Q-P1.3: Do you agree with the selection of policies to be addressed in the Part 1 plan?
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
Throughout the document we have identified policies which are inappropriate or being addressed in the wrong place . Part 1 Preferred Options should be radically shortened.
There is no objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the deliver of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1.
Throughout the document we have identified policies which are inappropriate or being addressed in the wrong place . Part 1 Preferred Options should be radically shortened. There is a plethora of policy options which are not central to the political decisions to South Warwickshire’s future or are duplicating national legislation or policy.
It would appear that necessary policies have been included, but is not clear where the policies on ensuring provision of services and infrastructure pertaining to specifics such as agreements with local authorities for provision of healthcare, schooling, roads and transport and utilities such as sewage centres. The plan presented does not appear to give specifics about cost models that will be applied to the developments nor is there an indication of time or phases to development and reassessment points over what is a 30 year period. There appears to be no policy on how cost appropriate social housing will be achieved.
Q P1.3 It would appear that necessary policies have been included, but is not clear where the policies on ensuring provision of services and infrastructure pertaining to specifics such as agreements with local authorities for provision of healthcare, schooling, roads and transport and utilities such as sewage centres. The plan presented does not appear to give specifics about cost models that will be applied to the developments nor is there an indication of time or phases to development and reassessment points over what is a 30 year period. There appears to be no policy on how cost appropriate social housing will be achieved.
As detailed above, it is considered that some of the policies proposed as part of the Issues and Options consultation document go beyond the scope of the Part 1 Plan. The policies proposed should be reviewed to ensure that detailed Development Management policies such as those referring to space standards (see Q-H3) and design (see Q-D1.2) are removed and included as part of the Part 2 Plan process.
As detailed above, it is considered that some of the policies proposed as part of the Issues and Options consultation document go beyond the scope of the Part 1 Plan. The policies proposed should be reviewed to ensure that detailed Development Management policies such as those referring to space standards (see Q-H3) and design (see Q-D1.2) are removed and included as part of the Part 2 Plan process. We trust the above is useful and will be taken into consideration in preparing further iterations of the South Warwickshire Local Plan. In the meantime, please do not hesitate to contact me should you require any further information.
The emerging plan appears to have an urban focus whereas half of the plan area’s populations live in rural areas. This potential for growth to be used to improve services and facilities across the rural area does not appear to be recognized or deployed to the extent that it reasonably could and should be used. Urban areas are already relatively congested whereas smaller a scale of growth can be accommodated in rural areas and this could, as an example, help support or enhance limited public transport services across many areas.
QP1.3 Do you agree with the selection of policies to be addressed in the Part 1 plan? Throughout the document we have identified policies which are inappropriate or being addressed in the wrong place . Part 1 Preferred Options should be radically shortened. There is a plethora of policy options which are not central to the political decisions to South Warwickshire’s future or are duplicating national legislation or policy. QP.1.4 Are there any areas where equality and inclusivity in planning needs further attention? This area seems to be almost totally absent from the document.
The emerging plan appears to have an urban focus whereas half of the plan area’s population lives in rural areas. This potential for growth to be used to improve services and facilities across the rural area does not appear to be recognized or deployed to the extent that it reasonably could and should be used. Urban areas are already relatively congested whereas smaller a scale of growth can be accommodated in rural areas and this could, as an example, help support or enhance limited public transport services across many areas.
Q P1.3 It would appear that necessary policies have been included, but is not clear where the policies on ensuring provision of services and infrastructure pertaining to specifics such as agreements with local authorities for provision of healthcare, schooling, roads and transport and utilities such as sewage centres. The plan presented does not appear to give specifics about cost models that will be applied to the developments nor is there an indication of time or phases to development and reassessment points over what is a 30 year period. There appears to be no policy on how cost appropriate social housing will be achieved.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
All existing adopted policies are to be retained or updated (except for those policies regarding retail changes of use - which are to be deleted for consistency with updated legislation).
Questions P1.3 and Q-P1 4: - Lockley Homes would select ‘No’ to Question P1.1 referred to above. Producing two separate Local Plans – Parts 1 and 2 will add significant confusion and a major time delay to the Local Plan making process. This will cause significant uncertainty for housing developers, rural landowners, local businesses, local communities and other key stakeholders. Our concerns about the Council’s proposed Plan-making approach are set out below. Page 174 (Chapter 12) of the SWLP (January 2023) states that: “…The South Warwickshire Local Plan will be divided into two parts. Part 1 would be a single document, while Part 2 could consist of multiple documents. Neighbourhood Development Plans would form part of the wider Development Plan for South Warwickshire, but would not fall within either Part 1 or Part 2….” Lockley Homes strongly objects 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 confusion to the Plan-making process, and will result in 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 area. Page 174 of the SWLP (January 2023) states that ‘smaller and non-strategic housing site allocations’ will be brought forward under Part 2 of the Local Plan. In response, Lockley Homes considers that placing small-scale and medium scale housing sites within a Stage 2 SWLP is completely unacceptable situation. 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. These important small and medium-sized housing sites should be brought forward as a matter of urgency within the emerging SWLP at the very front of the Local Plan period, in order to help boost the supply of new homes, consistent with paragraph 60 of the Revised NPPF (2021). These types of small housing sites have a key role to play in helping to deliver a much-needed supply of new homes to help tackle long-standing housing shortfalls present across the South Warwickshire Region. Relying on large Strategic Housing Sites to support the front of the Local Plan period (Stage 1/ Part 1) also has considerable risks, given that the local area is currently facing significant economic pressures/ the local area is facing a 300-year-economic-recession-event, and severe volatility in the residential mortgages market due to rising inflation. This approach to Plan making may not therefore be deliverable and would fail deliverability tests set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). This would affect the ‘Soundness’ of the overall proposed Plan-making approach, given that the Local Plan could be challenged against the above NPPF guidance. We suspect that the Councils preparing the emerging SWLP are already aware that they are taking forward an unsound Plan-making approach that tails tests of Soundness in paragraph 35 (indent d) of the Revised NPPF (2021) – given the Plans continual ongoing failure and continued refusal to promote the most sustainable patterns of new housing development within the South Warwickshire Region. This is supported by evidence given the highly obstructive planning policy approach being taken against the Lockley Homes site within the Village of Broom settlement. Which represents a highly sustainable site location for new housing. Moving smaller and medium sized sites to sometime in the distant future to be considered within a SWLP Stage 2/ Part 2 Plan version, is therefore helping the Council’s avoid the issue of why the Council’s are still refusing to promote the most sustainable patterns of new housing development coming forward within the South Warwickshire Districts. We find this highly obstructive approach being taken towards Local Plan preparation very concerning. The Council’s Planning Policy Teams stance on these issues is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making.
Q P1.3 It would appear that necessary policies have been included, but is not clear where the policies on ensuring provision of services and infrastructure pertaining to specifics such as agreements with local authorities for provision of healthcare, schooling, roads and transport and utilities such as sewage centres. The plan presented does not appear to give specifics about cost models that will be applied to the developments nor is there an indication of time or phases to development and reassessment points over what is a 30 year period. There appears to be no policy on how cost appropriate social housing will be achieved.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
Q-P1.3: Do you agree with the selection of policies to be addressed in the Part 1 plan? Yes Q-P1.4: If not, please indicate why 8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
There is no objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1.
The emerging plan appears to have an urban focus whereas half of the plan area’s populations live in rural areas. This potential for growth to be used to improve services and facilities across the rural area does not appear to be recognized or deployed to the extent that it reasonably could and should be used. Urban areas are already relatively congested whereas smaller a scale of growth can be accommodated in rural areas and this could, as an example, help support or enhance limited public transport services across many areas.
Q P1.3 It would appear that necessary policies have been included, but is not clear where the policies on ensuring provision of services and infrastructure pertaining to specifics such as agreements with local authorities for provision of healthcare, schooling, roads and transport and utilities such as sewage centres. The plan presented does not appear to give specifics about cost models that will be applied to the developments nor is there an indication of time or phases to development and reassessment points over what is a 30 year period. There appears to be no policy on how cost appropriate social housing will be achieved.
The emerging plan appears to have an urban focus whereas half of the plan area’s populations live in rural areas. This potential for growth to be used to improve services and facilities across the rural area does not appear to be recognized or deployed to the extent that it reasonably could and should be used. Urban areas are already relatively congested whereas smaller a scale of growth can be accommodated in rural areas and this could, as an example, help support or enhance limited public transport services across many areas.
Q-P1.3: Do you agree with the selection of policies to be addressed in the Part 1 plan? Yes Q-P1.4: If not, please indicate why 8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
Q-P1.3: Do you agree with the selection of policies to be addressed in the Part 1 Plan? 10.2 The wording in Tables 20 and 21 is too brief, especially considering the associated explanation listed in Table 19 states that it could mean adjusting or re-working a policy, or creating a new policy on the same subject. The Church Commissioners is concerned Table 20 has been generated based on the evidence conducted to date, greater information and evidence base should be generated to underpin the Part 1 Local Plan. In addition, all policies should be viability tested, to ensure they are deliverable and achievable. In addition, those policies stated as some elements to be addressed in Part 1, with the remaining be Part 2, it is unclear which elements are to be addressed where and why. 10.3 The Church Commissioners reiterates that the Part 1 Local Plan should be based upon strategic policies only, to set out where and how much development should take place across South Warwickshire, with detailed policies to follow within Part 2.