MIS.6 - Stoneleigh Park

MIS.7 - University of Warwick Main Campus

MIS.8 - University of Warwick Wellesbourne Campus

MIS.9 - Wellesbourne Airfield

Figure 11: Major Investment Sites

MIS.1 - Gaydon Area / M40 Junction 12 including Jaguar Land Rover and Aston Martin Lagonda

This automotive hub is home to the iconic British brands Jaguar Land Rover (JLR) and Aston Martin Lagonda. In addition to the economic activities on the Gaydon proving ground, circa 105ha of land has been allocated in the Core Strategy for employment purposes; 100 ha. for JLR, and 4.5 ha. for Aston Martin Lagonda. Through the SWLP, there is an opportunity to capitalise on the existing economic base and grow this area with further automotive-related manufacturing (i.e. Use Class B2).

We are reconsidering the specific allowed uses of the existing allocation at Gaydon, as the site has not come forward for the JLR related development it was originally allocated for in the SDC Core Strategy. As a key automotive cluster destination, is recommended that the existing 100 ha. JLR allocation is released to the wider market for manufacturing and small-scale logistics. Whilst well-located to the M40, this location is not seen as appropriate for strategic logistic uses (i.e. Use Class B8). Policy should prevent large (over 9,300 sqm) logistics units on the site, so that it stands as a strategic B2 manufacturing site on a well-located junction.

MIS.2/MIS.3 - Long Marston Area including the Garden Village and the Long Marston Rail Innovation Centre

The Long Marston Rail Innovation Centre is the UK's only looped test track and with its connection to the national rail network, provides a unique opportunity to act as a catalyst for growth in the rail technology sector. This part of South Warwickshire has the potential to intensify use of the site, and exploit the interrelationships with automotive and advanced engineering, especially in respect of alternative fuel technology. Existing opportunities in the Long Marston Area also include the employment land on Long Marston Airfield Garden Village.

MIS.4 - South of Coventry Area including Coventry Airport, Coventry Gateway and the National Battery Innovation Centre

The area of South Warwickshire to the south of Coventry has started to see considerable change. Strategic allocations in the current Warwick District Local Plan include large housing sites at Kings Hill and Westwood Heath as well as a sub-regional employment site to the south of Jaguar Land Rover's Head Quarters at Whitley. Planning permission has been granted for development on these sites and construction has commenced in the area.

Warwick University and Coventry Airport are located within the area. A planning application has been granted for a battery gigafactory on the airport site to support the country's shift towards electric vehicles and ultimately carbon neutrality. This development could complement existing facilities in the area including the Battery Industrialisation Centre, facilities at JLR and Warwick Manufacturing Group at the University.

Significant transport infrastructure improvements have been implemented, are ongoing and are being explored in the area. These include a new bridge over the A45 and transport improvements to connect JLR/Whitley Business Park to the new sub-regional employment site comprising Whitley South and Coventry Gateway. A new scheme will see a new bridge across the A46 and a new signalised gyratory system at the Stoneleigh Junction of the A46.

Further transport investment is being considered in the area. The potential for a new railway station near Kenilworth is being explored. A possible transport corridor, potentially incorporating Very Light Rail and to cater for other sustainable travel modes connecting the new Stoneleigh Junction to Warwick University and with strategic connections towards the proposed HS2 Interchange at UK Central in Solihull is also being explored.

This area has seen considerable interest from land promoters although it is important to note that much of the land is within the West Midlands Green Belt and the potential and suitability for further growth in this area would need to understand this context and the preferred option for growth.

MIS.5/MIS.6 - Stoneleigh Area including Stoneleigh Park agricultural science park and Stoneleigh Deer Park/Abbey Park

Stoneleigh Park is located to the east of Kenilworth and south of the village of Stoneleigh and is a major site in the Green Belt, home to the headquarters of the Royal Agricultural Society for England and a number of other agricultural and countryside organisations. The park hosts a wide range of shows and events and is an established part of the rural economy both locally and nationally.

The site will be significantly impacted by HS2 as it intersects Stoneleigh Park. This necessity for change to the site means that the emerging Local Plan provides an opportunity to reassess the use and purpose of the site and the density of development, noting that it currently is located in the Green Belt.

Stoneleigh Deer Park/Abbey Park will be protected as an existing/committed employment site.

MIS.7 - University of Warwick Main Campus Area

The University is a leading employer in South Warwickshire and plays an important role within the local economy as well as being of national and international importance. The campus has been developed following a Masterplan approved in 2009 that has now largely been implemented. A further planning application granted in 2019 enabled construction of two major projects

The University has aspirations to continue to improve and develop its campus and therefore the Plan will need to ensure that the aspirations of the University can be met, whilst ensuring any negative impacts of growth are mitigated. The relevant authorities have been working closely with the University to develop a Masterplan Framework Supplementary Planning Document (SPD) and Warwick District Council agreed to adopt the SPD in October 2024, subject to similar approval by Coventry City Council. The SPD was formally adopted by Warwick on 3^rd December following final approval at the Coventry City Council Full Council meeting.

The SPD provides a framework for guiding the level and broad location of growth on the main University of Warwick campus. The SPD provides supplementary guidance to Policy MS1 – University of Warwick - of the adopted Warwick District Local Plan. The South Warwickshire Local Plan will need to continue to support this major employer and its continued benefits to the local economy.

MIS.8/MIS.9 - Wellesbourne Area including University of Warwick and Wellesbourne Airfield

Wellesbourne is home to the adjacent sites of Wellesbourne Airfield and the University of Warwick's Wellesbourne Campus. The University of Warwick Innovation Campus Masterplan Framework Supplementary Planning Document was adopted in July 2023.

We would like to see an integral relationship between the university campus and airfield site, with the campus growing as a centre for cross-fertilisation research and development in high-tech automotive, battery and biosciences. The proximity of an operational airfield would hold the potential that aviation technology could add to these scientific endeavours. The airfield site also has the potential to house further industrial and research and development activities related to the campus (i.e. Use Class B2).

Other important economic assets in South Warwickshire include:

Silicon Spa – It is the home of the gaming industry. This extends from Leamington out to the surrounding areas of Southam and Warwick employing over 2,000 highly skilled people.

Automotive – Home to the UK's automotive industry. Coventry and Warwickshire has a reputation for being a world class centre for advanced manufacturing and engineering. Aston Martin, JLR and Lotus have a major presence in South Warwickshire. Manufacturing accounts for over 40% GVA in Stratford.

Food and Drink – Food and drink is important to the economy and Warwickshire is well known for its quality restaurants, locally produced artisan food and drink, farm shops delicatessens and café culture.

Highly Skilled Workforce – South Warwickshire has a well-qualified and skilled workforce which attracts businesses. Warwick and Stratford have a higher-than-average population with NVQ4 qualifications and above.

Bowls England – The HQ of Bowls England is in Leamington and each year hosts the National Bowls Championships.

Shakespeare's Birthplace – A popular attraction for overseas and UK visitors and is situated in the heart of Stratford-upon-Avon.

Castles and Country Estates – South Warwickshire is home to a number of significant country estates as well as Warwick and Kenilworth castle, both of which are major tourist attractions.

Royal Shakespeare Company – It is a major British theatre company employing over 1,000 staff and producing around 20 theatrical productions each year.

Cotswolds National Landscape – This is the third largest protected landscape in England which is popular with walkers and visitors to the area.

Agriculture – Warwickshire is home to a diverse range of farming, food and drink businesses and is approximately 70% agricultural land. Agriculture is important as it contributes to the local economy, local communities, protects the local environment and is a large employer to local people.

What was said in the I&O

A question was posed in the I&O document asking whether a policy should be included in the SWLP regarding additional economic growth at the identified Major Investment Sites. 82% of the 95 respondents to this question agreed that a policy should be included in the Local Plan.

In terms of protecting other existing employment sites in South Warwickshire, Question E6 asked if a policy should be includedwhich protects South Warwickshire's economic assets.Out of the 99 responses, a total of 85 respondents (85.9%) were in favour of having a policy to protect South Warwickshire's economic assets.

Question E8.1 pertained to Existing Employment Allocations in the SDC Core Strategy and the WDC Local Plan, asking "Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP?"

The revisions that were proposed to the existing Atherstone Airfield allocation within the I&O consultation involved retaining the allocation, but only retaining part of the site for relocating Canal Quarter Regeneration Zone businesses once the site had been developed for new businesses coming into the area.

There were 69 responses to Question E8.1. 'Yes' was selected by 52 participants (75.4%), 'No' was chosen by 8 respondents (11.9%), and 'Don't know' was selected by 9 respondents (13.0%).

Justification

NPPF

2024 NPPF Chapter 6 'Building a strong, competitive economy' makes clear at para 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 goes on to state that planning policies should set criteria or identify 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.

South Warwickshire Employment Land Study (2024)

This Study provides recommendations as to which existing employment allocations in the SDC Core Strategy and WDC Local Plan should be taken forward in the SWLP. The Study recommends that the existing 100ha. JLR allocation within the SDC Core Strategy is released for general manufacturing and small-scale logistics uses going forwards, rather than retained as an allocation entirely for JLR related uses as currently allocated. We will engage with JLR on looking at alternative sites that may be suitable for their needs.

South Warwickshire Economic Strategy 2023 (SWES)

The following SWES objectives are relevant:

Objective 5.3: Develop the Wellesbourne Innovation Campus & sector supply chains. Develop the Kenilworth Gateway employment site.

Objective 5.5 Sector diversification, internationalisation and inward investment support. To work with regional partners to attract inward investment into development and delivery of the proposed EV Giga Factory at Gateway South, Coventry Airport.

6.4 Provision of Office Accommodation and Refurbishment of Existing Office Stock

It is important to ensure that there is a sufficient quantity of office accommodation to meet the needs of South Warwickshire. The South Warwickshire Employment Sites Study (2024) sets out the office need up to 2050, as set out in Section 4.1.

As well as having sufficient sites in the right places to meet office need, office accommodation needs to be high quality and of the right type to meet the requirements of occupiers. Affordable office accommodation is also required. This Policy Direction seeks to address these matters, although specific allocations for office land will not be proposed until the next Reg. 19 version of the Plan.

In South Warwickshire, office accommodation is at a premium and there is an identified issue regarding a lack of grow-on space for businesses to expand. Changing requirements have led to higher demand for hybrid workspaces, and higher quality office space. There is a move towards cellular offices, with these in demand particularly for 2 or 3 people, rather than co-working space. As well as a demand for larger commercial units, there is an ongoing requirement for small industrial starter units. In terms of location, there is a growing preference for town centres rather than out of town business parks.

In Leamington Spa, the gaming industry in particular is experiencing pressures for office space. In the wider market, there is a need for both large and small spaces. One issue identified is businesses who would prefer to move into bigger premises being unable to do so, thus reducing the availability of smaller units for smaller businesses and start-ups.

What was said in the I&O

The Issues and Options consultation did not have a specific question relating to office accommodation; however, there was a question (Issue E5) about the provision of business accommodation in general.

Issue E5 stated that "In South Warwickshire, office accommodation is at a premium and there is an identified issue regarding a lack of grow-on space for businesses to expand. Changing requirements have led to higher demand for hybrid workspaces, and higher quality office space. There is a move towards cellular offices, with these in demand particularly for 2 or 3 people, rather than co-working space. As well as a demand for larger commercial units, there is an ongoing requirement for small industrial starter units. In terms of location, there is a growing preference for town centres rather than out of town business parks.

In Leamington Spa, the gaming industry in particular is experiencing pressures for office space. In the wider market, there is a need for both large and small spaces. One issue identified is businesses who would prefer to move into bigger premises being unable to do so, thus reducing the availability of smaller units for smaller businesses and start-ups."

The majority of respondents (76.1%) expressed agreement with the inclusion of a detailed policy in Part 1 that supports a range of business units. The results indicated that there is a need to encourage the growth of diverse businesses, including startups that may encounter challenges in securing affordable premises.

Justification

NPPF

Paragraph 85 of the NPPF states that "Policies… should create the conditions in which businesses can invest, expand and adapt."

Paragraph 86 of the NPPF states that Policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to the national industrial strategy and any relevant Local Industrial Strategies and other local policies for economic development and regeneration. "

The South Warwickshire Employment Land Study (2024) considered that the market signals indicate that a significant proportion of market demand is driven by the need for high quality office space within Leamington Spa and Warwick town centres. The Study found that there is currently a lack of high-quality space in the town centres to support the needs of the digital and creative sector. It is therefore important that Local Plan policy protects and encourages the refurbishment of existing office stock within Leamington Spa town centre to provide this space.

The Study also found that office vacancy rates in Warwick District are currently much higher than Stratford-on-Avon; and Coventry & Warwickshire (8.9%) at 10.8%. Stratford-on-Avon has a much lower office vacancy rate of 3.8%. The high vacancy rate in Warwick is partly driven by a mismatch in the available supply of stock and what occupiers want, as a significant portion of Warwick's office stock is outdated and not of high quality.

The South Warwickshire Employment Land Study suggests a number of potential sites that could be allocated for office use, however additional work needs to be completed before we make any decisions on allocating specific sites for office development in the SWLP. It is expected that the Reg. 19 (publication) version of the SWLP will include proposed office allocations. We will also explore allocating specific sites for affordable office development.

There is significant issue with a lack of affordable office accommodation in the Districts. 'Affordable' in this context refers to workspace where rates are maintained below the market rate. We will explore what may be an appropriate level to set an affordable rate as a percentage of market rate. For example, this could include discounted market sales / fixed equity where the units are always sold at a percentage (for example 75%) of the market rate. Alternatively, where the units are offered for rent, these could be at a percentage of the market rate for comparable units in the locality. The definition of comparable will change over time and the locality will depend on the level of market activity in the area.

South Warwickshire Economic Strategy (SWES)

The SWES had the following relevant objectives:

Objective 8.1 of the South Warwickshire Employment Strategy 2023 Is to "facilitate the provision of additional affordable employment premises across South Warwickshire through the SWLP".

Objective 8.2 of the SWES is "to ensure adequate future supply of employment land in the right locations across South Warwickshire through the SWLP."

6.5 Airfields

South Warwickshire has three airfields that have been proposed for an element of economic redevelopment: Coventry Airport, Atherstone Airfield, and Wellesbourne Airfield.

It is considered that Coventry Airport and Wellesbourne Airfield could be appropriate for redevelopment/partial redevelopment for employment purposes. Wellesbourne Airfield is currently protected for aviation activities within the Area Strategy for Wellesbourne in the SDC Core Strategy, therefore any future employment development of the site would need to ensure that the aviation function of the airfield would continue to be secured. Coventry Airport has already received planning permission to be developed for a Gigafactory. Land south of Coventry Airport is allocated within the WDC Local Plan (Policy DS16) for a major employment site (B1, B2 and B8 uses) of sub-regional significance.

Atherstone Airfield is currently an allocation (SUA.4) within the SDC Core Strategy for the relocation of businesses from the Canal Quarter Regeneration Zone. Whilst we did propose to retain this as an employment allocation within the I&O consultation document, it is no longer considered appropriate for development due to lack of adherence with our overall growth strategy (see Section 4.1). As such, we are now proposing to release the existing Core Strategy allocation of Atherstone Airfield.

What was said in the I&O

No specific question on Airfields was asked in the Issue and Options consultation document, however, the Issue E7 on the Core Opportunity Area and the Major Investment Sites did note Wellesbourne Airfield and Coventry Airport as Major Investment Sites in South Warwickshire.

Justification

Airfields are generally considered to be Previously Developed Land under national planning policy, and therefore their redevelopment enables large scale employment sites to be delivered without the need to develop greenfield land. They can be particularly suitable for redevelopment for employment uses, due to their large scale.

Each of the three Airfields within South Warwickshire have different qualities in terms of location, scale and setting, and therefore the type and quantum of development that would be considered appropriate differs between them. Whilst Atherstone Airfield is currently allocated for employment development within the adopted SDC Core Strategy to accommodate the relocation of businesses from the Canal Quarter Regeneration Zone, we propose to remove this allocation as it is considered development of this site would not accord with our overall spatial growth strategy (see Section 4.1). Coventry Airport already has planning permission for a Gigafactory (a facility to manufacture batteries for electric vehicles and a range of other applications at scale), however, it is considered that the site should be allocated for this use in order to ensure the delivery and protect the site from an application for other uses during the process of identifying an occupier for the site.

It is considered that Wellesbourne Airfield can accommodate some employment development, as recommended by the South Warwickshire Employment Study 2024, although it is also considered that the overall aviation function of this airfield should be protected.

The South Warwickshire Economic Strategy (2023)

The Economic Strategy includes the following relevant objectives:

Objective 5.2 Support the provision of an electric vehicle "Gigafactory" and support low carbon future mobility and its associated value and supply chains within South Warwickshire.

Objective 5.5 Sector diversification, internationalisation and inward investment support: To work with regional partners to attract inward investment into development and delivery of the proposed EV Giga Factory at Gateway South, Coventry Airport.

NPPF

2024 NPPF Chapter 6 'Building a strong, competitive economy' makes clear at para 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.

Paragraphs 86 and 87, have been expanded specifically stating that policies should identify appropriate sites to meet the needs of the modern economy, such as laboratories, gigafactories, data centres and freight and logistics.

6.6 A Low Carbon Economy

It is important to try and encourage greener businesses into the area as well as encouraging existing businesses to become greener and to have the opportunity for greener initiatives.

The location and accessibility of new facilities relative to their suppliers and customers can help make substantial reductions and a significant contribution towards the goal of net zero.

Whilst many existing commercial buildings may not achieve optimal energy efficiency, there is considerable scope for industry to play a key role in harnessing renewable energy generation.

What was said in the I&O

The Issues and Options consultation document said that it is important to try and encourage greener businesses into the area as well as encouraging existing businesses to become greener and to have the opportunity for greener initiatives. Businesses may choose to do this in several different ways, for example looking at active travel promotion for employees, adapting existing buildings and looking at new buildings to become more energy efficient.

Whilst many existing commercial buildings may not achieve optimal energy efficiency, there is considerable scope for industry to play a key role in harnessing renewable energy generation.

Overall, there was majority support for a policy which would encourage businesses to be low carbon, and a significant amount of support for a policy which would look to identify sites or development zones which are targeted at businesses wishing to be innovative towards a low carbon economy.

Justification

In 2019, Warwick and Stratford-on-Avon District Councils both declared a climate emergency. Both have committed to reduce district wide emissions by 55% by 2030. A joint 'Climate Change Action Programme', agreed by both Councils in November 2021, sets out ambitions and how we'll achieve them. This requires the rapid decarbonisation of emission sources which fall outside of the jurisdiction of local authorities. A 2021 report produced on our behalf showed that emissions arising from energy use in non-domestic buildings and industrial processes represented 22.9% of the total carbon footprint of the Stratford and Warwick District areas. A recent report produced by Sustainability West Midlands highlighted that 65% of UK SMEs have been financially impacted by their lack of response to weather information. As the impacts of climate change continue to be felt, it is likely that this figure will increase. Economic development will play a vital role in driving the UK's transition to net zero. It is predicted that by 2050, there could be up to 1.18 million jobs in low-carbon and renewable energy sectors, and this offers great opportunities to the area given our access to research and talent. We will encourage low-carbon sectors to the Stratford and Warwick Districts to ensure that the area is well positioned to benefit from this. The Local Plan will enable a shift to a low carbon economy within the area in the following ways

1. Businesses will be supported to reduce their carbon footprint.
2. Economic development within Stratford and Warwick Districts will maximise the economic opportunity presented by the transition to net-zero and the need to adapt to a changing climate.
3. Business resilience will be increased through the provision of climate change adaptation measures.

South Warwickshire Economic Strategy (2023)

The SWES includes the following relevant objectives:

Objective 4 – To de-carbonise the existing South Warwickshire economy

4.1 Work with existing partners to establish a network of low carbon business champions to promote and support the de-carbonisation of existing businesses and to encourage a circular economy across South Warwickshire

4.2 Encourage and support the retrofitting of commercial premises with renewable energy generation

4.3 Work with Shakespeare's England and the new Local Visitor Economy Partnership (LVEP) tourism businesses to de-carbonise the tourism sector including through more sustainable travel

6.7 Supporting Rural Employment and Diversification

South Warwickshire is a predominately rural area, and this Policy Direction seeks to support economic activities in rural areas. The rural economy encompasses all businesses operating in rural locations; not just those engaged in agricultural or land-based activities such as farming, food production or tourism. Whilst needing to be mindful of constraints such as landscape setting and traffic on rural roads, this strategy seeks to capitalise on the potential to provide for local employment opportunities to ensure thriving rural communities, including through agricultural diversification schemes.

This policy is intended to enable the economic prosperity of rural areas by supporting the provision of employment (particularly small businesses) within rural areas, as well as the diversification of rural businesses, including agricultural uses.

What was said in the I&O

The Issues and Options consultation document identified that over half the population of South Warwickshire lives outside of the main urban areas. Whilst many of these residents will commute to these urban areas or outside the District for work, a proportion are employed in the rural economy.

The I+O consultation document noted that travel to places of work by public transport in South Warwickshire is difficult due to its rural nature and the lack of regular and reliable bus services. It can hinder any job opportunities for people both in Warwick and Stratford district and with Stratford having a predominantly older population, businesses often look to locate in the north of the county where labour supply is better.

The I+O consultation document considered that the South Warwickshire Local Plan should explore the diversification of the rural economy. With appropriate diversification, businesses may be able to have greater resilience by providing a range of income generating streams. For example, farm shops and tourism can supplement agricultural income which can create new jobs and help sustain the vitality of rural communities. Innovation surrounding technology can also help to support agricultural and rural businesses in adapting to changing circumstances, including helping to address climate change and increasing biodiversity.

Another component of the rural economy is the provision of general employment opportunities in rural locations, including within villages, perhaps through the conversion of historic farm buildings that are no longer suited to modern agricultural uses.

The Issues and Options consultation document asked respondents if we should include a Policy supporting the diversification of rural businesses. There was overwhelming support amongst respondents to include a policy supporting diversification.

Justification

NPPF

Paragraph 85 of the NPPF states that "Policies… should create the conditions in which businesses can invest, expand and adapt."

Paragraph 86a states that Policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to the national industrial strategy and any relevant Local Industrial Strategies and other local policies for economic development and regeneration. Paragraph 88 states that "Planning policies and decisions should enable the sustainable growth and expansion of all types of business in rural areas"

Para 89 states 'Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.'

South Warwickshire Employment Land Study (2024)

The South Warwickshire Employment Land Study identified that there are 91 'agri-tech' businesses within South Warwickshire supporting 1,610 jobs. The sub-sector is driven by rural businesses such as food production, farming, food processing, food logistics rather than high-technology companies.

The Employment Land Study also found that manufacturing businesses were spread across the whole district, reflecting that there is a strong presence of industrial businesses in the smaller towns and rural areas. The Employment Land Study also identified that there has been high take-up of small units, even in rural areas, which is reflected in ultra-low vacancy rates across the whole area.

South Warwickshire Economic Strategy (2023)

The SWES had the following relevant objective:

3.2 - Support the diversification of the rural economy including through the provision of local hubs for rural and agricultural industries that foster collaboration and innovation.

6.8 Supporting a Range of Business Units and Affordable Employment Space

In South Warwickshire there is an identified issue regarding a lack of grow-on space for businesses to expand. As well as a demand for larger commercial units, there is an ongoing requirement for small industrial starter units. In terms of location, there is a growing preference for town centres rather than out of town business parks. In the wider market, there is a need for both large and small spaces. One issue identified is businesses who would prefer to move into bigger premises being unable to do so, thus reducing the availability of smaller units for smaller businesses and start-ups.

What was said in the I&O

Issue E5 identified that there is an identified issue regarding a lack of grow-on space for businesses to expand. As well as a demand for larger commercial units, there is an ongoing requirement for small industrial starter units. In terms of location, there is a growing preference for town centres rather than out of town business parks.

One issue identified was businesses who would prefer to move into bigger premises being unable to do so, thus reducing the availability of smaller units for smaller businesses and start-ups.

The majority of respondents (76.1%) expressed agreement with the inclusion of a detailed policy in Part 1 that supports a range of business units. The results indicated that there is a need to encourage the growth of diverse businesses, including startups that may encounter challenges in securing affordable premises.

Justification

NPPF

Paragraph 85 of the NPPF states that "Policies… should create the conditions in which businesses can invest, expand and adapt."

Paragraph 86a states that Policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to the national industrial strategy and any relevant Local Industrial Strategies and other local policies for economic development and regeneration It also sets out that policies should allow for new and flexible working practices, such as live-work accommodation.

The South Warwickshire Employment Land Study 2024

Iceni engaged with local agents and investors in Coventry & Warwickshire to gain insight into the current state of the commercial market, the profile of enquires received and where there are gaps in the supply provision.

It was identified that despite a recent 'pause' in activity, over the past decade, demand for industrial space has been consistently strong. As a result, rents have significantly risen, especially for new-build units.

Whilst there has been some recent development, there has been a lack of small and mid-sized units delivered This is as a result of developers maximising their plots with the development of larger single units. Agents report that there is an ongoing mismatch between the available supply and what the market wants.

It was considered that this issue could be managed through allocation policies or the allocation of smaller sites that lend themselves to small and medium units. Available sites and units to do not stay on the market long once advertised, therefore there is scope to be 'pickier' on what unit sizes are delivered.

There is a good provision of small units however lack of mid-box space means there is nowhere for growing businesses to move onto and therefore they relocate. There is also a lack of affordable space for SMEs.

'Affordable' in this context refers to workspace where rates are maintained below the market rate. When looking at specific allocations and a detailed policy to support affordable workspace in the Reg.19 version of this Plan, we will explore what may be an appropriate level to set an affordable rate as a percentage of market rate. For example, this could include discounted market sales / fixed equity where the units are always sold at a percentage (for example 75%) of the market rate. Alternatively, where the units are offered for rent, these could be at a percentage of the market rate for comparable units in the locality. The definition of comparable will change over time and the locality will depend on the level of market activity in the area.

South Warwickshire Economic Strategy (2023)

The SWES has the following relevant objectives:

Objective 8 – To ensure the adequate supply of employment land

Objective 8.1 - facilitate the provision of additional affordable employment premises across South Warwickshire through the SWLP.

Objective 8.2 - ensure adequate future supply of employment land in the right locations across South Warwickshire through the SWLP.

Objective 8.3 - To ensure the appropriate availability of physical infrastructure such as offices, enterprise and innovation centres and move on space in rural market towns in support of their neighbourhood plans.

6.9 Protecting Community Facilities

Community facilities such as local shops, meeting places/village halls, medical facilities, sports venues, open space, cultural buildings, pubs and places of worship are important for supporting the health, wellbeing and inclusivity of communities.

This policy will aim to provide protection for existing community facilities, to ensure that these are not redeveloped to other non-community uses unless necessary). There are some circumstances in which the loss of a community facility may be required due to reasons of viability, however, in these cases, this Policy provides a rigorous framework against which proposals of this nature must be assessed.

What was said in the I&O

Issue E8 begins by covering existing employment allocations and goes on to acknowledge the benefits of the many business use premises across South Warwickshire. It is explained here that whilst national planning policy is clear that we cannot arbitrarily resist the change of use of such premises, it is legitimate to ensure that as the local planning authorities, we should be satisfied that all reasonable endeavours have been explored prior to change of use. Reasonable endeavours include a satisfactory marketing period with the property marketed at an appropriate value, an independent viability assessment and consideration of a range of alternative commercial uses.

Question E8.3: Do you agree that proposals seeking the loss of a business, commercial or community building or facility should be subject to marketing, viability and alternative use tests?

Approximately three quarters of respondents answered 'yes' to this question. There was a 50:50 split of developers and business respondents who answered, 'yes' vs 'no'. All other respondent types showed a much clearer preference for 'yes' than 'no'.

Question E8.4: Marketing, Viability and Alternative Use Tests - Please specify what you consider to be appropriate tests

Several respondents stated that marketing periods should be at least 12 months long. It was also mentioned that the SWLP should look at example[s] from other local authorities to ensure a rigorous approach was taken. One respondent highlighted that if a building was irreplaceable in a location, this should factor as a consideration.

Protection of community facilities such as theatres and pubs were noted as particularly important by two respondents. For example, it was suggested that residents should be able to purchase unviable village pubs.

However, a couple of respondents considered that the tests should be more lenient towards businesses wanting to change use and it was suggested different scenarios should be subject to different tests, rather than a one-size-fits-all approach.

Explanatory Text

The National Planning Policy Framework recognises that community facilities and services contribute to the sustainability of communities, and that planning policies and decisions should enable the retention and development of accessible local services and community facilities.

When assessing the proximity of similar facilities in accordance with criterion 3, these should be available to access by all reasonable sustainable modes of transport by the community.

Where a viability assessment is required in accordance with Criterion 1, the applicant will need to demonstrate that all reasonable measures to improve the viability of the facility have been pursued. The District Council will have any assessment independently reviewed by a qualified person and the costs of this must be met by the applicant.

It is important that the period covered by the marketing period is recent and reflects current market conditions. To ensure this is the case, the end of the marketing period should be within a maximum of six months of the date of submission of the planning application.

Consultation and engagement with the local community, including the Parish Council, must be demonstrated. Proposals for a community consultation and engagement strategy should be developed in close association with the Parish Council and advice should be sought from the District Council on the approach to engagement.

Justification

It is already recognised that community facilities such as local shops, meeting places/village halls, medical facilities, sports venues, open space, cultural buildings, pubs and places of worship are important for promoting healthy and inclusive communities. The provision of new and protection against undue loss of these facilities are vital considerations.

Many of these facilities provide an important role in promoting community cohesion, offering opportunities for diverse groups of people to socialise. They can also provide multi-functionality by hosting events, clubs, and providing informal meeting spaces for local interest groups. This is often the case with village/community halls. The National Village Halls Survey 2020 written on behalf of ACRE (Action in Communities with Rural England) found that village halls make a significant contribution to the economy, give small and local businesses a location to operate (e.g. yoga classes, dog training classes) and provide other employment opportunities (e.g. cleaners and caretakers).

Pubs also have a strong role to play in supporting the local economy. They can help bring activity and vibrancy to our high streets in town centres and in rural areas where employment opportunities are more limited and provide indirect opportunities by supporting food suppliers and brewing industries.

Much work has already been done by Stratford's Public House Task and Finish Group to ensure the foundations are laid for the enhancement of policies that protect the loss of community facilities and services. Whilst this work has, primarily, been with pubs in mind, the principles and planning guidance published in the Public Houses Planning Advice Note can be applied to other, defined, facilities and services. It is clear from the work of this group that there is a strong recommendation to convert the guidance in the Advice Note to policy. It has been advised that changes to future policies, including measures to strengthen protections against redevelopment of pubs, should be considered and consulted on as part of preparing a new local plan. For example, The Public House Task and Finish Group highlighted the need to require multiple criteria to be met not just the one criterion as stipulated under the current CS.25 Healthy Communities policy.

Paragraph 98 of the NPPF states that planning policies and decisions should "plan positively for the provision and use of shared spaces, community facilities", "guard against the unnecessary loss of valued facilities and services" and "ensure that established shops, facilities and services are able to develop and modernise and are retained for the benefit of the community".

6.10 Supporting our Changing Town Centres

Town centres play a major role in serving local communities and form an important part of South Warwickshire's identity and character. Thriving town centres support local economic growth and encourage investment. Recent changes in consumer habits such as the growth of internet shopping and the economic impacts of the Covid pandemic are changing the traditional composition of our high streets. It is therefore essential that the Local Plan sets out a policy framework that will continue to support the maintenance of and enhance the ongoing vitality and viability of our town centres.

What was said in the I&O

The Issues and options consultation document outlined a suggested policy response which would identify South Warwickshire's network and hierarchy of town centres. It was also noted that a technical study was being produced by independent consultants to examine the current health and functionality of our town centres and to advise us on any future floorspace requirements that may be required during the plan period to 2050. The retail study would also examine the relationship between our town centre and out of centre retail destinations.

The Issues and options consultation (January 2023) specifically sought opinion regarding questions suggesting two alternative policy approaches for our town centres.

The summary responses indicated a strong preference for identifying town centre retail areas and town centre boundaries in Part 1 of the Plan.

Justification

NPPF

Chapter 7 of the NPPF (Ensuring the vitality of town centres) states that planning policies should support the role that town centres play at the heart of local communities. The NPPF requires Local Plans to address the following key issues: -

1. Define a network and hierarchy of town centres and promote their long-term vitality and viability – by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries, allows a suitable mix of uses (including housing) and reflects their distinctive characters
2. Define the extent of town centres and primary shopping areas and make clear the range of uses permitted in such locations, as part of a positive strategy for the future of each centre.
3. Allocate a suitable range of sites in town centres to meet the scale and type of development likely to be needed looking at least ten years ahead. Town centre boundaries should be kept under review where necessary
4. Where suitable and viable town centre sites are not available for main town centre uses, allocate appropriate edge of centre sites that are well connected to the town centre. If sufficient edge of centre sites cannot be identified policies should explain how identified needs can be met in other accessible locations that are well connected to the main town centre
5. Recognise that residential development often plays an important role in ensuring the vitality of centres and encourages residential development on appropriate sites.

The NPPF also requires Local Planning authorities to apply a sequential test to planning applications for main town centre uses which are neither in an existing centre nor in accordance with an up-to- date plan. Main town centre uses should be located in town centres, then in edge of centre locations: and only if suitable sites are not available (or expected to become available within a reasonable period) should out of centre sites be considered.

When assessing applications for retail and leisure development outside town centres, which are not in accordance with an up-to-date plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set threshold (if there is no locally set threshold, the default threshold is 2500 sq.m of gross floorspace).

The Retail and Town Centres Uses Study (2022)

This study provided a robust series of recommendations to help the plan making process against the background of the pandemic and worsening macroeconomic position.

The headline retail capacity forecasts showed no immediate capacity for comparison goods to 2035 with limited capacity emerging thereafter from 2040. No convenience goods capacity is forecast across South Warwickshire over the period to 2035. In the case of both convenience and comparison goods there is no requirement to allocate any new sites for retail provision in the period to 2035. This is due to the convenience floorspace proposed as part of the Councils existing housing allocations together with the fact that some convenience capacity could also be met by the reoccupation of currently vacant units and within smaller new development or redevelopment proposals.

An assessment of the potential for new commercial leisure needs was also undertaken. The findings of the market research surveys, and health check assessments confirmed the importance of leisure uses and venues to the overall mix and attraction of centres within south Warwickshire. As a part of their future adaptation and growth, it is important that the SWLP policy approach maintains and promotes a diverse and flexible range of leisure uses in their main centres.

In the context of the issues and challenges identified in the Retail Study, retail will remain a key part of town centres overall offer, vitality and viability – helping to generate trips, footfall and spend – it is critical that policies and strategies developed for each centre help to promote greater flexibility and diversity, so that they can respond more effectively and rapidly to future trends.

The Town Centres study also emphasised the potential for new residential development in and on the edge of main town centres which may help to maintain vitality and viability. This would help generate trips, footfall and spend for the benefit of existing shops and businesses as well as supporting any new provision.

The South Warwickshire Employment Land Study (2024) considered that the market signals indicate that a significant proportion of market demand is driven by the need for high quality office space within Leamington Spa and Warwick town centres. The Study found that there is currently a lack of high-quality space in the town centres to support the needs of the digital and creative sector. It is therefore important that Local Plan policy protects and encourages the refurbishment of existing office stock within Leamington Spa town centre to provide this space.

The South Warwickshire Employment Sites Study suggests a number of potential sites that could be allocated for office use, however additional work needs to be completed before we make any decisions on allocating specific sites for office development in the SWLP. It is expected that the Reg. 19 (publication) version of the SWLP will include proposed office allocations.

South Warwickshire Economic Strategy 2023 (SWES)

The following SWES objectives are relevant:

Objective 7.1 To facilitate the delivery of the World Shakespeare Centre in Stratford-upon-Avon; support & facilitate the delivery of key public realm/highway schemes to help improve the place and economic wellbeing of town centres e.g. Bridge Street / High Street (SuA), Parade (Leamington Spa), Bath Street

Objective 7.5 Deliver Leamington's Future High Street Fund and wider transformation projects to strengthen the 'Silicon Spa' cluster as the national centre for digital creative industries. To work in partnership Transforming Leamington Board to progress projects to address town centre issues in Leamington Spa

6.11 Arts and Culture

The sensitive expansion of South Warwickshire's arts and cultural sector, and associated heritage and tourism assets, will contribute to social inclusion, health and wellbeing and improvements in quality of life for all sectors of the local population. Culture is recognised by national government as making a significant contribution to 'place making' and delivering sustainable communities.

The protection, promotion and expansion of existing cultural facilities, visitor attractions and associated activities will ensure their role as key economic drivers stimulating and regenerating the local economy is supported and will be enhanced as often as possible.

What was said in the I&O

References to arts and culture was primarily in relation to existing heritage assets and associated with economic development, specifically tourism. Responses recommended capitalising on South Warwickshire's heritage assets to ensure a thriving destination for tourism/culture.

Justification

South Warwickshire has a rich cultural heritage, which includes a wide range of organisations and venues, which not only are important to make South Warwickshire a great place to live, work and visit, but also contribute directly to the economy of the area.

The South Warwickshire Economic Strategy 2023-2028 includes an objective "... to increase the vitality of our high streets and town centres and promote the economic value of our artistic and cultural assets. The visitor economy - including hospitality, retail, leisure, cultural heritage and the arts – is identified as a 'core opportunity sector'.

Stratford District Council's 2030 vision includes to "... be well-known internationally for the culture, heritage and countryside across the District, and for the quality of its visitor experience, as well as for being Shakespeare's birthplace." Warwick District Council's Corporate Strategy 2030 includes creating vibrant communities, with actions relating to creative communities, arts, heritage and sports.

Further guidance will draw from relevant arts and culture strategies, such as Warwickshire County Council's Heritage and Culture Strategy 2020-2025, as well as advice notes produced by Historic England, and the guidance offered within the NPPF.

The 'agent of change' principle is set out in the NPPF and is necessary, to require changes in use of land to manage the impact of that change, to protect the ongoing operation of existing arts and cultural venues.

6.12 Tourism

We are proposing to address tourism within Part 2 of the SWLP, and therefore there is no Policy Direction at this stage. Whilst tourism is an important issue that the Local plan will need to address, it is not felt that tourism plays a spatially strategic role and should therefore be addressed in part 2 of the South Warwickshire Local Plan. In the meantime, the existing tourism policies of the SDC and WDC Development Plans will continue to hold full weight.