Issue and Options 2023
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New searchChapter 1 – Introduction A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it is may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then, although Part 2 will need to be in conformity with the SWLP, preparation of Part 2 should be undertaken, as far as possible, in parallel with Part 1 in order to expedite its adoption. Even so, it is possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. Every effort should be made to avoid the delays which have resulted in the situation where although the current Stratford on Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not yet adopted. The Plan Period The vision for the Local Plan is set out up to the year 2050. The current National Planning Policy Framework (NPPF) at paragraph 22 states that strategic policies should look ahead over a minimum 15-year period from the date of adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055. As such, we contend that the Plan should have a 30 year horizon and run until 2055. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP including a Green Belt study. Approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are located within, the Green Belt. It is inevitable that the emerging plan will need to remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is essential in order to understand the sensitivity of different parts of the Green Belt to development. This matter should be considered alongside other evidence based documents to help establish the most appropriate locations for allocations. There are, however, a number of non Green Belt settlements in the plan area that are suitable for an allocation. Bishop’s Itchington is located outside of the Green Belt. As detailed within these representations it is a sustainable location for development. BDW control land at Ladbroke Road, to the east of Bishop’s Itchington that is ideally suited to residential development. As detailed in our Call for Sites submission is a readily deliverable housing site that should be preferred location for residential development.
Chapter 3 – Vision and Strategic Objectives Q.V3.1: The Vision The Vision outlined in the Draft Plan is appropriate, as are the objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities. Delivery of the SWLP should be achieved in a sustainable way that responds to the climate emergency and meets the five overarching objectives. This will ensure that the right development will be delivered in the right places. The Strategic Objective Chapter 3 – Vision and Strategic Objectives Q.V3.1: The Vision The Vision outlined in the Draft Plan is appropriate, as are the objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities. Delivery of the SWLP should be achieved in a sustainable way that responds to the climate emergency and meets the five overarching objectives. This will ensure that the right development will be delivered in the right places. A number of the Strategic Objectives identified in the Draft Plan are appropriate and should be translated in to policy in the following way. • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. There is the opportunity to include allocations in the SWLP that will deliver infrastructure that supports not just the proposed development, but also delivers onsite facilities that can benefit the local area as a whole. For example, the provision of new public open space that will be to the benefit of the local area as a whole. • Developing opportunities for jobs is an entirely appropriate objective. – There are a number of large villages in the plan area, such as Bishop’s Itchington, that have employment sites, services and facilities that create job opportunities. The plan should look to direct housing allocations to these locations to ensure that there is a workforce available. • Delivering homes that meet the needs of all our communities. –Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. While the focus should be larger strategic allocation that can make meaningful contributions to the housing need, smaller allocations will still be required to allow smaller settlements to meet their needs. • Contributing towards a net zero carbon target – Development opportunities that can provide significant amounts of green infrastructure and have access to services and facilities by sustainable means, such as train stations, and which can incorporate Active Travel should be preferred locations for allocations. • Connecting people to places – This is an important objective that will increase and improve access by sustainable and active travel modes. Allocations that are located close to public transport opportunities, educational facilities, green spaces, and employment opportunities, or can provide these opportunities on site, should be preferred. • Protecting and enhancing environmental assets – The SWLP should look to support allocations that can provide significant biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.
The Sustainability Appraisal has been very broadly applied and as such does not accurately reflect the sustainability of individual sites. It, therefore, does not accurately interpret the deliverability of the sustainable transport Growth Options and the proposed development strategy of the SWLP. A detailed response to the Suitability Appraisal is attached at Appendix 1.
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.
The South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. l. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of service and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.
