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 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.

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 infrastructure delivery option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development The infrastructure requirements for the development strategy are critical in ensuring that development is deliverable and truly sustainable. One of the critical considerations in the site selection process should be the presence of onsite infrastructure at the site or the ability fro development to provide it. Q-I3 – Please select the CIL 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 The CIL requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. Q-I4.1 – Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes. There are a series of existing infrastructure schemes proposed across both plan areas. It would be sensible to include a policy in the plan confirming the nature and location of these schemes. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability The development strategy needs to be deliverable and viable and there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The allocation should be ‘deliverable’ as defined in the Glossary of the NPPF. It is appropriate that development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. In order to inform this process regard should be had to the site specific submissions put forward through the Call for Sites process. As part of their due diligence in promoting sites, BDW have undertaken a series of technical studies and a masterplanning process in order to ensure that their proposals are viable and deliverable. As detailed in our Call for Sites submission in respect of BDW’s land interest at Bishop’s Itchington, the site can delivery all necessary infrastructure, is viable and deliverable in the short term.

Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development The infrastructure requirements for the development strategy are critical in ensuring that development is deliverable and truly sustainable. One of the critical considerations in the site selection process should be the presence of onsite infrastructure at the site or the ability for development to provide it. As an example, the site in which BDW has an interrest at Bearley Station is a large scale development next to a train station. The site will encourage improvements to the train station and enhance the sustainability credentials of the area generally, by providing a station car park, a new school, large areas of public open space and employment. As part of the site selection process the local authority should consider how the infrastructure already present or can be provided can benefit the existing and new communities. Q-I3 – Please select the CIL 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 The CIL requirements must be considered as part of the plans viability assessment. Q-I4.1 – Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes. There are a series of existing infrastructure schemes proposed across both plan areas. It would be sensible to include a policy in the plan confirming the nature and location of these schemes. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability The development strategy needs to be deliverable and viable and there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The allocation should be ‘deliverable’ as defined in the Glossary of the NPPF. It is appropriate that development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. In order to inform this process regard should be had to the site specific submissions put forward through the Call for Sites process. As part of their due diligence in promoting sites, BDW have undertaken a series of technical studies and a master planning process in order to ensure that their proposals are viable and deliverable. This includes liaising with key service providers such as Network Rail and West Midlands Trains and also County Public Rights of Way officers.

Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development The infrastructure requirements for the development strategy are critical in ensuring that development is deliverable and truly sustainable. One of the critical considerations in the site selection process should be the presence of onsite infrastructure at the site or the ability for development to provide it. As an example, the site in which BDW has an interest at Wilmcote Station is a large scale development next to a train station. The site will encourage improvements to the train station and enhance the sustainability credentials of the area generally, by providing a station car park, a new school, large areas of public open space and employment. As part of the site selection process the local authority should consider how the infrastructure already present or can be provided can benefit the existing and new communities. Q-I3 – Please select the CIL 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 The CIL requirements must be considered as part of the plans viability assessment. Q-I4.1 – Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes. There are a series of existing infrastructure schemes proposed across both plan areas. It would be sensible to include a policy in the plan confirming the nature and location of these schemes. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability The development strategy needs to be deliverable and viable and there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The allocation should be ‘deliverable’ as defined in the Glossary of the NPPF. It is appropriate that development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. In order to inform this process regard should be had to the site specific submissions put forward through the Call for Sites process. As part of their due diligence in promoting sites, BDW have undertaken a series of technical studies and a master planning process in order to ensure that their proposals are viable and deliverable. This includes liaising with key service providers such as Network Rail and West Midlands Trains.

Issue I2: Infrastructure Requirements and delivery QI-2 - Please select the option which is most appropriate for South Warwickshire Option I2a states that Part 1 of the Local Plan would set out infrastructure requirements for all scales, types and location for development equally across South Warwickshire, whilst Option I2b would only focus on the strategic infrastructure relating specifically to the growth strategy. 3.6 However, the scope of the Plan as stated on Page 2 of the Consultation Document is that the Part 1 document would set out the overall strategy for the pattern, scale and design quality of places within South Warwickshire. This includes the provision of housing, employment and infrastructure at the strategic level. Subsequent Part 2 Plans would then ‘set out detailed policies for specific areas, neighbourhoods or types of development. This could include allocating sites and the provision of infrastructure at a local level, establishing design principles and setting out other more detailed planning policies’. 3.7 In this context, Option I2b is most appropriate, as the Part 1 Plan cannot pre-determine the infrastructure provision that may be required as a result of the identification of sites through Part 2 Plans. To do so would otherwise be pre-emptive of the location and scale of growth to be provided through Part 2 Plans. Any viability assessment undertaken in support of the Part 1 Plan cannot accurately assess the viability of Part 2 sites, given their full infrastructure requirements cannot be known. 3.8 The Councils should nonetheless be clear that infrastructure identified within the Part 1 Plan should be funded through a combination of developer contributions from strategic sites, combined with other sources of external funding. In either Option, development should only be required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision. Any policy wording in the Plan for Section 106 agreements will need to ensure decision makers consider the need for infrastructure requirements at the time of making the decision. Planning obligations be necessary to make the development acceptable in planning terms, directly related to the development; and fairly and reasonably related in scale and kind to the development (PPG, Reference ID: 23b-002-20190901). QI-3: Please select the option which is most appropriate for South Warwickshire The establishment of a CIL charging schedule (Issue I3) is also directly related to Issue I2: Infrastructure Requirements and delivery. In this regard, it is submitted that strategic infrastructure brought forward through the Part 1 Plan is most appropriately delivered through the use of S106 agreements, rather than CIL. This ensures that infrastructure funding derived from a development is more inherently linked to the infrastructure required to deliver that development. The timing and delivery of infrastructure can also more appropriately monitored through legal agreements. 3.10 However, should the Councils be minded to introduce CIL, it is considered that new settlements, such as that proposed at Long Marston Airfield, should be exempt, due to the scale of the bespoke infrastructure required to deliver it. QI-5: Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments 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.’ The Church Commissioners strongly emphasises that viability work referred to within the second sentence above should be undertaken ahead of, and to inform, the next stages of the Part 1 Local Plan. Considerations relevant to viability and deliverability should be considered at the earliest stages of plan-making, to ensure that any allocations identified are viable and deliverable, including identifying infrastructure requirements.

HS2 are pleased to see in the Issues and Options consultation for the South Warwickshire Local Plan that both districts acknowledge the HS2 Line of route and associated safeguarding. This is specifically mentioned in Issue I4 discussing Infrastructure Safeguarding. By doing so this follows our published guidance in preparing local plans (Safeguarding directions guidance notes for LPAs). From our records we can see we have been consulted on the Local Plan before in which we issued a no comment response. In regards to this stage of the consultation HS2 again has no comments but would like to be notified of any sites/land which might affect the safeguarding of the HS2 line of route and be kept up to date with the progression of the South Warwickshire Local Plan. Many thanks for keeping us up to date with the progress so far.

Q I.2 12b. Without a significant change to the approach to funding infrastructure none of the options will be adequate. Is this a Local Plan matter, as most utilities are provided by the regulated private sector, not public authorities, and there is a statutory duty on these regulated companies to provide the infrastructure. The Parish Council consider there is no reference to obtaining funding commitments from statutory providers and the key private-sector agencies involved in public infrastructure/services guaranteeing the investment necessary. It is incumbent on the South Warwickshire Local Plan to make a statement as to how these facilities will be provided well in advance of any site allocation and development commencing. It is disingenuous to maintain that the private sector will be able to fill this gap entirely. QI.3 Option 13b on the subsidiarity principle seems more relevant for each district council. QI.5 The infrastructure within the parish is inadequate for any development. Unless the chosen option presents proposals to deal with these issues in the early years of the plan none of the growth options will be acceptable.

Issue I2 – Infrastructure Delivery 5.6.1 St. Modwen acknowledge that the most common concerns relating to infrastructure in South Warwickshire relate to transport, utilities, education, green infrastructure and health facilities. 5.6.2 St. Modwen are confident that the proposals set out in our Vision Document for Southeast Southam align with the 5 Strategic Objectives of the SWLP. These are:  Addressing Climate Change – Our vision for land East of Southam supports sustainable and net zero carbon ambitions to address climate change effects including through the provision of green and blue infrastructure and through delivery of the 20 minute neighbourhood;  Promoting wellbeing – Our vision for land East of Southam is capable of delivering on site provision of health and education facilities, along with affordable housing which St. Modwen agree is critical to the success of achieving sustainable communities. Our proposals promote healthy, inclusive and safe places and include the provision of pedestrian and cycle connections within and between neighbourhoods, high quality public space, safe and accessible green infrastructure, sport and recreation facilities, local shops, meeting places, access to healthier food and allotments.  Improving connectivity – Our vision for land East of Southam will provide for appropriate transport infrastructure and consider the opportunities from existing or proposed transport infrastructure particularly those in relation to walking, cycling and public transport. The development would adhere to the principles of the 20 minute neighbourhood.  Increasing biodiversity – Our vision for land East of Southam includes green and blue infrastructure providing multiple benefits to existing and new residents of the town. These spaces will create and enhance habitats and biodiversity rich places securing measurable net gains for the development.  Creating well-designed and beautiful places – Our vision for land East of Southam will be focused on design quality relating to individual buildings and the spaces and places between them including the potential for public art. 5.6.3 St. Modwen strongly believe that development on Land to the East of Southam maximises the chance of ensuring infrastructure delivers services the new residents and the existing residents of the town need. 5.6.4 It is also important to plan properly for infrastructure requirements across the SWLP area. Identifying impacts and mitigation linked to growth scenarios is critical if development is going to be delivered viably and in accordance with the principles of the Local Plan. Infrastructure evidence will form a key part of the Councils evidence base and should be assessed ahead of and not after key Growth Options analysis is completed. CIL requirements can then be assessed based on an appropriate growth scenario. Issue I5 – Viability and Deliverability 5.7.1 St. Modwen strongly feel that viability and deliverability are key to achieving a successful SWLP. The land being promoted as part of the appended Vision Document is within one land owners control being promoted with one master developer, St. Modwen, promoting and delivering the site. The land to the Southeast of Southam is therefore available in accordance with Para 68 NPPF terms which notes that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. 5.7.2 We would also highlight that land to the Southeast of Southam should be considered fully deliverable under NPPF definitions as meaningful development would occur within 5 years of the sites allocation in the SWLP. St. Modwen would be fully prepared to submit a Statement of Common Ground in support of collaborative working to ensure applications are submitted that support the Council’s vision for development in Southam. St. Modwen want to work with the SWLP team to ensure that Land East of Southam can be delivered quickly and in accordance with the emerging policies in the Local Plan. This would include viability assessment based work showing that Land East of Southam is a highly deliverable development solution for the SWLP.

Q-I2: Please select the option which is most appropriate for South Warwickshire Option 12a: Set out infrastructure for all scales, types and locations of development. This option has been chosen as infrastructure delivery of strategic sites may need to consider the wider context of cumulative growth across a catchment. Q-I5: Please add any comments you would like to add about infrastructure, viability and deliverability Severn Trent is keen to be consulted further in the development of Infrastructure Development Plans, particularly in relation to strategic sites.

Key infrastructure must be financed and delivered in advance of any development. Mitigation is unacceptable.

Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments 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’. 3.7 Caddick Land submits that this work should be undertaken as a priority, ahead of and to inform the next stages of the Part 1 Local Plan. Considerations relevant to viability and deliverability should be considered at the earliest stages of plan-making, to ensure that any allocations identified are viable and deliverable. This includes identifying infrastructure requirements associated with the proposed growth strategy as part of the process of preparing the evidence base and should be made clear in any forthcoming consultation.

Option I3b: Each District Council to produce its own Levy Currently, the two district councils have their own separate CIL schedules. St Joseph recommends each District Council should continue with this strategy, as the two geographical areas have different priorities in terms of regeneration, commercial space etc. to allow for reduced or increased CIL rates.

Issue I2: Infrastructure Requirements and delivery Q-I2: Please select the option which is most appropriate for South Warwickshire NWBC Response – Recommend Option I2a: Set out infrastructure requirements for all scales, types and location of development - Although strategic sites do require specific focus/addressing in infrastructure terms, the wider impact of multiple smaller developments must not be ignored and can and will ultimately have similar scale infrastructure and service impacts to the specific large strategic proposals. NWBC Response – Agree that all identified options need to be used to address infrastructure requirements and delivery including; 1. On-site directly by the infrastructure provider as a requirement of an individual planning permission – e.g. digital communications, energy, water, roads, cycleways, access to public transport 2. On-site incorporated into the design of the development by the developer – e.g. renewable and low carbon energy, green infrastructure, affordable housing, design quality 3. 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 Issue I3: Community Infrastructure Levy (CIL) Q-I3: Please select the option which is most appropriate for South Warwickshire NWBC Response – No comment. North Warwickshire Borough do not currently apply the CiL approach, only the use of S106 Obligations. The new ‘Infrastructure Levy’ proposed in the Levelling Up and Regeneration Bill may need to be reflected by the emerging joint Plan.

National Gas Transmission has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document. About National Gas Transmission National Gas Transmission owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use. National Gas Transmission assets within the Plan area Following a review of the above Development Plan Document, we have identified one or more National Gas Transmission assets within the Plan area. Details of National Gas Transmission assets are provided below. Asset Description Gas Transmission Pipeline, route: CHURCHOVER TO WORMINGTON Gas Transmission Pipeline, route: CHURCHOVER TO WORMINGTON DUPLICATE Gas Transmission Pipeline, route: CHURCHOVER COMP TEE TO HONEYBOURNE A plan showing details and locations of National Gas Transmission’s assets is attached to this letter. Please note that this plan is illustrative only. Please also see attached information outlining further guidance on development close to National Gas Transmission assets. Utilities Design Guidance The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by National Gas Transmission infrastructure. National Gas Transmission advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines, underground gas transmission pipelines, and other National Gas Transmission assets. Therefore, to ensure that future Design Policy D1 ‘Strategic Design Principles’ remain consistent with national policy we would request the inclusion of a policy strand such as: “x. taking a comprehensive and co-ordinated approach to development including respecting existing site constraints including utilities situated within sites.” Further Advice National Gas Transmission is happy to provide advice and guidance to the Council concerning their networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Gas Transmission wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Gas Transmission on any Development Plan Document (DPD) or site-specific proposals that could affect National Gas Transmission’s assets. We would be grateful if you could check that our details as shown below are included on your consultation database

National Grid Electricity Transmission has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document. About National Grid Electricity Transmission National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. The energy is then distributed to the electricity distribution network operators, so it can reach homes and businesses.National Grid no longer owns or operates the high-pressure gas transmission system across the UK. This is the responsibility of National Gas Transmission, which is a separate entity and must be consulted independently. National Grid Ventures (NGV) develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States. NGV is separate from National Grid’s core regulated businesses. Please also consult with NGV separately from NGET. NGET assets within the Plan area Following a review of the above Development Plan Document, we have identified one or more NGET assets within the Plan area. Details of NGET assets are provided below. Asset Description ZF ROUTE TWR (135 - 208): 400Kv Overhead Transmission Line route: BERKSWELL - FECKENHAM ZF ROUTE TWR (209 - 337): 400Kv Overhead Transmission Line route: FECKENHAM - WALHAM A plan showing details and locations of NGET’s assets is attached to this letter. Please note that this plan is illustrative only. Please also see attached information outlining further guidance on development close to NGET assets. Utilities Design Guidance The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET. NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets. Therefore, to ensure that Design Policy D1 ‘Strategic Design Principles’ is consistent with national policy we would request the inclusion of a policy strand such as:“x. taking a comprehensive and co-ordinated approach to development including respecting existing site constraints including utilities situated within sites.” Further Advice NGET is happy to provide advice and guidance to the Council concerning their networks. Please see attached information outlining further guidance on development close to National Grid assets. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, NGET wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult NGET on any Development Plan Document (DPD) or site-specific proposals that could affect our assets. We would be grateful if you could add our details shown below to your consultation database, if they are not already included

It should be noted that, whilst safeguarding specific infrastructure is important to provide assurances as strategic infrastructure projects are heavily reliant on funding. The South-Western Relief Road (SWRR), which is necessary for the delivery of the Long Marston Airfield development, failed to secure the required funding via the Housing Infrastructure Fund, which led to substantial constraints for the Long Marston Airfield development. Until sufficient infrastructure is in place to support growth to the south and east of the settlement, any substantial growth around Stratford-upon-Avon should be focussed north and west of the A46, which has the infrastructure in place.

Q-I2. Please select the option which is most appropriate for South Warwickshire. 3.7 RPS considers Option I2b with a ‘focus on the strategic infrastructure relating specifically to the growth strategy’ is most appropriate. Noting that in the interim, existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two districts. Given the site promotion at Coventry Gateway West relies on the strategic infrastructure currently underway on the new access road to the A45/A46, other development schemes in close proximity to the site are most applicable to the delivery of our site. 3.8 RPS acknowledges that infrastructure provision is a factor in assessing the potential suitability of development in terms of location. Nonetheless, national policy (NPPF 2021, paragraph 20b and 20c and 20d) makes clear that strategic policies should ‘…make sufficient provision for…infrastructure’ and ‘should...anticipate and respond to long-term requirements and opportunities such as those arising from major improvement in infrastructure…” (paragraph 22). 3.9 Therefore, national policy does not consider existing levels of infrastructure provision as being an absolute constraint on development, but rather encourages local planning authorities to find solutions to blockages in infrastructure provision that can unlock the potential to support additional growth where this supports the wider strategic objectives and policies of the development plan. 3.10 Furthermore, the provision of significant new infrastructure investment can also be a catalyst for increased demand for housing and other uses that was not previously in use when previous plans were being prepared, most notably the significant investment planned as part of the HS2 project, as well as other significant infrastructure investments that has recently come into operation, i.e. Toll Bar End roundabout, and infrastructure provision associated with development around Coventry Airport, all in close proximity to the site. QI3. Please select the option which is most appropriate for South Warwickshire. 3.11 Option I3a - A single Levy would provide clarity and greater certainty regarding likely development costs. 3.12 National policy makes clear that contributions, either as part of a development or through in-kind benefits, should be defined in development plans (NPPF 2021, para 34). It also states that such policies should not undermine the deliverability of the plan. Furthermore, contributions or in-kind benefits secured through planning obligations must only be sought where they meet all of the three tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (NPPF 2021, para 57). 3.13 Therefore, the SWLP needs to ensure that any enhancements that are sought are consistent with national policy, fully justified on the evidence, and also do not go beyond the legal tests highlighted above.