Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability
Q-I2: Option I2a: Set out infrastructure requirements for all scales, types and location of development This is the approach we would favour. Integral to this would be consideration of the potential to accommodate growth where spare infrastructure capacity currently exists. Dispersed infrastructure is generally more deliverable and flexibleand in many circumstances can be provided more easily and quicker. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy We would not support this option. This option which appears to favour large-scale development and large-scale infrastructure schemes to support them. A far more considered and balanced approach is required. Q-I3: Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan We would not support this option. Option I3b: Each District Council to produce its own Levy A joint approach would seem to be more logical and supportive of the preparation of the local plan on a joint basis.
ISSUE I2: INFRASTRUCTURE REQUIREMENTS AND DELIVERY We would comment that focusing new infrastructure on existing transport routes such as the M42 and particularly Junction 3 would be the best use of scarce resources. In addition, the positive linking of new employment in and around locations such as Junction 3 of the M42 is very important. We have included a new site in the Call for Sites on the south-east side of Junction 3 of the M42 east of the A435 which we believe is an excellent location for the provision of distribution facilities and a logistics park which could provide much needed employment in this area and the provision of the sustainable requirement for electrical lorry and van charging. Q – I2: Please select the option which is most appropriate for South Warwickshire In the list of options there should be a much stronger Economic focus on the sustainable benefits of providing new employment as set out in our reply above. ISSUE 5: VIABILITY AND DELIVERABILITY Q – I5: Please add any comments you wish to make about infrastructure, viability and deliverability This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assessed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.
Q-I2: Please select the option which is most appropriate for South Warwickshire The JPC strongly supports option 12b.However without a significant change to the approach to funding infrastructure none of the options will be adequate. The JPC has carried out as much public consultation as practicable in the very limited time available. The local community in Henley and Beaudesert has expressed extreme concern about the inadequate infrastructure of the town. The community will oppose any growth option unless there is a realistic infrastructure investment plan. The document correctly identifies that provision of the appropriate new infrastructure must underpin this plan in particular identifying the importance of effective communications, especially transport. The provision of adequate utility and Internet services is also deemed essential, as are the public services of health, education and welfare. There is nowhere in the document that outlines the way improvements in all of these things are to be undertaken. There is also no reference to obtaining funding commitments from statutory providers and the key private-sector agencies involved in public infrastructure/services guaranteeing the investment necessary. This is critical to areas like Henley in Arden/Beaudesert and the surrounding villages, which feature heavily in the growth priorities. It is incumbent on SWLP to make a statement as to how these facilities will be provided well in advance of site allocation and development commencing. It is disingenuous to maintain that the private sector will be able to fill this gap entirely, yet this seems to be the assumption throughout the plan. QI-5. The JPC has received views from 2-300 residents in the short time available. The community have made it clear that the infrastructure of Henley Beaudesert is seriously inadequate. There is anger about the quality of the road, rail and bus situation which has been wrongly identified as strengths of the town. There are several other serious concerns relating particularly to antiquated drainage and sewage systems and flood hazards. Unless the chosen option presents concrete proposals to deal with these issues in the early years of the plan none of the growth options will be acceptable.
ISSUE I2: INFRASTRUCTURE REQUIREMENTS AND DELIVERY We would comment that focusing new infrastructure on existing transport routes such as the M42 and particularly Junction 3 would be the best use of scarce resources. In addition, the positive linking of new employment in and around locations such as Junction 3 of the M42 is very important. This is particularly so where there could be provision for motorway-related services such as budget hotels, fast food and with that the provision of electrical charging points which could cater for cars using both the M42 and the A435. We have included a new site in the Call for Sites on the north-east corner of Junction 3 of the M42 which could provide both employment and the sustainable requirement for electrical car charging. Q – I2: Please select the option which is most appropriate for South Warwickshire In the list of options there should be a much stronger Economic focus on the sustainable benefits of providing new employment as set out in our reply above. ISSUE 5: VIABILITY AND DELIVERABILITY Q – I5: Please add any comments you wish to make about infrastructure, viability and deliverability This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assessed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.
Chapter 1 - Introduction We note that the document has not benefited from transport specialist input and, therefore, has a number of shortcomings. It seems to make an assumption that the transportation issues can be left for later, are not difficult to solve, and will not identify any major issues that impact upon the deliverability of the plan. We believe it is the other way around - that identifying the transport links that are practicable and affordable is core to shaping large areas of the plan and should be addressed within it. Section 1.2 describes the relatively low population density and the good existing, but mainly long distance, transport links. South Warwickshire is perceived as rural, affluent, and with better transport links than many other parts of the country. In comparison with, for example, Coventry (urban and with areas of deprivation), East Lancashire (post-industrial decay), or North Yorkshire/South Lincolnshire (rural but with poor transport links), South Warwickshire may struggle to compete for Government (levelling-up) funding. Section 1.8 says that more technical assessments will be commissioned after the Issues and Options consultation has closed. These include a Green Belt Study and Landscape Character Assessment. However these two studies are critical to the allocation of sites process so they are needed as soon as possible.
Chapter 4 -Sustainable Development A number of growth options and new settlement locations are listed. However it is difficult to understand how any of these options can be assessed without having a Green Belt Study or Landscape Character Assessment available. When those studies are completed, they may say that some areas are totally unsuitable for new development. Q-I-2 We support Option I-2a: Set out infrastructure requirements for all scales, types and location of development. I4 – Infrastructure Safeguarding To tackle the climate emergency and create vibrant local communities, the focus must shift from large road projects to developing active travel options locally. Therefore there should be no infrastructure safeguarding for road projects, but there should be safeguarding of land for future strategic cycle routes, for example.
Issue I3: Community Infrastructure Levy (CIL) 12. Whatever approach is adopted with regards CIL, as the consultation acknowledges, there is will still be a role for Section 106 agreements to address site specific issues. The Plan will need to set this out. 13. There needs to be robust testing of the appropriate level of CIL and other policy requirements. It should be noted that on-site requirements can also impact on viability of a scheme by reducing the amount of land available for housing development. 14. The HBF notes that CIL can also reduce flexibility in negotiations and if contributions are only for small amounts spending CIL can also become problematic. Issue 14: Infrastructure Safeguarding 15. The HBF would support safeguarding for infrastructure if the purpose of the safeguarding is to improve certainty for developers on what infrastructure is required where and when. However, the safeguarding of land must not serve as a barrier to development and hold up delivery of much needed homes. This issue may need to be considered on a case-by-case basis and/or flexibility may be required. 16. The Infrastructure Delivery Plan will be an important part of the evidence base for the Local Plan and the HBF and its members would welcome the opportunity to comment on and feed into this document. Issue I5: Viability and Deliverability 17. As the PPG (ID: 10-001-20190509) says plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Viability assessments should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan (PPG10-002-20190509). It will be important that policy requirements, and combination(s) of different requirements, are robustly tested through the whole plan-viability testing. 18. As noted in PPG (ID: 10-003-20180724) assessing the viability of plans does not require individual testing of every site or assurance that individual sites are viable. In light of this there will remain a need for flexibility within policy to enable site specific viability considerations to be taken account where required.
Viability is a critical issue and should not be underestimated, especially for new settlement proposals where the infrastructure required is both significant in scale and cost. However, it is not just infrastructure costs which affect viability but the increasing cost of construction whether caused by inflationary pressure or regulations. There are also costs associated with, for example, providing on-site Biodiversity Next Gain, not just monetary but also reducing the extent of built development which affects the value of the overall site. Further, there may be additional cost burdens for all development associated with policies which will be included in the Local Plan or there is an unreasonable expectation about the proportion of affordable homes provided as part of allocated housing schemes. 13. In addition, there is an increasing desire at national and local level to push the infrastructure cost burden onto the landowner to mitigate all impacts and for a proposal to make an ever greater contribution, in whatever form, to the wider community. Alongside any Planning Obligations (assuming this regime remains in its current form), there is also the payment of the Community Infrastructure Levy. All these costs, combined with capital gains tax being paid on land transactions (which may well increase), is increasingly raising a question with landowners about whether it is worthwhile for their land to developed for much needed housing or employment rather than retain a long-term income for the current use? 14. For clarity, through this response Braemar recognises that a fair and reasonable contribution should be paid towards appropriate infrastructure, but the Councils equally need to recognise that there are increasingly significant cost burdens associated with the development of land, whether inside or outside the control of the Councils.
Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development This is the approach we would favour. Integral to this would be consideration of the potential to accommodate growth where spare infrastructure capacity currently exists. Dispersed infrastructure is generally more deliverable and flexible and in many circumstances can be provided more easily and quicker. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy We would not support this option. This option which appears to favour large-scale development and large-scale infrastructure schemes to support them. A far more considered and balanced approach is required. Q-I3: Please select the option which is most appropriate for South Warwickshire Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan We would not support this option. Option I3b: Each District Council to produce its own Levy A joint approach would seem to be more logical and supportive of the preparation of the local plan on a joint basis.
INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable.
Section 4 I2. The infrastructure of our 15th century market town is not compatible with the new houses proposed. Whilst we understand new housing needs to be built somewhere, central Henley is not the place. The plan doesn’t detail how it will support existing services. Our roads are in a poor state, often narrow with very minimal parking. The High Street and roads off the lights junction are already very busy. Sewage is an issue too. The high school is now at capacity and it is difficult to get a doctors appointment within 2 weeks now, let alone with more residents. Section 4 I5. The quality of the roads around Henley are awful. Full of potholes and uneven surfaces. Very limited parking in the town and residential roads. Having even more residential cars and building trucks would be unthinkable. The Council would be unable to create more parking as there just isn’t the land around the High Street. Roads are busy already particularly around the roads by the crossroads lights at rush hour. It is already difficult to pull out of Arden Road by the school due to high volumes of traffic queuing up the Warwick Road up the hill. If more homes were built here using this road, it would be gridlock and would create much more pollution.
We share residents concerns about the potential increase in demand on our local infrastructure. We have not seen the required development in active travel infrastructure, health services, bus and rail services which are needed to ensure that our town remains a pleasant place to live. Currently we do not believe that this is getting sufficient focus within the consultation to give us or residents confidence.
Q-I2: Please select the option which is most appropriate for South Warwickshire: A: Set out infrastructure requirements for all scales, types and location of development B: Focus on strategic infrastructure relating specifically to the growth strategy 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: A: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan B: Each District to produce its own Levy 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: The County Council favours Option 12a. We believe that this gives greater clarity over requirements at the earliest stage. It will support potential developers to understand the implications of growth within a specific area and help avoid conflict with infrastructure providers. Q-I3: The ability to charge differing rates across the individual District Council areas is already dealt with in the two existing separate CIL strategies. WCC considers that a single CIL would bring considerable benefits and as such would support such an approach. However, WCC also recognises some of the challenges of this approach and will seek to work with both Districts whatever the outcome. Currently the District Council’s CIL approaches differ and as a minimum we would suggest that the application and monitoring processes should align. This would require a clearly agreed timetable and a shared set of paperwork. As a key Infrastructure provider and an organisation who actively bids for CIL funding the key issue is consistency of approach for determining funding allocation, monitoring spend etc. We also feel that there must be a mechanism whereby funds can be made available across the Local Plan area to help support the delivery of key infrastructure required because of cumulative impact. Q-I5: Under Infrastructure Delivery (Chapter 4, 4.1, Issues I2) a list of 3 ways for infrastructure to support new development is provided along with supporting/explanatory text. No. 3 states ‘off-site through the provision of financial developer contributions to pay for the provision of infrastructure to be provided elsewhere – e.g. education, health facilities, biodiversity restoration’. We have concerns that this suggests that this is the only way that off-site infrastructure can be delivered. We believe that this point and the explanatory text should be amended to also make reference to the delivery of transport and highway improvements via a section 278 highway agreement. For many large off-site transport improvements, the delivery generally relies on either s106 contributions or s278 highway agreements or a combination. This is often because the infrastructure costs are too large to be borne by a single development parcel and would have implications for the viability of development. This means that infrastructure delivery is reliant on developers submitting planning applications for the allocated sites in a timely and coordinated manner, all of the s106 contributions need to be received (often from different development sites or phased parcels within those sites), or s278 applications made, in order for the infrastructure to be designed, technically approved and constructed on-site to dovetail with the identified development occupancy trigger(s). If infrastructure is to be delivered at the right time, then the infrastructure delivery mechanisms/processes need to reflect the overall programme for the delivery of the infrastructure and require the design work, which is often complex, to be carried out sufficiently early so that the on-site construction period dovetails with the build out/occupancy rates of development. Recommend that for this strategic objective and particularly for large scale infrastructure delivery, there should be a mechanism to plan and monitor the overall programme for delivery, including design and construction stages, and to identify risks. The further assessment as part of the Housing and Economic Land Availability Assessment (HELAA), Infrastructure Delivery Strategy and viability assessments will be important to determine the deliverability of infrastructure. However, there are many elements for transport and highways schemes that are unknowns until the detailed design stage and these can make a scheme undeliverable, e.g. costs associated with diversion/protection works for statutory undertakers’ equipment, requirement for structures, ground conditions etc., by which time development and even occupation has started. Either more information should be provided by land promoters as part of the viability assessment work during the Local Plan review, or robust contingencies should be incorporated into the assessments.
I am concerned that all significant projects exceed budgets and over-run time scales, and this is not allowed for in strategic planning; the result will be a hit for future local residents and their community charges.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: The Respondent considers Option I2a as being most appropriate to ensure a consistent approach across the plan area and avoid disconnect between the SWLP and current extant Local Plan policies. While the Respondent would not object to the utilisation of a combination of S106 Planning Obligations and Community Infrastructure Levy (CIL) as per the current system, any policy must reflect the provisions of the CIL Regulations 2010 (as amended) and particularly Regulation 122, which requires S106 obligations to be fairly and reasonable related in scale and kind to development. Q-I3: The Respondent considers that a single CIL for the whole of South Warwickshire is most appropriate since it will provide greater certainty to developers. While the Consultation Document indicates that separate levies could better respond to different conditions in different areas of South Warwickshire (i.e., the Stratford-on-Avon and Warwick Districts), in the Respondent’s view, this can equally be achieved through the implementation of different charging zones where these are justified. The Consultation Document confirms that an Infrastructure Delivery Strategy (IDS) will be prepared which will set out the key pieces of new infrastructure needed to deliver the Councils’ growth strategy and how such infrastructure will be delivered. The Respondent is supportive of this action and considers the preparation of an IDS to be an essential component of the evidence base. Q-I5: Completion of a robust and comprehensive Plan Viability Assessment will be essential to ensure that the SWLP is viable and deliverable in a timely manner. The Respondent considers that both an IDS and Viability Assessment should be prepared at an early stage and used to inform a preferred strategy. Any such documents should be made available for comment as part of the Preferred Options Public Consultation.
Q-I2: We do not agree with any of the potential options described above. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). For reasons already set out within this wider Representations Statement (2023), we also object to the Council’s proposed Local Plan-making approach of producing a Stage 1 and Stage 2 (Parts 1 and 2) of the SWLP. This will just add a significant time delay to Local Plan delivery across the South Warwickshire Region, at a time when the local economy is facing such considerable economic uncertainty. This does not bode well for the delivery of a certain and clear planning policy framework going forward across the South Warwickshire Region. Placing small-scale and mediums scale housing sites within a Stage 2 SWLP is also completely unacceptable, and this proposed planning policy approach is in direct conflict with paragraphs 60 and 69 of the Revised NPPF (2021). Paragraph 69 of the Revised NPPF places considerable importance on small and medium-sized housing sites and their important contribution towards meeting the housing requirement of an area, and the fact that these sites are often built-out relatively quickly to help meet the urgent housing needs. Q-I3: Page 31 of the SWLP consultation report (January 2023) states that: “…To support the infrastructure requirements set out within the Local Plan, an Infrastructure Delivery Strategy will be prepared which will set out the key pieces of new infrastructure and the climate resilience of infrastructure needed to deliver the Plan and how this will be delivered. It will be necessary to ensure that developer contributions do not undermine the deliverability of the Plan, to this end the Plan will be informed by robust delivery and viability studies to assess the impact of infrastructure requirements…” Lockley Homes response Lockley Homes maintains its view that there has been a huge, substantial, unprecedented and significant recent material change, and a huge and rapid shift in highly damaging adverse economic circumstances now facing the South Warwickshire Region and the wider United Kingdom, due to the presence of the ongoing global coronavirus pandemic (COVID-19), economic uncertainty caused by Russia’s Spring 2022 invasion of Ukraine, and the subsequent severe and unprecedented economic downturn. Which is anticipated to cause one of the worst economic recessions in the UK in living memory since records began. The severity of the forthcoming recession is now acknowledged by central Government (London), who accept that the COVID-19 pandemic has caused one of the worst economic recessions within the UK not seen for the last 300 years. This is highly significant, and should now result in an urgent re-shaping of affordable housing, Community Infrastructure Levy (CIL), planning obligations, and infrastructure policies within the Council’s emerging Local Plan Review. The Council’s preparing the emerging SWLP and its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) now need to begin to finally accept that their highly onerous planning policy position on these policy issues now needs to change to help support the highly fragile local economic recovery, and help support the house building development industry at a time when they are trying to bring forward sites under an incredibly challenging economic climate, which will affect the financial viability of many housing schemes. A highly onerous affordable housing and CIL/ planning obligations/ infrastructure demands approach therefore needs to be avoided within the emerging Local Plan Reviews referred to above. The worst global health pandemic event to affect the UK for the last 100 years, combined with the presence of one of the most severe economic recessions for the last 300 years, should now result in a more supportive Development Management and Planning Policy approach being taken (to support the interests of the private sector development industry and rural landowners) by the LPA within the emerging SAP and SWLP Reviews in relation to unreasonable and highly onerous affordable housing planning policy requirements, Community Infrastructure Levy (CIL) planning policy requirements, and other infrastructure demands/ planning policy requirements being placed on the house building development industry, the local business community and rural landowners looking to bring forward sustainably-located new housing development sites. In order to help support the future financial viability of new housing development schemes coming forward across the district at an incredibly challenging time, and to help support the fragile post Covid-19 local economic recovery across the South Warwickshire Region. This approach would be consistent with Government guidance reinforced within paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The evidence is perfectly clear, all of the above ‘pandemic-related’ factors appear to have been given an insufficient level of planning policy consideration and material planning weight whatsoever by the LPA’s when preparing the Council’s emerging Site Allocations Plan (SAP) and emerging South Warwickshire Local Plan (SWLP). We have concerns about this ongoing failure and continued incompetence being taken towards Local Plan preparation within the South Warwickshire Region. These critically important ‘pandemic-related factors’ described above therefore require critical consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams as part of their ongoing Plan-preparation work going forwards. To ensure that the Council’s planning policy approach is sufficiently robust, based on a platform of credible and fit-for-purpose evidence, and responds effectively to guidance in paragraphs 31, 35 (indents b and c) and 82 (indent d) of the Revised NPPF (2021). The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). The Council’s preparing the above referred to Local Plan Reviews cannot continue to load and place unreasonable planning policy demands and requirments onto the house building development industry for the reasons explained above. A heavily revised planning policy approach is therefore urgently needed to allow the Council’s Plan-making approach to respond effectively to the above NPPF guidance.
The developments over the last few years have made south Leamington a no go area at certain times of the day. It is obvious that the infrastructure has not been introduced to accommodate the developments resulting in congestion and pollution on a large scale. I do not see any plans to rectify this issue.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: Please select the option which is most appropriate for South Warwickshire: Option I2a: Set out infrastructure requirements for all scales, types, and location of development Option I2b: Focus on strategic infrastructure relating specifically to the growth strategy It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for utilise both approaches in respect of infrastructure to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: Option I3a: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan Option I3b: Each District to produce its own Levy It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Issue I5: Viability and Deliverability Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage. As intimated at NPPF para 58. Lone Star Land are in the process of collating a robust evidence base to demonstrate a sufficient level of confidence that land at Deppers Bridge within site F2 can come forward and deliver all that is required of them in terms of necessary infrastructure provision for a New Settlement. This includes the provision of a railway station on the existing Chiltern Line, a link road, diverting traffic around Bishops Itchington, an enhanced sustainable route to Southam and provide the necessary social, health and education infrastructure (in the form of new primary and secondary schools) within the site. It is acknowledged that the Council will be publishing an Infrastructure Delivery Strategy and associated viability assessments which will be undertaken as the Local Plan progresses to ensure that what is put forward as a preferred development strategy is both deliverable and viable. It is important that key stakeholders (such as Transportation and Health) are fully engaged in the production of that evidence base, with a clear indication of agreed costs to be borne by each of the major allocations, as part of delivering the wider IDP objectives.
SWLP Infrastructure Development inevitability brings transport problems to any area it is envisaged, where all new houses are considered to have a minimum of two cars & Commercial development many vehicles of various sizes travelling from outside the area. The M40 / A46 road structure was originally designed to by-pass Henley in Arden and Wooten Wawen. This has not proven to be the reality, the A3400 remains the preferred and shortest route from Birmingham to Stratford upon Avon. The High Street in Henley in Arden, which is a Conservation area, narrows to about 25 feet in several places creating a bottleneck which cannot be improved, the listed buildings at these points are less than a yard from the road. In addition the lights at Stratford Rd./ Warwick Rd. causes further delays to traffic. Further South on the A3400 the canal bridge at Wooten Wawen also provides a bottleneck preventing any widening of the A3400 to accommodate any additional traffic created by development, consequently before any consideration of development in the area of Henley in Arden and surrounding villages can be even contemplated the County Council will have to consider the road structure in this area. Traffic pollution and air quality is a particular problem in Henley in Arden, as a result of the current high level of traffic using the A3400 and A4189, especially when there is any disruption on the M40/M42 resulting in all the traffic passing through Henley in Arden. Any addition to the existing heavy traffic as a result of development would be unacceptable without measures being taken to either reduce the amount of traffic or provide a relief route. Any traffic coming North on the M40 to access residential or commercial areas, in Claverdon, Henley & the surrounding Villages, has to exit the M40 at Junction 15, and then pass through Claverdon on the A4189, then negotiate the lights at Henley. Similarly any traffic from North of Henley wishing to go South on the M40 has to do the same route in the reverse direction. There is both Heavy Haulage (RS Adams) & Johnson Coaches to the North of Henley at Liveridge Hill which currently has to negotiate these routes on a daily basis. The High Street in Henley in Arden is very restrictive & there is no way it can be improved. Whilst I appreciate major Road construction may not be the County Council responsibility it should highlight the need and insist on a Southern entrance and Northern exit off the M40 at junction 16 before it agrees to comply with the government requirement of additional housing and business development in the County. An A3400 relief road, to by-pass Henley in Arden and Wooten Wawen, from the top of Liveridge Hill on the A3400 traversing the river Alne, the Stratford canal, Warwick Rd. and entering the A3400 South of the canal bridge at Wooten Wawen should be investigated before any consideration for further development in these areas is contemplated. I appreciate an A3400 relief road to be highly contentious, and even if it was constructed, it would only move the bottleneck to Stratford upon Avon where an Eastern relief road is desperately needed to overcome the problems at the bridge over the River Avon in order to access the proposed developments South of Stratford. The problems of the road structure, in and around Henley in Arden, prohibits any development of any type which will substantially increase the numbers of vehicles in the area using the A3400, the High Street in Henley in Arden and the A4189, Warwick to Redditch Rd. The SWLP infrastructure plans however does not appear to take any current road problems into consideration. The County Council & Stratford DC need to take responsibility to identify the existing road problems, before they agree to undertake any expansion of the Housing & Commercial stock in Warwickshire. In addition Stratford CC needs to investigate the archaic sewage system in the Conservation area of Henley in Arden, Beaudesert & Wooten Wawen before any further development is allowed. Having seen the facility I am sure it cannot take the addition of further developments without up-grading which again will be extremely disruptive to the A3400 if undertaken. The Infrastructure & utility services must be the main priority of both Warwick CC & Stratford DC Planning before any expansion of Housing or Commercial development is considered. It cannot be left to the Private Developers who will only do the minimum. Get the basic infrastructure right before any building begins.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
For the local plan we need affordable Housing . And more food shops at the bottom end of Town . We only have Iceland and Cos Scutere that youst be the CO-OP . There aren't any shops on Clemens St lIKE THERE YOUST BE .
Having viewed the Local Plan I have the following concerns on the issue of climate resilience and net zero. The use of fossil fuelled vehicles needs to be reduced. With the developments proposed it seems doubtful this will happen. The opposite is more likely. The vast majority of new residents will almost certainly use cars/vans for all their transport needs. Due to the expensive nature and poor provision of a charging network switching to electric vehicles in any significant numbers just won’t happen. The plan needs to show how a much improved public transport system can tackle this issue. The following statement doesn’t do this. At this stage in the plan-making process, no detailed feasibility work has been undertaken around the capacity of existing bus and rail infrastructure or the potential for enhanced or new services. There may be locations identified in these growth options where bus or rail improvements are found not to be feasible, or where the existing capacity could support only limited growth. Further work will be undertaken as the growth options are further refined.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
Q-I2: It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Recognising that S106 will still play a part in site related infrastructure delivery, it is important that there is robust testing of the appropriate level of CIL having regard to site viability. Q-I5: The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detailed viability work must support the Local Plan process. Such viability work should either; a) be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58, or b) if based on general ‘site character types’ be sufficiently flexible to allow viability to be considered through S106 to address any unforeseen exceptional site delivery costs. 3.12. The Infrastructure Delivery Plan will be an important part of the evidence base, and Corbally Group would welcome the opportunity to comment on it.
Q-I2: Option I2a: Set out infrastructure requirements for all scales, types and location of development This is the approach we would favour. Integral to this would be consideration of the potential to accommodate growth where spare infrastructure capacity currently exists. Dispersed infrastructure is generally more deliverable and flexible and in many circumstances can be provided more easily and quicker. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy We would not support this option. This option which appears to favour large-scale development and large-scale infrastructure schemes to support them. A far more considered and balanced approach is required. Q-I3: Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan We would not support this option. Option I3b: Each District Council to produce its own Levy A joint approach would seem to be more logical and supportive of the preparation of the local plan on a joint basis.