Preferred Options 2025

Ends on 7 March 2025 (52 days remaining)

11. A Biodiverse and Environmentally Resilient South Warwickshire

A healthy natural environment is of vital importance to people, places, the economy and nature itself. It provides important services such as food, fresh water, clean air, climate stabilisation and resilience, flood control, recreation, tourism and much more.

Broadly speaking, there are two types of natural asset that combine to give South Warwickshire its distinct natural environment. Firstly, there are specific environmental assets, including nature conservation and biodiversity interest, and features of historic value (including geologically and geomorphologically important features). Secondly, there are particular landscape characteristics familiar to the locality based upon its topography, farming, history and settlement patterns.

South Warwickshire is experiencing concerning declines across a number of key habitats and species and there is a significant need to halt and reverse these declines for the future prosperity of South Warwickshire. This means that development delivered through the SWLP must not be done at the expense of the natural environment. Instead, opportunities will be identified to protect and enhance existing ecological assets and the prevailing landscape character.

The following section focuses on the protection and enhancement of biodiversity, geodiversity and landscape across South Warwickshire on a strategic scale. It identifies how specially protected sites, landscape and priority species will be safeguarded against future development, how progressing the Local Nature Recovery Strategy will be used to influence the creation of new habitats to increase connectivity, and how Biodiversity Net Gain will be used as a tool to deliver the biodiversity ambitions of Stratford-on-Avon District Council and Warwick District Council.

11.1 Protection of Sites, Habitats and Species

Safeguarding is more than merely preventing the destruction of natural features, but an expectation that development proposals should embody the long-term management of these features to enhance their value to biodiversity and geodiversity, as well as recognising opportunities for securing biodiversity enhancement through the built environment.

South Warwickshire has a rich array of biodiversity and geodiversity assets, valued for environmental, social, and economic benefits. These sites include those with statutory legal protection such as Sites of Special Scientific Interest (SSSIs), as well as sites of local importance such as Local Nature Reserves and Ancient Woodlands, which fall to Local Plans to determine their protection.

In addition to protected sites, South Warwickshire is home to multiple Priority Species. These species are identified in the Warwickshire, Coventry, and Solihull Local Biodiversity Action Plans, produced by the Wildlife Trust[6] and Warwick District Council's Biodiversity Action Programme[7]. In total, there are 27 Protected Species within Warwickshire. These species have been designated as such based on multiple considerations, including their scarcity, cultural value, and their identification as internationally or nationally threatened. It is crucial that the SWLP takes the protection of these species into consideration and provides measures to enhance populations.

Safeguarding existing designated sites, expanding the network of designated sites, and enhancing the populations of Protected species will form a key consideration of the new SWLP.

What was said in the I&O

Question B9 of the Issues and Options consultation asked "Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to flood or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites."

131 responses were received to this question. 126 responses (96.2%) supported the implementation of such a policy.

The following relevant question was also asked:

"Should the South Warwickshire Local Plan introduce Wildbelt designations?"

80% of respondents supported the inclusion of Wildbelts in the SWLP. However, since the initial introduction of Wildbelts as a concept in 2020, the Environment Act has introduced the concept of Local Nature Recovery Strategies. It is proposed that LNRSs are used to safeguard areas for nature in the SWLP due to their grounding in nationally recognised policy. Therefore, wildbelts will not be included as a land designation in the SWLP.

Draft Policy Direction-36 - Protection of Sites, Habitats and Species

The SWLP will include a policy to protect and enhance internationally, nationally, and locally important biodiversity and geodiversity sites and assets, both designated and non-designated, using the evidence-based documents such as the emerging Local Nature Recovery Strategy (LNRS) and the findings of the Habitat Regulations Assessment (HRA) as a guide.

The policy will cover:

Nationally Important and Protected Sites:

  • Sites of Special Scientific Interest (SSSIs)
  • National Nature Reserves
  • Ramsar sites
  • Special Areas of Conservation
  • Special Protection Areas
  • Sites identified for formal designation under the above schemes/categories

Locally Important Sites and Assets:

  • Ancient woodland
  • Ancient and Veteran trees
  • Local Nature Reserves
  • Local Wildlife Sites, including potential, and in certain instances rejected ones.
  • Sites not yet subject to formal designation but known to make a positive contribution to biodiversity and/or geodiversity
  • Irreplaceable habitats (as defined in the Biodiversity Gain Requirements (Irreplaceable habitat) Regulations 2024)
  • Local Geological Sites
  • Sites of geological or geomorphological importance
  • Protected rare, endangered, or priority species, particularly those recognised in local biodiversity action plans

The policy will follow the principles outlined in the Lawton Report of more, bigger, better, and joined up. It will do this by:

  • Protecting existing important sites and assets.
  • Enhancing existing important sites and assets.
  • Identifying opportunities to create and enhance habitat connectivity by identifying new sites for designation.
  • Creating new habitats which support Warwickshire target species.

Do you agree with the approach laid out in Draft Policy Direction-36 - Protection of Sites, Habitats and Species? Comment

Justification

The national planning policy guidance on conserving and enhancing the natural environment and the criteria that apply to sites of international and national importance for biodiversity and geological conservation is set out in the NPPF. Paragraphs 187 and 192 of the NPPF set out the requirements to protect and enhance biodiversity and geodiversity.

Section 40 of the NERC Act 2006 places a legal duty on public authorities to conserve biodiversity.

The Apex Goal of the Environment Improvement Plan 2023 is thriving plants and wildlife. This is Government's plan for delivering legally binding targets in the Environment Act 2021. The plan aims to achieve a growing and resilient network of land, water and sea that is richer in plants and wildlife.

11.2 Local Nature Recovery Strategy

In recognition of the need to enhance biodiversity levels across the UK, the Government has committed to ensuring 30% of land is protected for nature by 2030. To provide strategic direction to enable this to be achieved, Local Nature Recovery Strategies are being produced.

Local Nature Recovery Strategies (LNRS) were introduced as part of the Environment Act 2021 to help reverse nature's decline. They will be used to identify and prioritise opportunities for nature improvements, focussing on particular areas, species and habitats.

48 LNRSs will be produced throughout England to link together to cover the whole country, forming part of a Nature Recovery Network. The South Warwickshire Local Nature Recovery Strategy is being produced by Warwickshire County Council as the Responsible Authority.

LNRS are designed to work closely with Biodiversity Net Gain (BNG). LNRS guide the delivery of BNG to support the protection or improved resilience of important habitats.

This policy will aim to protect existing areas of importance for nature and require development to enhance, connect and expand these areas in line with the LNRS.

What was said in the I&O

The Issues and Options consultation didn't include specific questions about LNRS. At the time of consultation, they were an emerging area of national policy awaiting further detail Government.

Draft Policy Direction-37- Local Nature Recovery Strategy

Development proposals will be expected to support the principles of LNRS and demonstrate that a positive contribution will be made to the regional nature recovery network by maintaining and enhancing local ecological networks through habitat creation, protection, enhancement, restoration and/or management.

Do you agree with the approach laid out in Draft Policy Direction-37- Local Nature Recovery Strategy? Comment

Justification

LNRS are a statutory requirement of The Environment Act 2021.

Updates to the NPPF are expected to give weight to LNRS in the plan-making process.

11.3 Biodiversity Net Gain

Biodiversity net gain (BNG) is an approach to development that makes sure habitats for wildlife are left in a measurably better state than before.

BNG is additional to existing habitat and species protections. It aims to create new habitat as well as enhance existing habitats, ensuring that the ecological connectivity they provide for wildlife is retained and improved.

Under the mandatory system, developments (with some exceptions) are required to deliver 10% BNG. This will be achieved by delivering habitat on-site or, if that is not possible, through buying off-site biodiversity units.

BNG is designed to work closely with Local Nature Recovery Strategies (LNRS). LNRS guide the delivery of BNG to support the protection or improved resilience of important habitats.

Local Planning Authorities can seek a higher percentage for BNG where there is justified local need and opportunity.

This policy aims to reinforce the statutory framework for BNG and link the delivery of BNG to local priorities and strategies for nature recovery.

What was said in the I&O

The Issues and Options consultation included questions about wider Environmental Net Gain (ENG), rather than BNG alone. However, comments were made about BNG across other related questions.

Mixed views on going beyond statutory 10% BNG requirements – robust evidence would be needed to provide justification.

Good support for new development and changes to existing buildings to incorporate measures to increase biodiversity such as wildlife friendly and biodiverse planting and landscaping, appropriate external lighting and minimal paved/hard surfaced areas.

Draft Policy Direction-38 - Biodiversity Net Gain

All development proposals (unless exempt) must achieve a minimum of 10% BNG (or any higher percentage mandated through local or national policy/legislation) over the pre-development site value as measured by the DEFRA Statutory Biodiversity Metric.

As work on the SWLP progresses we will explore evidence to seek a higher percentage of BNG above the statutory 10% requirement to achieve greater biodiversity benefits.

Proposals should:

  • Be supported by core biodiversity gain information;
  • Be secured for at least a 30 year period from the substantive completion of the development;
  • Be delivered in accordance with the approved habitat management and monitoring plan;
  • Follow the mitigation hierarchy to avoid, minimise, mitigate, compensate/offset loss;
  • Aim to achieve the required net gain on-site within the development boundary.

Where a proposal adequately demonstrates in the biodiversity gain plan that the mitigation hierarchy has been followed and the required net gain cannot be fully achieved on-site within the site boundary, it must secure alternative provision of the required biodiversity units through:

  • The purchase of registered offsite biodiversity units using the Local Nature Recovery Strategy as a guide and in line with the below locational hierarchy:
    1. Within the Local Planning Authority area where the impact occurs
    2. Within a neighbouring Local Planning Authority area
    3. Within Warwickshire, Coventry and Solihull
    4. Elsewhere in England

or as a last resort,

  • The purchase of statutory biodiversity credits from the government.

Do you agree with the approach laid out in Draft Policy Direction-38 - Biodiversity Net Gain? Comment

Justification

In England, BNG is a statutory requirement, introduced by Schedule 7A of the Town and Country Planning Act 1990 (inserted by the Environment Act 2021).

Local Planning Authorities can seek a higher percentage for BNG where there is justified local need and opportunity.

11.4 Environmental Net Gain

Environmental Net Gain (ENG) is an approach to development that leaves the environment in a measurably better state than prior to development. It looks holistically at all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience, etc. and addresses these in tandem to ensure an overall net gain in ecosystem services. The broader scope, compared to biodiversity net gain (BNG) alone, provides additional benefits for both the environment and people.

The policy will require development proposals to contribute positively to the natural environment by enhancing biodiversity and ecosystem services. Further work is required to develop a comprehensive ENG framework, but an initial focus on BNG and carbon sequestration will provide a solid foundation.

What was said in the I&O

Just over 60% of respondents supported an integrated ENG policy, rather than separate policies to achieve ENG.

A firm view that ENG has wider benefits than BNG alone as it includes other areas such as air quality and water quality, as well as biodiversity.

Draft Policy Direction –39- Environmental Net Gain

We will aim to have a policy that requires development to contribute positively to the natural environment by providing measurable net improvements in biodiversity and ecosystem services. The initial focus will be on BNG and carbon sequestration, but the policy will be updated to incorporate other ecosystem services as a comprehensive ENG framework is developed.

Do you agree with the approach laid out in Draft Policy Direction –39- Environmental Net Gain? Comment

Justification

This is an emerging area of policy with limited coverage in other Local Plans.

It is supported by NPPF paragraph 187 which seeks to protect and enhance the natural and local environment, as well as Biodiversity Net Gain regulations (introduced by Schedule 7A of the Town and Country Planning Act 1990). It is also supported by Warwick District Council's Biodiversity Action Programme.

Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan.

11.5 Green and Blue Infrastructure

"Green and blue infrastructure" (GBI) refers to the network of multi-functional green spaces and water systems that exist in an area. GBI provides multiple benefits, including providing habitats for wildlife, enhancing health and wellbeing outcomes in an area by providing space for recreation, and building resilience to a changing climate including flood control and preventing urban heat islands.

Development can impact GBI in several ways. Firstly, the delivery of new development, and the subsequent increased number of residents in an area, can exacerbate pressures on existing areas of green space. This can reduce tranquillity and availability of space, weakening its recreational value, and it can have negative impacts on on-site biodiversity due to increased levels of disturbance and disruption to habitat connectivity. Therefore, ensuring new development incorporates high quality GBI is a key consideration.

Examples of GBI which should be embedded in the design of development include street trees, multi-functional Sustainable Drainage Schemes (SuDs), areas of open green space for play, areas of green space for biodiversity, and the enhancement of waterways. Combined, they result in the "greening" of an area.

In 2023, the Government published its Green Infrastructure Framework[8]. This Framework sets out a series of 15 underlying principles which should be followed to ensure the maximum benefits of green and blue infrastructure are realised. These principles are shown in Figure 18:

Figure 18: Green Infrastructure Principles Wheel

A circular diagram setting out the 15 principles of Green Infrastructure (GI). The centre of the diagram is a blue circle containing the 5 benefit principles of GI. Around the blue circle are 5 green circles containing the 5 process principles of GI, and 5 orange circles containing the 5 descriptive principles of GI.

Source: Green Infrastructure Principles

When delivered in line with the above principles, the effectiveness of GBI is maximised. Given the role GBI plays in enhancing biodiversity and community health and wellbeing it is proposed that enhancing, creating, and connecting GBI will form a key theme in the new SWLP.

Draft Policy Direction-40 Green and Blue Infrastructure

New development will ensure that existing and new GBI is considered and integrated into the scheme design from the outset. The functionality, accessibility and quality of existing open space should be reviewed and increased wherever this is possible.

One mechanism to ensure that GBI is delivered in line with the above requirements as well as the Green Infrastructure Framework, is to produce a "Greening Factor" for an area.

A Greening Factor is a planning tool used to improve the provision of Green Infrastructure in an area. When applied to a development site, it provides a threshold for the total area of a site which is expected to be covered by an element of GBI.

It is proposed that the GBI policy in the SWLP provides a Greening Factor for development across the South Warwickshire region. The policy will provide direction in line with the below:

Different Greening Factors will be calculated for major residential development, minor residential development, and commercial development. This is to take account of the significant pressure major residential development places on existing GBI.

The delivery of a greening factor on a site must be based on a baseline assessment of existing GBI, demonstrating that high value assets have been retained and enhanced where appropriate. This must be supported by the submission of a long-term maintenance plan for major developments.

The following green interventions will count towards a development's Greening Factor. These include where green features are present on a site and are retained.

  • Trees and hedges, including canopy cover
  • Areas of open space, including Green Wedges
  • Green roofs and walls
  • Multi-functional SuDS
  • Community designated Local Green Space
  • The enhancement and/or creation of habitats
  • Allotments and food growing spaces
  • Carbon Sequestration

A Site's BNG contribution will also count towards the overall Greening Factor of a site.

Ecological enhancements will be expected to be delivered in line with the findings of the following evidence-based documents, and designations:

The SWLP will expect the above green interventions to be delivered in a manner which further enhances the effectiveness of their deployment. Furthermore, there are considerations for each of the above which go beyond their role in contributing to a Greening Factor. To ensure the SWLP acknowledges this, separate sub-policies will be produced for each. The next section details the direction these policies will take.

Do you agree with the approach laid out in Draft Policy Direction-40 Green and Blue Infrastructure? Comment

Justification

In 2023 Natural England published guidance on the delivery and enhancement of green infrastructure. As a key resource for developers and local planning authorities, the framework integrates green infrastructure tools, principles, standards and design guidance. It is structured through five key standards, addressing:

  • urban nature recovery;
  • an urban greening factor;
  • an urban tree canopy cover standard;
  • accessible greenspace standards; and
  • a green infrastructure strategy.

The NPPF sets out the requirement for plans to take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure.. At an area-wide scale, the Green Infrastructure Standard will see local authorities develop delivery plans to support the creation and enhancement of new and existing greenspaces.

11.6 Carbon Sinks and Sequestration

Carbon sequestration is the capture, removal and long-term storage of carbon dioxide from the atmosphere and is recognised as a key component in mitigating (or if at sufficient scale, potentially reversing) climate change. Carbon dioxide is naturally captured from the atmosphere through biological, chemical and physical processes and is stored in vegetation, soils and oceans. These are often referred to as carbon sinks. The way in which we manage these carbon sinks can have a significant impact on carbon sequestration.

Carbon sequestration can be accelerated or decelerated through changes in land use. For example, land currently used for non-crop purposes (such as trees or grasslands) which is lost to other uses (such as development or intensive agriculture) can reduce or even stop carbon sequestration from happening on that land. Likewise, land which has no material carbon sequestration currently occurring can be converted, via alternative land use, to one which commences carbon sequestration.

This policy seeks to protect and enhance land which has a positive carbon sequestration role and create additional land fulfilling that function.

What was said in the I&O

The Issues and Options consultation didn't include specific questions about carbon sinks and sequestration.

Draft Policy Direction-41 - Carbon Sinks and Sequestration

  • Development will be expected to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. This will be based on the data shown in the map below. The threshold has not yet been set due to the need for further evidence including further Green Infrastructure evidence.
  • Where damage or loss is unavoidable then suitable mitigation must be sought through delivery of the Greening Factor as set out in the Green and Blue Infrastructure Policy.
  • We will explore the possibility of policies which require a net gain in carbon sequestration.

Figure 19: South Warwickshire Carbon Sequestration Baseline (from the 'Assessment of Carbon Sequestration and Habitat baseline and opportunities' report).

Map of the South Warwickshire area on an accurate base map showing baseline carbon sequestration results using a heat-map style symbology (going from light green/yellow to dark red). The darker areas on the map represent areas that are currently sequestering high volumes of carbon each year under baseline conditions. Locations identified in red as having high baseline sequestration rates are Bascote Heath, south of Ufton, east and north of Lighthorne Heath, several areas south of Wellesbourne, north of Long Compton, south of Great Wolford, east of Alcester, near Wootton Wawen, west of Hockley Heath south of Meer End and near Ashow. The baseline map indicates that large areas of SWLP are either not sequestering any carbon or actually emitting carbon each year (light green).

Do you agree with the approach laid out in Draft Policy Direction-41 - Carbon Sinks and Sequestration? Comment

Justification

Carbon sequestration provides clear benefits in building climate resilience and having synergy with other plan objectives.

The 2024 technical evidence 'Assessment of Carbon Sequestration and Habitat baseline opportunities' provides baseline mapping to identify existing carbon sinks and areas with the potential for carbon sequestration opportunities (as per Figure 19). It recommends establishing a presumption against the loss of Climate Change Resilience Assets (defined as existing features within the environment that contribute to climate change mitigation and adaptation), and for Nature-based Solutions to be provided to mitigate any loss.

Figure 20: South Warwickshire Carbon Sequestration Opportunities (Carbon Prioritised)

Map of the South Warwickshire area on an accurate base map showing the potential net increase in carbon sequestration (tonnes per grid square per year) as a result of implementing the most suitable identified Nature-based Solutions (NbS). The map uses coloured pixels to show the carbon sequestration opportunities in tonnes for the SWLP, with the majority of the map coloured in orange pixels meaning that Nature-based Solutions would generally provide less than 5 tonnes of carbon sequestration each year. There are small number of red pixels (approx. 400) which are identified as sequestering no carbon. There are an even smaller number (approx. 50) of green pixels where Nature-based Solutions would result in a net increase in carbon sequestration of more than 5 tonnes per grid square per year.

The role of planning in supporting the development of land for carbon sequestration is limited, however planning policies do exist for protecting nature sites, which almost without exception will function as carbon sinks, and further policies exist to require new development to provide new open space, green and blue infrastructure and biodiversity net gain. In the absence of this policy there would be no requirement for the carbon sink function of land to be specifically considered in development decisions. Promotion of nature-based solutions, where natural systems are protected, restored and managed can assist with the protection of carbon sinks while at the same time provide benefits for biodiversity and health and wellbeing.

11.7 Trees, Hedges, and Woodland

Trees, hedges and woodlands provide valuable habitats for wildlife and contribute to the character of the wider landscape and the overall amenity by contributing to high quality designed desirable locations to live and work. They provide an important role in sequestering and storing carbon dioxide and the right trees in the right places also provide wide ranging resilience to climate change by soaking up excess rainwater, filtering air pollution, reducing noise pollution and cooling the urban environment during periods of excess heat. They also contribute towards improving our health and well-being. Trees on private open space, such as those located within residential gardens can also contribute to the quality of the public realm. Trees therefore play a critical role in our efforts to mitigate the impacts of climate change, while also enhancing the amenity and character of an area.

This policy will promote the retention of existing trees, woodlands and hedgerows in the first instance as these take many decades to mature and realise their full benefits. It will also require the enhancement of sites with new tree planting as part of all development proposals. The policy also intends to reduce neighbourhood disparities by increasing tree canopy cover and nurturing a healthy, diverse and climate resilient local tree population.

What was said in the I&O:

There was not a specific question asked in relation to trees, woodlands or hedges in the Issues and Options consultation document. However, there was a general feeling from respondents that they wanted to see more 'greening' and climate adaptation.

In question S1 regarding Green and Blue Corridors, people commented that trees should be protected, and this was re-iterated in responses to question S10 about the overall Distribution Strategy. In question D4.2 regarding Safe and Attractive Streets, people commented that trees contributed towards providing attractive streets and that existing trees should not be harmed by development.

Draft Policy Direction-42-Trees, Hedges and Woodland

SDC and WDC will resist the loss of trees of value based on amenity, historic or ecological value, apart from where;

  • the tree is dead, dying or dangerous; or
  • the tree is demonstrated as causing significant damage to adjacent structures or felling is for reasons of good Arboriculture practice.
  • There will be a presumption in favour of the retention and enhancement of existing trees, woodland and hedgerow cover on-site. Trees that fulfil the below criteria must be retained on site, unless there is a sound arboricultural reason not to:
    • Tree Preservation Orders
    • Trees in a conservation area
    • Ancient Woodland
    • Ancient and Veteran trees
    • Protected hedgerows
    • Traditional Orchards
  • Development will be expected to increase tree canopy cover, this will be supported by a tree canopy assessment in line with guidance that is to be developed.
  • Tree planting will be in line with:

Do you agree with the approach laid out in Draft Policy Direction-42-Trees, Hedges and Woodland? Comment

Justification

Local Authorities have a statutory duty to consider the protection and planting of trees when granting planning permission for proposed development, as set out section 197 of the Town and Country Planning Act 1990, and paragraphs 136, 187, and 193 of the NPPF.

11.8 Parks, Gardens, Food Growing, Open Space and Local Green Space

People need to have access to high quality open space in order to increase both physical and mental wellbeing and to reduce health and social inequalities. Open spaces comprise of many different forms and may include parks and gardens, outdoor sports provision and allotments and orchards besides many other examples.

The benefits of open space include:

  • providing recreational value
  • providing wildlife habitats
  • minimising noise, heat islands and air pollution
  • facilitating sustainable travel through the provision of safe cycle routes
  • contributing towards food production, for example through allotments

The section sets out the approach to protecting and enhancing valuable assets for community use, and addresses:

  1. Local Green Spaces
  2. Registered Parks and Gardens
  3. Open Spaces
  4. Urban Parks and Play Areas
  5. Allotments, Orchards and Community Gardens.
  6. Outdoor Sport and Leisure

What was said in the I&O

At the issues and options stage Public Open Space for Leisure and informal recreation was considered a topic suitable for Part 2 of the Local Plan. However, comments indicated a support for preserving these features and ensuring that development sites had sufficient green space within them. The comments related to health and well-being, climate change/climate adaptation, green infrastructure and biodiversity enhancements that green spaces could provide. As such, work has progressed to include policy directions covering green spaces within Part 1 of the local plan.

As this policy direction covers various aspects the policy direction has been subdivided to provide policy direction for each elements including the following and the numbers on the front correspond to the policy direction number given to each element of the policy direction

43 a- Local Green Spaces

43-b- Registered Parks and Gardens

43-c- Open Spaces

43-d- Urban Parks and Play Areas

43-e- Allotments, Orchards and Community Gardens.

Local Green Space

Local Green Spaces are designated spaces that are important to the community, and which are to be retained and afforded the same level of protection as Green Belt when considering development. Local Green spaces have to meet certain criteria as outlined in Planning Practice Guidance.

Draft Policy Direction 43a- Local Green Space

  • LGS currently within adopted Neighbourhood Plans will be rolled over into the SWLP plans.
  • New Local Green Space designations will be supported, and these will be updated and shown on policies maps.
    • Existing Local Green Space proposals, including RURAL.4 of the Stratford-upon-Avon Site Allocations Plan will continue to be progressed, informed by consideration of any reasonable alternatives.

Do you agree with the approach laid out in Draft Policy Direction 43a- Local Green Space? Comment

Registered Parks and Gardens

Registered Parks and Gardens are a designated Heritage Asset and are valuable assets to South Warwickshire.

Draft Policy Direction-43b- Registered Parks and Gardens

  • The policy will protect and where possible enhance registered parks and gardens.
  • Support efforts to reinstate landscape or built features which contribute positively to the historic interest of the park or garden.
  • where extensions are proposed to properties backing on to registered communal grounds, they must preserve the significance of views into, from and across the garden, including any impacts from pollution, as listed in the above Pollution Policy.

Do you agree with the approach laid out in Draft Policy Direction-43b- Registered Parks and Gardens? Comment

Open Spaces

Open spaces are defined in the NPPF as 'all open space of public value, including not just land, but also areas of water (such as rivers, canals, lakes and reservoirs) which offer important opportunities for sport and recreation and can act as a visual amenity.' They are an important asset that should be protected.

Draft Policy Direction 43c- Open Spaces

  • Development involving the loss of open space will not be permitted unless significant public benefits outweigh the loss.
  • The Councils will seek to enhance and improve open space and to provide new areas of open space where there is a deficiency in quantity, quality or accessibility.
  • New development will be required to ensure adequate provision of open spaces in line with future guidance.
  • It is expected that open spaces will be provided in the first instance onsite and only when it can be demonstrated that this is not achievable physically to deliver, then an off-site contribution will be sought to enhance or provide new open space, within 400m of the development. Technical evidence will be obtained to determine thresholds for open space provision.
  • We will seek opportunities to improve access and accessibility to open spaces for all users.

Do you agree with the approach laid out in Draft Policy Direction 43c- Open Spaces? Comment

Urban Parks and Play Areas

There is a defined hierarchy of parks, Premier Parks, Area Parks, Neighbourhood Parks, Country Parks as outlined. These parks provide a sense of place for the local community and provide landscape quality to urban and rural areas, as well as encouraging healthy lifestyles and enhancing social interaction and community cohesion.

Provision for children and young people has focused on fixed play provision in the form of equipped play areas and other specialist provision such as multi-use games areas and wheeled play provision or skate parks. Current research suggests that there are benefits in encouraging play in wider settings, and within the public realm.

Draft Policy Direction 43d-Urban Parks and Play Areas

  • Developments will be required to ensure adequate play provision is provided in line with future guidance.
  • It is expected that play spaces will be provided in the first instance onsite or in the immediate vicinity and only when it can be demonstrated that this is not achievable physically to deliver, then an off-site contribution will be sought.
  • Develop better and more local and inclusive play spaces for all users
  • Create a more child friendly public realm by encouraging the provision of play spaces in wider urban settings.
  • Multi Use Games Areas (MUGA) will be requested as part of Major development sites and the aspiration is that every resident will have a MUGA available to them within 15 minute's walk. This will help foster community cohesion and help with active lifestyles. Should there be insufficient space to provide a MUGA onsite or other demonstrable reason why this cannot be provided, then an off-site sum will be requested to enable the creation or enhancement of existing facilities. Design guidance for MUGA's will be outlined in future guidance.

Do you agree with the approach laid out in Draft Policy Direction 43d-Urban Parks and Play Areas? Comment

Allotments, Orchards and Community Gardens.

Allotments, orchards, community gardens and growing spaces play an important role in enabling small scale local food production. Additional benefits include supporting community cohesion, providing educational and biodiversity benefits, and improving general wellbeing, reducing health inequalities and food justice.

The provision of allotments is a statutory function for local authorities under a number of acts including the 1950 Allotment Act. There has been a growing interest in the development and establishment of community gardens which are similar to the more traditional allotment provision but offer an alternative that is less formal and potentially easier to integrate within urban environments.

Policy Direction 43e Allotments, Orchards and Community Gardens.

  • Developments should seek to provide space for food growing. Technical Evidence will be obtained to inform and provide guidance.
  • Food production spaces should be provided onsite in the first instance and only where it is robustly demonstrated that it is not feasible or practical to provide this onsite will an off-site commuted sum to enhance or provide new facilities be considered.
  • Consideration should be given in orchards to the species selected which should be a mix of local species and also climate resilient species in line with future guidance. A management and maintenance plan will also be needed.
  • To ensure that these developments contribute towards biodiversity at the design stage as well as at the use stage i.e. ponds, natural hedging and the inclusion where possible of bee hives

Do you agree with the approach laid out in Policy Direction 43e Allotments, Orchards and Community Gardens? Comment

Justification

The NPPF states in para 96 that Planning policies and decisions should aim to achieve healthy, inclusive and safe places and beautiful buildings which: c) enable and support healthy lives, through both promoting good health and preventing ill-health,, especially where this would address identified local health and well-being needs and reduce health inequalities between the most and the least deprived communities – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling. Providing open spaces in their various guises is an important way in which to achieve this.

11.9 Outdoor Sports and Leisure

Facilities that provide opportunities for leisure, sport and community are vital for physical and mental health. The Playing Pitch Strategy currently being prepared will be a vital piece of evidence to provide guidance on the provision of outdoor sports pitches.

The protection and enhancement of sports and leisure facilities that play a role in physical and mental well-being.

Draft Policy Direction-44- Outdoor Sports and Leisure

  • The redevelopment of existing community, sport and leisure uses and land formerly used as such to other uses will only be supported where it can be demonstrated that: there is no need or demand for such uses on the site and adequate alternative provision is available to meet the needs of the area; equivalent or better replacement facilities are secured on or off site that are equally accessible to the community or the development is for an alternative sport or leisure facility or use the benefits of which clearly outweigh the loss of the current or former use.
  • Where strategic residential development is proposed the provision of new facilities will be sought. The needs for sports and leisure will be assessed on a case-by-case basis depending on the type of development, the location of the site in relation to existing facilities and the capacity of existing facilities. Evidence of this will be available within the Playing Pitch Strategy, and an outdoor and .
  • Proposals for the extension or redevelopment of existing community, sport or leisure facilities to expand and/or diversify the existing use will be supported.
  • Outdoor sports and leisure provision will be easily accessible for all users.

Do you agree with the approach laid out in Draft Policy Direction-44- Outdoor Sports and Leisure? Comment

Justification

Providing open spaces is an important objective of the NPPF, and is a key aspect to providing sustainable development, particularly with regards to the social objective of sustainable development. People need to have 'access to a network of high quality open spaces' which 'reflect current and future needs and support communities health, social and cultural wellbeing'. The NPPF makes clear under Paragraph 135 that developments should 'optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space)'.

11.10 Areas of Restraint

Areas of Restraint are currently a Stratford only designation that seek to protect sensitive areas within a settlement that make an important contribution to the character of that settlement.

What was said in the I&O

The issues and options consultation asked whether we should remove Areas of Restraint across South Warwickshire, whether we should maintain them and introduce Areas of Restraint across all of South Warwickshire, or whether we should keep them within Stratford District and not introduce within Warwick. There was support for maintaining Areas of Restraint, and identifying areas within Warwick District.

Some developers felt that the areas could be captured in landscape and historic policies.

Draft Policy Direction-45- Areas of Restraint

  • Areas of Restraint will be utilised across the two districts, with Stratford designations being reviewed, and new designations being identified within Warwick where appropriate.
  • Areas of Restraint will seek to protect areas that make an important contribution to the character of the settlement.
  • The policy will seek to ensure that development does not harm the open nature of these identified areas, unless the scheme has demonstrable community benefits and contributes significantly the Local Plan's core objectives.
  • Projects which enhance the character and visual amenity of Areas of Restraint will be encouraged, as will the promotion of beneficial uses such as public access, nature conservation and food production.

Do you agree with the approach laid out in Draft Policy Direction-45- Areas of Restraint? Comment

Justification

Many of the settlements within South Warwickshire benefit from the open areas in and around them, these open areas help contribute to the sense of character that people value and the settlement is known for. Whilst open countryside is protected from most forms of development, this may not always be sufficient to protect areas of sensitive land such as river valley corridors on the fringes of a settlement which can be under particular pressure for development and intensified use.

Areas of Restraint would not be considered as local landscape designations in that they would not relate primarily to the quality of the landscape itself. They would apply to relatively small areas within or adjacent to settlements and their overriding purpose would be to protect the inherently open nature of a particular area because of the valuable contribution it makes to the character and physical form of the settlement. This could include significant areas of open space within the urban area or a physical feature which is important in establishing its setting.

It is not intended to restrict all forms of development within Areas of Restraint. It is proposed that there would be a range of activity supported within them, mainly of an agricultural or recreational nature. On this basis, various forms of development may be appropriate, including limited extension or alteration to existing buildings, buildings related to existing or proposed outdoor sport and recreation facilities, cemeteries, allotments, farm diversification schemes and small-scale additions to existing groups of farm buildings.

A study to review and identify Areas of Restraint across South Warwickshire would be undertaken to help inform the designations.

11.11 Protecting the Cotswold National Landscape

The Cotswold National Landscape (formerly referred to as the Cotswold Area of Outstanding Natural Beauty (AONB) falls within the southern edges of Stratford-on-Avon District and covers approximately 104km of the local plan area. The designation is not relevant to Warwick District. The National Landscape already affords significant protection through national policy and exists to protect the area's special qualities, including its landscape and scenic beauty. It is important that any policy seeks to conserve and enhance National Landscape and its unique properties.

What was said in the I&O

The question was asked in the I&O as to whether to create a buffer around the Cotswold AONB. 59.5% of respondents selected the option that sought to implement a buffer, and 40.5% felt that the current approach should be maintained. It is perhaps worth noting that the difference was only 14 respondents. However, the Cotswold National Landscape Board were in favour of implementing a buffer.

Draft Policy Direction-46- Protecting the Cotswold National Landscape

  • The Cotswold AONB/National Landscape Policy will remain largely the same, however a buffer zone will be introduced to help ensure that we are pro-actively responding to the duty to 'seek to further' the purpose of conserving and enhancing the natural beauty of the area.
  • The Buffer Zone will assist development management officers, and those wishing to develop within the setting of the National Landscape.
  • The buffer zone will not be an extension to the National landscape Designation.

Do you agree with the approach laid out in Draft Policy Direction-46- Protecting the Cotswold National Landscape? Comment

Justification

Section 85 of the Countryside and Rights of Way Act (2000) was amended by the 2023 Levelling-up and Regeneration Act (2023). This amendment amended the duty wording from to 'have regard' to, 'seek to further' the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty. This alteration is seen as a change from passive regard to pro-active regard, and as such an amendment to how the national landscape is considered is seen as appropriate.

Creating a buffer zone of approximately 3km around the National Landscape, as suggested by the National Landscape Board, will provide greater clarity to development management officers and reduce ambiguity when they are considering planning applications within the setting of the National Landscape. The purpose of the buffer is to ensure that developments which may impact the National Landscape and it's setting are assessed appropriately, and consistently, with the Cotswold National Landscape Board being consulted on certain development proposals if they fall within the buffer zone. The buffer is not an extension of the National Landscape, and instead will be a tool to ensure consistency of approach and to ensure great weight is given to the impacts of development within the setting of the National Landscape. The creation of a buffer would not prevent Development Management officers consulting the Cotswold National Landscape Board on sites outside this buffer, should they feel that they would have an impact on the National Landscape and its setting, such as in the instances of large urban extensions, new settlements or large scale wind turbines.

11.12 Special Landscape Areas

Special Landscape Areas (SLA) are another Stratford-upon-Avon designation. Special Landscape Areas are areas of high quality landscape that also contain associated historic and cultural features. The existing SLA Policy seeks to protect, enhance and facilitate better management of the best of the area's landscapes outside the Cotswolds National Landscape. The policy does this by resisting development proposals that would have a harmful effect on the distinctive character and appearance of the relevant SLA.

What was said in the I&O

The issues and options consultation asked whether Special Landscape areas should remain as a Stratford designation only, whether they should be removed as a designation entirely, or whether they should be introduced in Warwick District.

54% of respondents believed we should introduce the designation in Warwick so that there are Special Landscape Areas across the whole of South Warwickshire. 30.7% of respondents felt that we should discard special landscape areas, and 15.3% felt we should maintain the current approach of using SLA's in Stratford but not in Warwick. Therefore, there was a clear indication that Special landscape Areas should be utilised across the whole of South Warwickshire.

Draft Policy Direction 47- Special Landscape Areas

South Warwickshire contains some very special landscape areas, and in order to ensure these are suitably protected and their character maintained Special Landscape Areas will be designated across both Stratford on Avon and Warwick.

The SLA designation will not restrict development, but instead ensure that development in these areas does not have a harmful impact on the areas' distinctive character and appearance.

Do you agree with the approach laid out in Draft Policy Direction 47- Special Landscape Areas? Comment

Justification

The NPPF does not mention Special Landscape Areas specifically, however it does contain a number of policies that address how Landscape/Character matters are to be considered and it makes clear that landscape and character need to be suitably considered.

The rural nature of South Warwickshire means there are areas of particularly high landscape quality. To ensure this is maintained, Special Landscape Areas can be used to ensure their distinctive character and appearance is not harmed by development.

The purpose of the Special Landscape Area designation is to protect, enhance and facilitate better management of the best of the area's landscapes outside the Cotswolds National Landscape. Special Landscape Areas are a way to ensure developments are protecting and enhancing valued landscapes, and that any developments are sympathetic to the landscape setting.

SLAs have to be, by definition, 'special' at a district level to merit inclusion. All landscapes are important, especially to their local residents. However, to define an entire district as 'special' would potentially undermine the purpose of designating specific areas for their landscape quality. Designation has to be driven by the key qualities of a particular area of landscape. On that basis, any SLAs identified will represent particularly high quality countryside in the context of the Local Plan area, based on their landscape and scenic quality, as well as natural and historic features. A study will need to be undertaken that identifies particularly high quality areas that are considered suitable for designation as a Special Landscape Area.

11.13 Protecting and Enhancing Landscape Character

Landscape character contributes to the sense of place across South Warwickshire, and it is important that the landscape is protected and enhanced as much as possible. At a National Level landscape has been divided by Natural England in their National Character Area Profiles. Within Stratford and Warwick, the landscape areas consist of Dunsmore and Feldon (96), Arden (97), Cotswolds (107) and the Severn and Avon Vales (106). These areas "contain distinct, recognisable and consistent pattern of elements in the landscape that makes one landscape different from another, rather than better or worse" (Natural England). These areas have been assessed at a finer grain in the Warwickshire Landscape Guidelines, which contain the Landscape Character Assessments (LCA's).

Given the sensitivity of the landscape within Stratford and Warwick, landscape has been further broken down into Landscape Description Units (LDUs). These represent the landscape type in a specific location, for example soil, tree cover character, geology, topography, land use and settlement pattern, and are the 'building blocks' of the LCAs. Within these LDU's nest Land Cover Parcels (LCPs), and these are the finest grain units of landscaping, describing any local variation that is present and visually apparent within the LDUs, such as patterns of field enclosures. Combined, this Landscape Evidence is key to help inform planning decisions and ensure that policies can be effectively implemented At present the Landscape Evidence pertaining to Landscape Description Units and Land Cover Parcels dates to the previous local plans, and therefore it is acknowledged that this information needs updating.

What was said in the I&O

Within the Issues and Options landscape was considered throughout the document as part of numerous other topic areas and landscape character was considered a matter for Pt.2 of the local plan. However, as work has progressed it has been possible to incorporate a draft policy direction at this earlier stage of the plan making process.

Draft Policy Direction-48- Protecting and Enhancing Landscape Character

Development will avoid detrimental effects on the landscape setting and on features which make a significant contribution to the character and setting of an asset, settlement or area. Where a proposal would result in landscape harm, the general principle is that it should be refused unless there would be an over-riding benefit of the development for instance to meet an evidenced local housing need. Developments will require high quality landscaping schemes that positively contribute towards enhancing the character and amenity of the landscape and seek to incorporate measures to minimise and mitigate the effect of development upon the landscape, while also seeking to minimise the cumulative effect of development to prevent coalescence. These schemes will consider the landscape context, local distinctiveness and historic character and landscape, including tranquillity.

  • Developments will take into account the local topography and built form, as well as key local views and vistas and seek to avoid creating hard developed edges to the open countryside.
  • We will explore the need for major developments applications to require a full Landscape Visual Impact Assessment.
  • We will explore the possibility of requiring long-term management and maintenance (minimum of five years) of new landscape proposals to ensure their establishment. Evidence will be gathered to inform this approach.

Do you agree with the approach laid out in Draft Policy Direction-48- Protecting and Enhancing Landscape Character? Comment

Justification

The NPPF states in paragraph 135 that planning policies and decisions should ensure that developments are visually attractive as a result of good architecture, layout and appropriate and effective landscaping and are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities). Within Para. 187, the NPPF highlights that planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan). Conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas.

11.14 Agricultural Land

The best and most versatile agricultural land should be protected from development. This is increasingly important in the view of producing more food locally to reduce overall greenhouse gas emissions and reduce reliance on other countries for imported food items that can be grown locally. Lower grade agricultural land may be used to cultivate non-food crops such as biomass.

The policy should aim to protect the best and versatile agricultural land and only allow development if the benefits of the developments outweigh the protection provided to the land.

What was said in the I&O

Issue B8- Agricultural land was included to get views on this issue. A question was asked as to whether to include a policy safeguarding the best and versatile land agricultural land, unless it can be demonstrated that the harm to the agricultural land outweighs the benefits of the development to the area.

90% respondents were in favour of including a policy that would safeguard the best and most versatile agricultural land.

Draft Policy Direction-49- Agricultural Land

  • Development outside the identified growth strategy sites/ settlements will be required to protect best and most versatile agricultural land.
  • Any development that is put forward in the best and most versatile agricultural land will need to demonstrate that the benefits of the development outweigh the harm.
  • The large-scale renewable energy developments will be prioritised on the poor-quality agricultural land (Grades 3b, 4 and 5).

Do you agree with the approach laid out in Draft Policy Direction-49- Agricultural Land? Comment

Justification

NPPF (2024) Paragraph 187 (b) states that "Planning policies and decisions should contribute to and enhance the natural and local environment by: recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland".

Paragraph 187 and footnote 65 of the NPPF also provide some guidance on agricultural land.

A Green Future: Our 25 Year Plan to Improve the Environment sets out the Government's 25-year plan to improve the health of the environment by using natural resources more sustainably and efficiently. One of those measures include providing protection to best and most versatile agricultural land.

Defra's guidance on soils also provides reference to agricultural land.

Do you broadly support the proposals in the A Biodiverse and Environmentally Resilient South Warwickshire chapter? If you have any additional points to raise with regards to this chapter please include them here. Comment


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