Issue and Options 2023

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No

Issue E8: Existing Employment Sites. Q-E8 .1.E-8.2-8.4As noted throughout this representation we fully support the protection of employment land assets of all types and sizes. However, the Chamber is concerned with the proposal to simply “roll forward “ all existing employment allocations without any evidence that these have been reviewed and fully understood. There area number of prominent sites where we see no evidence that the sites are likely to come forward. Therefore retention of such sites as part of the overall employment allocations is, in effect, reducing the quantum of allocated land. We do not wish to go into great detail on each of these sites but sites at Kenilworth, Stratford Road Warwick, and the JLR “reserve “ at Gaydon -all good examples where there is no apparent evidence related to likely timing.In terms of the latter site, as recognized in the text this site /location represents a highly significant potential land resource alongside the M40 motorway. The land offers great potential for a wide range of commercial and employment uses. Continuing to “reserve ‘ the land for one particular user and in which JLR have no legal interest seems wrong. In contrast the proposals set out to review and maintain a modified Atherstone Airfield allocation appear appropriate and are supported (ref Q-E8.1).

Yes

(Q-E8.3, 8.4) In terms of testing retention of business premises and land against marketing, viability and alternative tests we support this type of policy. There are examples across much local plan area of these policies and it is apparent that some policies are more effective than others. It is noted have noted above that the adopted Rugby BC local plan contains in Policy ED1 (Protection of Rugby’s Employment Land) a comprehensive “test “ based policy that appears robust and effective in protecting employment land and sites. The Chamber would strongly advocate more research and liaison with local authorities that have operated this type of policy. For example, different degrees of rigor in terms of marketing time periods are evident in the policy examples and it seems essential that marketing evidence is properly documented and carried out of a reasonably long period of time .The Chamber would be happy to discuss this further with local planning authorities.

Yes

Issue E2 .A low carbon economy:QE-2 a,b,c The Chamber supports the general sentiments set out in the document on these issues. It supports efforts to cncourage businesses to move to Zero carbon but wishes to understand how resources might be directed to this general objective?However.it also considers that detailed “over prescriptive” policies aimed at particular sectors may not be effective. Indeed it is also important to appreciate that such policy relating to low carbon policy making may, inadvertently, impose additional costs on local businesses. This is particularly true of small businesses that make up the majority of the sub regions enterprises. If policies are to be brought forward to address low carbon initiatives these need to be carefully coasted, be introduced on a phased basis and their likely overall impacts set out in the supporting evidence with reasoned justification. The Chamber would welcome further discussions on this important matter and we would wish to explore what resources are available to assist the shift over to low carbon across a range of sectors in the local economy. As noted small business is generally less well equipped to deal with policies that carry costs burdens. Option E2 (a). There is merit in the overall aspiration here to create employment areas where similar or compatible business can co-locate together. There is a danger that too much prescription may stifle business innovation and entrepreneurial activity. Option E2-b.It is difficult not agree with the general sentiment. However operating such policies at a local level when surrounding areas do not have such requirements risks driving business away to local authority areas without similar requirements. Issue E3. Diversifying the economy. Q-E3 Achieving these aims across the whole economy is seen as important. Across the West Midlands and across the local plan area there are a number of business development organisations and regional /national initiatives aimed at assisting the diversification of local economies. Any policy framework needs to be integrated with the work of these organisations and authorities and the access to resources they might provide. Q E3c .On a matter of detail raised, the Chamber does not favour the use of Section106 provisions to regulate the recruitment of staff ,initially favouring locally recruited workers. There are well-documented widespread labour shortages and disrupted supply chains in some key sectors of the national economy. This is also true of the local economy. The imposition of this type of restriction would hold back immediate progress of new development schemes. There is experience of these policies across Greater London and that they have inadvertedly led to delays and imposed costs on businesses. Issue E4.Sustaining a rural economy. Q-E4.1-4.2 The existing policy framework of the two adopted local plan areas seems appropriate at the strategic level subject to combining these in an appropriate way. The Chamber wholeheartedly supports the continued development and diversification of the rural economy. The general sentiments set out,are difficult to argue with .The Chamber is unsure of what additional measures can be captured in land use planning policies and which do not run a risk of stifling innovation and entrepreneurial activity .Development management policies and the current Use Classes framework allow considerable flexibility in repurposing spaces for new uses .As pointed out ,resources are an important consideration in developing the rural economy and a multi agency approach by the public sector is essential .If land uses policies that encourage cooperation between agencies can be developed that would seem a major benefit. Overall, while there is no harm in general policy that encourage and support more small-scale rural businesses, the Chamber cannot see the benefit or added value in more specific policies without a linkage to resources and particularly financial support. Support for small business is essentially an inter–agency operation and there is no evidence that this has been factored into the text outlined. Issue E5: Lack of Business Accommodation. Q-E5 a&b. This is an issue of central importance to the Chamber. Some currently sectors do suffer from a shortage of suitable premises and accommodation .In part this may be addressed through additional allocations but often there is an issue of affordability. The following key principles need to be adopted • Greater protection of existing business areas and premises so they are not “ lost “ to housing development. • Policies that encourage and facilitate the repurposing of retail units for a wider range of commercial activities. • New allocations for “affordable “ small scale “ activities. • Support the provision of the widest possible range of business units including the upgrade and modernisation of existing stock . The Chamber is not clear, on the basis of the commentary set out here, what benefits accrue from general policies as suggested. There is a good analysis of the problem in the text but the Chamber is not clear what solutions are being advanced to address the difficulties identified? The current policies in the two adopted local plans should be dovetailed and rationalize to produce one set of consistent and clear policies. Issues E6&7.Core Opportunity Area (COA) and Major Investment Sites(MIS) Q-E6a&b ,E7.2 a&b. As listed in the consultation the new plan area should contain a number of important economic assets that should be nurtured and where appropriate expanded over the plan period. Rather than a general policy to “blanket” these assets, the Chamber favours specific and targeted policy individual site frameworks for some but not all these important assets .For example, the Chamber is aware of the benefit created by the policy in the current Stratford Local Plan that seeks to protect and develop Wellesbourne Airfield. This has proved important in the defence of the County’s last remaining hard runway based airfield –an asset that increasingly has considerable future economic development potential. The principle of directing growth to a particular general part of the plan area –the Core Opportunity Area is only likely to be effective if the land use policy framework is aligned and supported by a full range of policy initiatives and fiscal support measures including inward investment, national and regional grant focus and a concentrated focus on the chosen area and sites by all public agencies. This requires “buy –in “beyond the scope of land use policies. The cooperation of Warwickshire C. C. (WCC) and the West Midlands Combined Authority (WMCA) in this initiative is essential. On the basis of the limited information given here, we do not favour prescriptive policies seeking to channel growth towards the Core Opportunity Area. We support the principle of allocating additional land adjacent to the MIS where appropriate (Ref Option E7.2a7b). However this should take place against the background of a thorough overall review of each of the major MIS areas. Issue E9. Supporting our changing town centers. Q-E9a&b By common consent, this issue is a high priority short-term challenge not only across this plan area but also generally across the UK. Here policies encounter strong market forces, which are altering the content, function and operation of town and district centres. There are questions about how much land use planning can alter these market dynamics. The text of the consultation document summarises the challenge and largely the Chamber supports the approach outlined subject to rationalizing and aligning the current policies in the two plan frameworks. We agree that many of the issues are appropriate to detailed planning guidance and would sit comfortably in Part 2 of the new plan .In an addition there are many issues here covered by the application of the Use Classes Order. For example, it might argued that the changes enacted to the Use Classes Order in 2020 and most notably the introduction of new Use Class E has weakened the ability of the land use planning process to control and change town centres and other similar retail concentrations. The weaknesses created by the new broader Use Classes framework needs to be considered and a range of possible measures considered. The new plan should adopt a more “sectoral ‘disaggregated policy approach to town /district centre uses, that moves away from a reliance on a Use Classes Order that is not able to discriminate between sectors and simply favours the change of use of land to that with the highest use value. There are good examples of these weaknesses that have unintentional consequences. a)The shortages of open storage land and spaces has serious consequences for the operation of communities. Over the past seven years these shortages have created steep rises in land values .It is important for land use planning to seek to protect remaining stocks of storage land and premises so that built up areas can function efficiently. This will have an additional benefit that travel (and freight) movements are minimized. However brown field land policy and general allocations for employment land mean that storage space continues to be lost to higher values.It is rarely protected as the asset that it represents . A more sectoral plan framework is required. - b) Similar problems arise with low density commercial land uses uses such as R&D space and indeed some types of new office space .Often these specialist low density uses cannot compete with pressures from other high value uses notably housing and distribution land .The operation of general Use Classes based policies does not protect some key sector employment needs and in particular land required by small scale “start ups”and “niche” specialist scientific businesses. Consideration should be given to further encouragement by appropriate policies to the “repurposing “of town and village centre retail buildings for other employment uses and policies that seek to selectively resist change from retail to residential which is facilitated under the new Use Classes Order (2021). Already in some of the larger towns in Warwick and Stratford Districts there is evidence that market forces have allowed under new class E, some former shopping units to be converted to small business premises such as offices and workshops .If these market trends could be treated more “sectorally’ and aligned with more financial support measures this could improve the stock of employment land being better aligned to changing needs. Issue E10. Tourism. Q-E10 The Chamber fully supports the further growth and expansion of the visitor economy and tourism. The development plan framework must positively support this development. We agree with the broad sentiment of the consultation that the role is “spatially non- strategic” and that Part 2 of the proposed joint plan will be an appropriate place to address most issues of the development . Issue E11.Any other economic issues about SW economic needs. Q-E11 As noted above we believe the monitoring and measurement and, if necessary, the subsequent alteration of the Plan’s economic policies is an essential ingredient of an effective long-term plan for the area. The use of detailed “Market Signals and Intelligence ’ as exemplified in the 2019 SQW Study(referenced above) sets out many appropriate parameters that should be looked. These submissions have pointed out the deficiency in the broad approach to planning for employment land using Use Classes –there are deficiencies in the broad classification of the new Use Classes and they are often too broad and general.as noted, generally the Chamber favours a more detailed “sectoral “approach . A good example would be logistics and distribution .The Chamber sees merit in the approach employed in Leicestershire, whereby rail based distribution is treated separately from road based logistics and distribution. The Chamber favours greater commitment to rail based logistics and distribution. This would accord well with the general objectives in the plan to align policy to decarbonize transport and remove freight from the road network. The Chamber sees merit in establishing an effective monitoring based measure or target, based around developing a “5 year employment land supply test “.This would apply to the plan area .It would draw on parallels from housing policy where this measure has been a long term metric. This initiative would require that the plan has, at all times, a readily available 5 Year Supply of new employment land ready for take up /implementation in the market .In the Chambers view this would represent an easily measurable metric capable of monitoring and equip the area with a range of immediately available land opportunities. The Chamber is aware that the concept of “5 year supply” relating to housing policy may be removed by changes to national planning policy .In this event it recognizes there may be reluctance to introduce the concept for employment land .As an alternative consideration should be given to the introduction of “criteria based” policies to control the provision for specific sectors. Good examples of such policies can be found locally in development plan policies for North Warwickshire (ref Policy LP6, Additional Employment Land In North Warwickshire) and NW Leicestershire (ref EC2 .New Employment Sites in NW Leics ) The Chamber considers these types of policy approaches depend on monitoring and measurement across the plan. This would assist Inward Investment to the area and align well with the work of the Inward Investment and business development agencies that are active across the area

Yes

Issue Q-H1-1. Following on from the importance of the link between housing and the local economy, the Chamber supports the use of the “trend –based “ approach/methodology in establishing the appropriate level of housing requirements .The alternative (2014- based household projection method)set out would seem to “bake in “ a shortfall of housing relative to recent market performance. This could lead to undesirable consequences for the local economy.

Issue H2.Q-H2-2a&bThe provision of a supply of Affordable Housing is by the same token an important ingredient of a balanced local economy .The draft recognises the challenge of maintaining a sufficient supply of affordable housing. Section 106 agreements have provided a major source of deriving affordable homes associated with the development of larger scale housing developments. This must continue and the Chamber would caution against an alternative approach where the mechanism of S106 agreement’s to achieve this provision is abandoned .In addition, the Chamber would welcome further initiatives created by joint working with other social housing providers and any initiative to directly build more local authority housing stock that can be effectively controlled by local authorities.

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No answer given

Yes

Issue H4; Sub Regional Housing Provision. In principle, the Chamber supports a regional approach to the provision of both housing and employment provision. Thus it follows that where south Warwickshire may agree or is required to take additional housing and employment provision from surrounding areas it should do so.

Ref. Q –H4-1-3. It is, of course, a matter of regret that no formal sub regional mechanism exists as part of the formal land use planning process . However, the Chamber fully supports the continuation of the strong cooperation, joint working and liaison across the region and sub region that has characterised the period since 2011.It is essential that this continues across the next plan period .It is regrettable that the development plans across Coventry and Warwickshire are not moving in step in a coordinated manner. However there is an opportunity for this joint plan “to set the agenda” for the subsequent local plan reviews across the Sub –region.

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The Chamber is supportive to the objectives set out in this Chapter. It recognizes and acknowledges that the Plan has a role to play in tacking the climate change. However, it must be emphasized that the introduction of measures and policies must always be fully costed and their impacts on business and commerce be properly understood before measures are adopted. As we have continually emphasized in this submission, small businesses that are the lifeblood of the economy of the new plan area, are not always well equipped to bear the impact and consequences of new policy initiatives. As pointed out elsewhere in this submission, the Chamber is concerned that if policies to move to Zero Carbon are not replicated in surrounding areas then they may create the unintended consequence of encouraging business to relocate to nearby areas where new initiatives have not been introduced.

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