Issue and Options 2023

1.0 Background This submission contains both specific comments on the text of the consultation document and general comments and issues the Chamber of Commerce wishes to highlight. As requested where the consultation questions are addressed they are referenced with the appropriate number and by the indicating the relevant Chapter and section of the document. The Coventry and Warwickshire Chamber of Commerce (referred to here as “The Chamber’) welcomes the opportunity to engage with the process leading to a new joint plan for Stratford and Warwick Districts. Business across South Warwickshire and indeed the C&W sub region is heavily dependent on the overall supply of employment land and business premises. A key concern of the Chamber regarding the existing sub regional Coventry and Warwickshire local plan policy frameworks is that they have failed, over their life to date, to provide sufficient new employment land and commercial premises to meet both the needs of existing businesses and provide what is needed to attract new growth and businesses. This new joint plan is therefore vital to producing an adequate range of new employment land opportunities to supplement existing stock and which can meet long term requirements .It is important that new land is allocated to meet a full range of business needs and that the allocation of land is influenced by attention to Market Signals data and the views of industry and business. To assist its input into the process the Chamber has formed an Employment Land Panel drawing on the expertise of its members, advisors and consultants with knowledge and expertise across the Coventry and Warwickshire sub region and the West Midlands. The Employment Land Panel would, in the future, like to engage with the team developing the planning framework on a regular basis. This would help ensure that the voice of business is represented as the overall plan strategy develops. 2.0 General It is central that the South Warwickshire Local Plan produces a policy framework that encourages business growth and development. This should also ensure that it meets needs and requirements across the whole spectrum of the economy and across the whole plan period to 2050.In terms of this latter requirement the plan should be underpinned by a commitment to detailed monitoring of economic performance to ensure a good understanding of the economic performance of the plan and its policies. This would then facilitate changes and alterations to the overall strategy to take account of change identified. Throughout the period to date covered by both the current Warwick and Stratford Local Plan frameworks (approx. 2011-2022) there have been sectoral shortages of employment land and evidence of mismatch between available supply and market requirements .This is evidenced in a number of sub regional and regional studies. The Chamber believes that there are several factors at work here including. -The inadequacy of the overall amount of employment land allocations to meet market demand .In particular there is evidence of shortages of industrial land in areas adjoining key settlements. -Affordability issues whereby new land allocations are, through market mechanisms, not available to some market sectors -A failure to properly understand market dynamics that have led to land generally allocated for employment use ending up being directed to one sector –usually distribution or logistics. -Mismatches between the scale of allocations and the prevailing market needs of particular areas across the new joint plan area. The Chamber welcomes the more strategic approach offered by the new joint plan across the wider area of south Warwickshire. Employment markets tend to operate across local authority boundaries and the wider plan area offers an opportunity to better meet the full range of needs. The draft Plan appears to advocate more disaggregated approach to meeting future employment needs. Therefore the suggested levels of employment land provision to both 2041 and 2050 indicate a separate allocation for B8 (warehousing and distribution) allocations, with Offices and General Industry having their own allocations .The Chamber welcomes this approach, though it would question if this goes far enough in disaggregating proposed supply? . A key weakness of the current adopted plan allocations (for both Stratford and Warwick and indeed across the sub–region)is that ,in the main, they simply allocate land for general employment across all Use Classes. Particularly on the larger allocations this general approach leads to land coming forward for the highest value uses –generally Class B8 (Warehousing and Distribution) where values can approach residential values. This has then created shortages of general industrial land and in particular smaller scale units. These trends, drawbacks and issues are well documented in the report Coventry and Warwickshire Market Signals Study 2019 produced by BBP Regeneration Ltd. This was produced by the CW LEP, WCC and the local authorities across Coventry and Warwickshire and represents a key piece of relatively up to date market evidence and recommendations. The draft Plan document is dominated by housing issues and much of the support evidence reflects this domination. Given the political profile of housing this is not surprising. However, the Chamber considers that the emerging new plan framework provides a major opportunity to give the local /sub regional economy equal prominence .The new plan needs to provide a framework in which the economy can grow and reach its full potential. This will require sufficiently large and more varied employment land allocations in appropriate locations across the plan area .In addition, as noted above, it is essential that there is a commitment to continuously monitoring the performance of the plan in terms of its economic impact. Recent changes in working patterns and the way market forces are creating new demands for new types of commercial space need to be properly accounted for in the new plan framework .As noted there isa strong emphasis throughout this consultation on housing provision .In future stages of the plan process, the Chamber wishes to see more detailed consideration of employment issues and how the new framework will tackle the changing patterns of work and employment. While the Chamber acknowledges that both local authorities produce Annual Monitoring Reports (AMR’s), these are in terms of monitoring the local economy very general and are not consistent in their content. They provide very broad data not sufficient to understand the detailed dynamics of the land and property markets .The emergence of the new joint plan provides an opportunity to address this deficiency and develop useful data sets that will better enable measurement of the local markets.

Nothing chosen

Issue V2; Vision. Overall the Chamber supports the proposed Strategic Objectives and Vision for the plan area. However we would wish to see more explicit reference to creating a policy framework that seeks to support the continued maintenance, development and growth of the local and sub regional economy. Currently this is lacking from the Vision statement. We note that in the previous consultation there was a call for any plan to “be proactive regarding economic growth “. (Ref p 20) V3; Strategic Objectives. (Ref Q-V3.1&2) It must be recognized and evaluated that all new policies will create potential cost impact and the proposed shift in emphasis towards a “Zero Carbon “ South Warwickshire is likely to come at some cost to both public and private sectors. Thus the Chamber would urge that all relevant proposals in this long-term strategy are fully evaluated and costed prior to their introduction for their impacts on the local economy.

Issue 11; Sustainability Appraisal. QI-1. At this stage of the plan process and given a lack of more detailed evidence base on some relevant matters the Chamber does not support or endorse a specific growth option. However as set out the Chamber does favour adoption of growth options that promote sustainable development across the whole plan area and options which give prominence to the importance of developing the local economy of the sub region.

Issue 12. Infrastructure. Q-12a&b). It goes without saying that the provision of appropriate infrastructure of all types at the right time is vital to the creation of a successful economy and indeed to the survival and continued growth of Chamber members and their businesses. During the current plan periods to 2031 the Chamber has been disappointed that infrastructure provision has not always kept pace with development or indeed provided to enable the growth of particular land uses .For example, there remain a number of employment allocations which are not coming forward due to a lack of necessary infrastructure, for example the employment allocations at Kenilworth and Stratford Road, Warwick. Experience suggests that more involvement by the public sector in bringing forward key infrastructure to encourage and facilitate growth in such instances could have created more economic growth. Energy infrastructure provides a good example of another current deficiency in key infrastructure provision. In recent years we have been aware of specific examples where the lack of power/energy infrastructure has prevented new business relocating to key sites across the sub region, including examples in both Stratford and Warwick districts. This represents in part, a failure of the land use planning process to provide the correct framework. The understanding of energy supply and capacity issues to facilitate expansion and development of businesses and has been limited .It suggests that there is a poor understanding of the mechanisms and processes that underpin energy provision and a proper appreciation of the complexity of the processes involved in this provision. It seems likely that energy is only one of a range of infrastructure issues where a greater understanding of how infrastructure mechanisms actually operate is required. This points to a need to better understand the situation across the local plan area and to understand precisely how individual proposals will be serviced and facilitated. At the moment there is no evidence base to support the view that this assumption is incorrect. Issue 13 .CIL Q13a&b. Currently we would favour retention of the existing system of Section 106 and CIL as operated locally. We note that reforms of the whole framework of developer contributions are promised by central government and it seems wise to wait to see the scope and extent of national reform before adopting a new position for South Warwickshire. Issue 15: Viability and Deliverability. Q-15 The Chamber welcomes the commitment to ensure that new proposals and allocations are fully “tested “ in terms of viability and deliverability. In the current economic climate there are a number of commercial land uses that may not be viable and a good understanding of different markets and sectors will be important when considering the deliverability of proposals generated in the plan framework. It should be acknowledged that based on the current adopted plans this has not always been successfully achieved. Lessons based on past experiences and outcomes need to be taken. As noted below the Chamber wishes to see all current employment allocations re-tested and reviewed in terms of likely deliverability.

Yes

No answer given

Yes

Nothing chosen

No answer given

Issue S1: Green and Blue infrastructure. Q S1a&b. Overall the Chamber supports the overall “hierarchical “ approach to settlement planning outlined in the emerging strategy. However, as the Chamber has noted above , there is a lack of real detail supporting much of the emerging strategy and the Chamber will await further evidence and background information before making specific comment on the distribution strategy. The Chamber particularly welcomes the recognition in the draft proposals relating to a much clearer appreciation and proactive understanding that improving both “green “ and “blue “ infrastructure environments must be a key and proactive part of economic and social planning rather than simply an “afterthought”. The Chamber recognizes that this specific distinctive treatment of infrastructure has potential to contribute proactively to the planning of industry; and employment and can improve the quality of life in South Warwickshire. Issue S2; Intensification. Q-S2 a,b,c. The Chamber cautions against the use of this blanket approach. Over the past 10 years against a background of greater differentials in prevailing land values much employment land and premises have been lost principally to new housing. Indeed this has been reinforced by national policies .At the same time many local planning authorities have failed to protect areas of employment concentration particularly in urban areas. The effect of this has been a loss of cheaper often lower quality business space. This type of space forms a vital component of a functioning employment land market. The result is that there are now significant “gaps’ in the provision of some types of employment and business space. Perhaps the best current example is storage space where much of the stock of such spaces and premises in urban areas has been lost. These losses have often generated unsustainable alternative locations in rural locations. The general concern is that by a process of intensification losses of important elements of cities, towns and smaller communities are lost. On a related point, the Chamber is concerned with an overreliance on the new Use Classes Order to allocate and regulate commercial space. See the Chambers comments below which relate to the same general point. Issue S3: Using Brownfield land. Q-S3.1, 3.2a-c. It is national policy to prioritise the development of brown field land. However it must be acknowledged that the policy as applied in recent times is partly responsible for the loss of significant areas of valuable small scale industry and business premises and a loss overall of employment land. This is well documented. In particular the application of the policy has resulted in the loss of significant land and premises that provide accommodation at the lower end of the market and which has eroded the supply of cheaper more affordable premises. In some local authorities this is recognized and is balance by policies that seek to protect local businesses and require that if brownfield land that supports employment use is threatened then a detailed assessment and balancing of priorities is under taken .The Chamber fully supports such a policy approach to “testing “these development pressures .The adopted Rugby Borough Local Plan contains a comprehensive policy (ED1: RBC adopted local plan) that seeks to protect its stock of employment land and establishes a series of “tests’ in the event that changes /loss of employment land is promoted .The Chamber fully supports this type of comprehensive policy that would go some way to protecting employment assets. Issue S4: Growth of existing settlements Q-S4,1-2 The Chamber agrees that the existing framework and hierarchy of settlements provides a good basis for future land use allocations .The Chamber would like to see a range of new employment land provided across the existing built framework. There appear to be good opportunities across all settlements of varying size to facilitate and allocate the provision of new employment allocations of an appropriate scale. In this way it will encourage a better relationship of homes and job opportunities and underpin sustainable development .As recognized by the SDC draft policy framework in relation to Employment Enabling Sites (ref SAP 8- draft Site Allocations Plan 2021)there are opportunities to provide a supply of small scale low cost affordable units in smaller communities and settlements. Issue S5, The potential for New Settlements. Q-S5.1,2,3,4 As recognized in the text of the document, with the plan framework running to 2050 it seems likely that the provision of new settlements will be required to sit alongside growth provision achieved by extending settlements. Therefore the Chamber supports the initiative. The difficulty of establishing a genuinely sustainable new community, as distinct from a large housing scheme, represents a major challenge. Fundamentally it requires significant resource and commitment from both public and private sectors. On a point of relative detail it is suggested that more in depth work is carried out to look at development thresholds and viability in new communities. Put another way how do we create genuinely sustainable new development? There is a considerable pool of experience and knowledge to draw on. The New Towns programme and the Garden City developments exemplify this. They provide evidence that in order to support good levels of facilities and services significant scale and concentrations of development are required. Otherwise without sufficient “critical mass” small scale new settlements run a danger of evolving into large isolated estates with minimum facilities and become “car dependent” .The thresholds quoted (Ref; Table3, p48) seem low but the consultation is not clear about what actual scale of new settlement is being tested. As an example it seems highly unlikely that the rail industry, and particularly the Train Operating Companies, would be prepared to open a new railway station on the basis of the 6000 dwellings quoted (ref; Table 3 p48.) The Chamber of Commerce would support a bold long term planning approach whereby a policy framework that includes new settlements would set out ambitious and long-term aspirations for relatively large-scale new communities. This would include the provision of significant new jobs, community facilities, environmental and social infrastructure alongside significant dwelling provision. This will increase the sustainability of the overall strategy and deliver a wider range of jobs. Issue S6. Green Belt boundaries. The Chamber fully supports and welcomes the stated intention to review current Green Belt boundaries as referenced at Issue S6 (page 57) in the draft document. Given the duration of the strategy and the wider sub regional growth context it appears unlikely that the levels of growth indicated in the HEDNA papers can be accommodated without changes to green belt across this plan and indeed across the sub region .The Chamber would support this review for the joint plan area being done in conjunction with this review and that it should not be dependent on individual reviews of the whole sub region .This is because the timing and programmes of other areas largely remains unclear and a wider GB review could seriously delay this plan .There already exists a reasonably up to date technical evidence base (reference here to Land use Consultants Study 2016).This work could form a good baseline for further work on altering the relevant green belt boundaries across this plan area. It would also save time and resources duplicating previous relatively recent work. Issue 7. Options for Growth. Q-S7 2 Options 1-5. At this point in the plan making process the Chamber feels that there is not enough evidence base or complete information to support any single growth option. Generally, the Chamber supports the Options that feature a strong economic emphasis and content .The Chamber notes that there is considerable overlap between many of the options. Options 3&4 align most closely with the Chambers aspiration to see the plan underpinned by strong economic principles but other Options, say 1(Rail Corridors)&2(Sustainable Travel) would be easily adapted to reflect the Chambers position. The adoption of a dispersed development strategy as set out in Option 5,appears unlikely to be the basis of a long term sustainable development framework that can underpin a growing economy . As noted above caution needs to be applied to embracing rail-based options that depend solely on rail .The whole rail system in the UK remains in a state of flux and national reforms and major investment are required to create capacity to address current operating difficulties. Rail travel is underpinned by complex public and privately operated systems that need to be fully understood in order to develop new and practical rail based growth. We see no evidence that the rail based options set out here have been “stress tested ‘ in terms of feasibility and deliverability. Issue S8. Small Scale Development outside the spatial growth option. Q-8.1&2 It follows from the Chambers comments above that it would strongly support small-scale development outside of the chosen spatial growth option. From an economic point of view it essential that the development strategy facilitates a wide range of growth and maximized opportunity for new job creation in a variety of locations including rural areas and small communities. It whole-heartedly supports the view that small-scale development can play a role in maintaining the vitality and viability of small settlements. This general approach should encompass encouraging the provision of new employment allocations in smaller communities usually rural areas. We would not advocate so called “ threshold approach “, which might unduly constrain and discourage entrepreneurial opportunity. We do not believe that a firm “threshold “ approach gives sufficient flexibility to meet all circumstances. Here the thrust seems to be focused on housing and not commercial development.

No

Nothing chosen

No

The Chamber has commented in a separate submission on much of the detail in the HEDNA. Generally we would caution against an overreliance on a statistical set of projections .It is noted that the Governments National Planning Practice Guidance (NPPG), which was updated in July 2021,is intended to set out how the government’s NPPF policies are expected to be applied. Paragraphs 025-032 of the NPPG deals with best practice in determining Economic Needs Assessments for development plans. While the work carried out by the consultants who produced the HEDNA appears comprehensive, the Chamber is unsure how closely the guidance has been followed to produce and calculate the overall growth requirements in the HEDNA? Two examples are: (i)The NPPG places emphasis on the use of market signals and market intelligence data –preferably drawn over long periods of time. While consultants were employed as part of the process of determining the overall numbers, the text suggests that the market intelligence used is largely a snapshot rather than a long term analyses .The is no reference to the 2019 sub regional C&W Market Signals Study (referenced above )which both LA’s were parties to and which sets out a thorough evidence based related to market signals for all local authorities in the sub region. (ii) The NPPG contains guidance on methodology and approach to planning for logistics and distribution sectors in para 031. Again the Chamber can see no detail or evidence how the plan preparation has followed the recommended approach or sought to obtain evidence base to inform the approach. Instead the table sets outa separate target figure and no detail relating to what evidence supports this or how it was determined? The previous adopted development plan (2011-2031) frameworks for the Coventry and Warwickshire sub region seriously underestimated the overall demand for employment land and made incorrect assumptions about the take up of new land allocations .They also failed to recognize that a substantial “pool ‘ of sites of varying types is essential to achieve a healthy employment market with a turnover of properties that allows growing businesses to expand and not relocate out of the area. We advocate more detailed evidence based work and adherence to national methodology relating to likely levels of market demand for all sectors .In, addition as noted above it is essential that overall performance is monitored.

selected

selected

selected