Issue and Options 2023

Yes

Issue B1: Areas of Restraint Please select the option which is most appropriate for South Warwickshire Q-B1 Option B1a We consider that Areas of Restraint are an affective policy tool for ensuring development is kept free of identified development parcels. This has been a long-standing policy commitment in Stratford and, for consistency, this should be applied to Warwick too. It would allow for a hierarchical approach, which is embedded in the NPPF, and as such would be consistent with national policy. The precise Areas of Restraint should be the subject of thorough evidence base testing and consulted upon as the SWLP advances. Issue B5: Environmental Net Gain Q-B5 a We consider that the work should be undertaken by the Council to explore and potentially pursue an integrated Environmental Net Gain Policy which will support nature’s recovery. We are aware of the governments Environmental Improvement Plan 2023 which seeks to halt and reverse the decline in nature – in the reaching of this goal, there should be a reduction in environmental pollution which would include noise, water quality, soil, carbon capture. One policy to deal with these elements seems sensible. As always though, any such policy would need to be evidence tested and thoroughly consulted upon. There would also need to be an awareness of the implications on viability – if overly onerous, the policy could act as a real dis-incentive for developers, who would seek instead, to build outside of South Warwickshire. Issue B8: Agricultural Land Q-B8.1 Do you agree that the plan should include a policy avoiding development on best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefits of development? Yes. We recognise the importance of BMV in considering development proposals. However, any such loss of BMV needs to be balanced with the competing – and highly important – need to deliver housing and other development. Any policy which restricts the loss of BMV would be inappropriate, and beyond the scope of the NPPF which would fail the tests of soundness. It is however appropriate to provide a policy which recognises the importance of BMV but allows for its loss where it is outweighed by the need for new development. Issue B9: Protecting Biodiversity and Geodiversity assets Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites? Yes – although SSSIs are protected by national policy. Paragraph 175 states that plans should distinguish between the hierarchy of international, national and locally designated sites, and on this basis such a policy should be included.

Nothing chosen

Issue P1: Part 1 and Part 2 plans We agree with the proposed broad content of the Part 1 plan, which would deal with the vision, strategic objectives, growth strategy and strategic policies. This approach, in our view, could expedite the plan making process, provide clarity and certainty for developers and allow a focus on the strategic priorities. However, we do continue to have reservations as indicated to our response to the scoping consultation, repeated below. In splitting the Local Plan out as envisaged, it is important that the part 1 Local Plan progresses on its own LDS programme/timetable and advances to adoption as expediently as is reasonably possible. It would not be appropriate for the part 1 Local Plan to be delayed to tie in with an LDS programme in relation to other elements of the Development Plan. It is also important that the part 1 Local Plan is the subject of its own examination – by way of example, in North Essex the three Councils submitted both their part 1 and part 2 Local Plans concurrently, and because the part 1 Local Plan was significantly delayed at examination stage (and significantly altered through the examination) it caused a follow-on significant delay to the part 2 Local Plan without the Councils being able to make any changes to part 2 plan content. It is also the case that deferring all allocations to later parts of the Development Plan relies upon those later parts being found sound. Were that not to be the case, the result would be a defined development strategy and housing and other development needs but no delivery mechanism absent of any positive allocations to implement the part 1 requirements. This is precisely the trap South Kesteven fell in to with their Development Plan – the Core Strategy identified a development strategy heavily reliant on Grantham (with over 50% of the entire plan period housing to be delivered at Grantham) and allocations deferred to an AAP. The AAP was found unsound at examination, and with no ability to deliver housing at Grantham the Council were faced with unplanned housing applications to determine.