Issue and Options 2023

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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.

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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Persimmon are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

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Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Persimmon therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.

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Q-B3: Please select the option which is most appropriate for South Warwickshire Option B3c: Discard Special Landscape Areas and bolster general landscape policy 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.

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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.

9. Land South-West of Studley 9.1. Persimmon is promoting land south-west of Studley for residential development and on-site green infrastructure. It should be noted that this site would support development of sufficient scale to deliver highways infrastructure improvements in Studley which along with providing mitigation for any proposed development would also seek to provide a betterment to existing residents through relief of existing congestion. Options to deliver highway improvements will be explored in conjunction with the County Council as the Local Highway Authority. 9.2. The site comprises of agricultural fields with field boundaries defined by hedgerow and sporadic trees. The site is bordered by Bromsgrove Road, Node Hill, Jill Lane and The Slough road to the north (A448), beyond which is existing residential development associated with Studley. 9.3. The site is located at the settlement edge of Studley which is characterised by residential development of mixed character and age. The development of this site would form part of this context and would complement the existing residential use. Any development would be accompanied by a robust landscape strategy which would reflect the existing landscape character of the area. 9.4. The accompanying Vision Document sets out that the south-west of Studley is the least constrained option for growth for the village. A well-designed scheme would deliver residential growth and could accommodate complementary services and facilities for the village. Any scheme would be accompanied by a robust landscape strategy and would include a landscape buffer to the south to preserve the character of Studley and Middletown. As set out above, it is anticipated that the proposal would accommodate sufficient development to support the delivery of highway infrastructure improvements for the village which would deliver benefits for future and existing residents. Sustainability Appraisal SA 9.5. The majority of land south-west of Studley is included within the brown outline as ‘small settlement at Studley’ on Figure C.18.1. The site is shown to adjoin the built-up boundary. It is suggested that the outline should be expanded to include all land south-west of Studley up to the A435. 9.6. The assessment of Studley against the SA objectives is presented at Section C18.1 of Appendix C. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each site within the settlement. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The land would deliver residential dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The land could also deliver additional local facilities and highway infrastructure improvements. 9.8. SA Objective 2 Flood Risk: The land is entirely within Flood Zone 1, land at lowest risk of flooding. There are limited areas of surface water flood risk within this area however this could be addressed by suitable design and sustainable drainage systems. It should be noted that land to the south-east of Studley is constrained by areas of Flood Zone 3 associated with the River Arrow. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as a Special Conservation Area (SAC), Site of Special Scientific Interest (SSSI), National Nature Reserve (NNR), ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space (LGS) or priority habitat. The SA refers to Rough Hill & Wirehill Woods SSSI as an important local designated site. This SSSI lies north-west of Studley and is separated from the site by existing built development. Any impact on the SSSI could be appropriately managed, including through sensitive design. Wirehill Woods is also an ancient woodland and is beyond the Natural England buffer distance. As noted above, there is also intervening built development. There are small areas of priority habitat (deciduous woodland) within the site that would inform a future masterplanning process. 9.10. SA Objective 4 Landscape: The land is characterised by residential development to the north. The accompanying vision document sets out that any design would be landscape-led and would look to reflect the pattern and scale of the landscape, integrate into its landscape context and create a high-quality environment for the settlement edge of Studley. 9.11. SA Objective 5 Cultural Heritage: The land is located close to two Grade II Listed Buildings. This would inform the design process for this site. It should be noted that land to the southeast of Studley is constrained by the presence of three Grade II* Listed Buildings and a Scheduled Monument. The setting of these assets would need to be carefully considered and would suggest growth should be directed towards other parts of the settlement. 9.12. SA Objective 6 Pollution: It is noted that there is small Air Quality Management Area (AQMA) within Studley (to the west of the High Street). This is located in the northern part of the village and the land south-west of Studley is the most separated from the AQMA of any of the potential growth directions. Impact on the AQMA could be managed and highway infrastructure improvements that could be supported by this proposal would likely lead to air quality improvements. The SA also identifies the River Arrow as a potential pollution receptor which would need to be managed. Coin Brook is also identified as a small tributary which runs south-west of Studley but is closest to Middletown and could be managed through appropriate sustainable drainage and landscaping. 9.13. SA Objective 7 Natural Resources: It is acknowledged that development of this land would result in a loss of agricultural land however this would be a minor loss in the context of the wider agricultural land in this area. The land is within a Mineral Safeguarding Area (MSA) however the site is relatively small compared to the MSA and given the location of adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity. 9.14. SA Objective 8 Waste: A residential development would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. 9.15. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. 9.16. SA Objective 10 Health: Studley benefits from a good access to healthcare facilities with a GP surgery located in the village and the close proximity of the Alexandra Hospital (which includes an A&E department) in Redditch, immediately to the north of the settlement. There is also good access to leisure and recreation facilities within Studley with scope to provide on-site open space. 9.17. SA Objective 11 Accessibility and 12 Education: Studley benefits from a bus service providing frequent local services to Redditch and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are also various local services and facilities within the local area, including a primary schools and a secondary school. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Studley which include the employment areas to the north-west of the settlement. The village is also located close to the Alexandra Hospital and associated employment opportunities in Redditch which can be accessed via public transport. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The Vision Document indicates how the land could be developed for residential use having regard to the constraints and opportunities. 9.21. The site benefits from a sustainable location within Studley and is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.22. The Vision Document illustrates that the south-west is the least constrained of the three growth options for Studley, the other two being north and south-east. The north is significantly constrained by existing leisure, recreation and ecological uses and the narrow gap between Studley and the neighbouring town of Redditch. To the south-east are areas of flood risk associated with the River Arrow and various designated heritage assets, notably Grade II* Listed Buildings and a scheduled monument associated with Studley Castle. The land to the south-west is comparatively free of constraints and provides a clear opportunity to support the growth of the village. This development could deliver benefits for the village, for example through highway infrastructure improvements. 9.23. The Vision Document also considers the purposes of the Green Belt and sets out that release of land in this area would not compromise these purposes. It also considers that the constraints associated with the other potential growth directions means that release these areas would compromise these purposes. 9.24. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.25. Persimmon has a land interest and is promoting the area for residential development. 9.26. Persimmon is an experienced national housebuilder with a proven track record of delivery across the country, including in South Warwickshire. 9.27. Persimmon’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation to the South Warwickshire Local Plan. 9.28. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.29. Persimmon has a land interest and are actively promoting the area for residential development. The site is available and could deliver housing in the first half of the Plan period. 10. Conclusion 10.1. This representation has been prepared by Pegasus Group on behalf of Persimmon Homes. 10.2. Persimmon are promoting Land South-West of Studley for residential development. The land is sustainably located adjacent to the built development edge of Studley and adjoins existing residential development. This land is suitable, available and deliverable and should be released from the Green Belt and identified as a location for future residential development as part of the South Warwickshire Local Plan. 10.3. These representations demonstrate that there are no significant constraints that would preclude the delivery of residential development in this area. 10.4. Persimmon welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site to assist in the accurate assessment of this site, this can be provided upon request.

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2.1. As set out in response to the Scoping and Call for Sites consultation, Persimmon supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Persimmon supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed, and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported, and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning, however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.