Issue and Options 2023

2.1 The Site [land south of M40 J15, Longbrook] comprises two fields on either side of the A429, south of M40 J15. The fields form part of the Sherbourne Park Estate. Both fields are currently in arable use. The western field is roughly triangular in shape with an area of 9.04 hectares. It has significant frontage to the A46 (Stratford Road) and the associated M40 J15 roundabout to the north, Watery Lane to the west, and the A429 to the east. The southern boundary is shared with private residential land. 2.2 The eastern field is irregular in shape with an area of 6.78 hectares, owing to the meandering flow of Longbridge Brook, which defines its eastern boundary. The western site boundary includes significant frontage to the A429 and a local access road serving a Highways England depot. This access is also part of a National Cycle Route (Route 41) which crosses the M40 to the north. 2.3 The site is located in a sustainable location, within close proximity to the market town of Warwick and Sherbourne village. Sherbourne Conservation Area is located to the west of the Site, as identified in Section 2.1 of the attached Vision Document. Accessibility 2.4 The Site is bisected by the A429, a major road connecting Warwick and Cirencester. Adjacent to the Site, the A429 consists of a single two-way carriageway subject to a speed limit of 50mph. To the north, the A429 connects to Junction 15 of the M40. It is proposed a new four arm roundabout junction would provide access to the Site, which would avoid intensification of site access points, allowing access to both parcels from a single junction. Flood Risk and Drainage Flood Risk 2.5 The River Avon is located approximately 750m to the south of the Site. The Horse Brook tributary of the River Avon flows to the north and along the eastern boundary of the Site. The Longbridge Brook is located 500m to the north east, and the Sherbourne Brook is located 250m to the south west. 2.6 According to the Environment Agency (‘EA’) the majority of the Site is located within Flood Zone 3 (High Probability - Land having a 1 in 100 or greater annual probability of river flooding) and Flood Zone 2 (Medium Probability - Land having between a 1 in 100 and 1 in 1000 annual probability of river flooding). These Flood Zones are attributed to the Horse Brook. However, the Flood Zones are based upon outdated and strategic level data. The Flood Zones do not consider the Stratford Road or the Warwick Bypass which are located upon embankments elevated above the floodplain. Therefore, the current Flood Maps for Planning do not accurately represent the flood risk at the Site. 2.7 To address this, a new bespoke hydraulic model of the Horse Brook was commissioned and has been prepared by BWB Consulting. The model has been reviewed by the EA and it was approved in January 2023. The model is based upon detailed topographical survey of the watercourses and hydraulic structures, and it includes the latest aerial topographical survey (LiDAR) of the floodplain. This hydraulic model provides an up to date and more accurate representation of flood risk from the Horse Brook to the Site and the local area. The model identifies that the western parcel of the Site should be entirely removed from the 1 in 1000-year floodplain, therefore this parcel should be treated as Flood Zone 1. The eastern parcel is also shown to be largely outside of the 1 in 1000-year floodplain, it is only the eastern boundary that falls within the 1 in 100- year and 1 in 1000-year floodplain (equivalent to Flood Zone 3 and Flood Zone 2 respectively). An extract of the approved model is provided in Appendix 2. 2.8 The EA’s risk of Flooding from Surface Water (RoFSW) mapping has also been reviewed which shows a close correlation to the detailed floodplain mapping, giving further confidence that the flood risk to the majority of the Site is low. Surface Water Drainage 2.9 The Site is understood to currently drain through a combination of limited infiltration into the ground and overland flows to the local watercourse, which is expected to be maintained throughout any future development of the Site. Other environmental considerations 2.10 The enclosed Vision Document demonstrates that: • The Site is very much transitional in terms of landscape character, sitting between the majority infrastructure of the M40 and its associated roads from J15. This, coupled with existing robust vegetation along the Site’s boundaries, reduces the site’s sensitivity in landscape and visual terms. Any proposals will include buffering of sensitive receptors, such as a strong landscape framework through a landscape-led masterplan approach. • The Site is not constrained in terms of ecology, it comprises intensively managed agricultural land. There are opportunities for habitat creation to ensure any proposals deliver the necessary biodiversity net gain. • The nearest heritage assets are the nearby Sherbourne Conservation Area to the west, which includes the grade II* Sherbourne Park and grade II* Church of All Saints, along with a number of other scattered listed buildings. There are also three scheduled monuments to the south and east. Any proposals will include increased boundary planting to strengthen the existing well-vegetated edges of the Site to mitigate any potential impacts on heritage assets. Site Suitability for Employment Development 2.11 The Site’s location adjacent to the Strategic Road Network (‘SRN’) is a unique opportunity to facilitate the delivery of employment/ commercial development in a location which will assist in the reduction in carbon emissions and congestion through placing new employment development close to the labour and consumer markets, including Warwick, Leamington Spa, and Stratford-upon-Avon, which are all in close proximity. 2.12 Reflecting on the site’s proximity and sustainable connections to the SRN, Warwick, Leamington Spa, Stratford-upon-Avon and surrounding villages, the Site is a highly sustainable location and can contribute to South Warwickshire’s economic and employment needs. Indeed, it’s location provides connections to the wider supply chain within South Warwickshire as well as being ideally placed to be developed in accordance with the emerging high tech / knowledge industries championed within the Midlands Engine: Ten Point Plan for Green Growth’ (May 2021). 2.13 With regard to flood risk, the Vision Document for the Site (Appendix 1), illustrates how the layout of the proposed employment development will be arranged to avoid the Horse Brook floodplain, thus ensuring that the development is at a low risk of flooding. This approach will also ensure that no floodplain will be displaced and that the flood risk in the wider area will be unaffected by the development. 2.14 Additionally, the development will be offset by a minimum of 8m from the watercourse to the top of the bank, to provide an ecological buffer and allow for continued access and maintenance. To provide further flood resilience, finished floor levels of the proposed employment site will be set at a minimum of 300mm above the 1 in 100-year flood level including the central climate change allowance. 2.15 For surface water drainage, an appropriate Surface Water Management Strategy which complies with the latest local and national advice will be implemented on the Site to attenuate the increase in surface water runoff caused by the proposed employment development. The rate at which the runoff is discharged into the watercourse will be restricted to the equivalent greenfield runoff rate, preventing an increase in flows leaving the Site and thus ensuring that the development does not have a detrimental impact upon flood risk elsewhere. 2.16 Through the application of Sustainable Urban Drainage Systems (‘SuDS’), surface water will be stored within the Site and subjected to stages of treatment to guarantee that the water quality in the wider area is protected. Wherever possible, above ground SuDS will be used to enhance the aesthetic amenity of the development and provide valuable habitats for the local wildlife. The surface water attenuated storage provided will be located outside of the floodplain and appropriately sized to accommodate the 1 in 100-year storm including an allowance for climate change. Example SuDS features that could be incorporated into the proposed development include attenuation basins, filter drains, permeable paving, and swales. 2.17 The Vision Document (Appendix 1) provides further information in regard to the issues and opportunities associated with the Site, specifically in respect of landscape and visual considerations, ecology and protected species, the historic environment, access, and traffic noise; the vision and principles associated with the key deliverables of the Site; and a concept Masterplan.

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3.2 Rainier are supportive of the overall vision of the Plan, which ultimately seeks to meet South Warwickshire’s sustainable development needs to 2050. 3.3 Rainier are however concerned that the Vision does not wholly acknowledge the importance of meeting the employment needs of South Warwickshire and it does not recognise the significant role that employment growth will play in meeting development needs up to 2050. 3.4 The plan’s focus should be equally between housing and employment needs, as both support each other and are integral to the growth of the area. 3.5 Rainier is supportive of the five overarching principles that have been established to underpin the Vision for the Plan; and their land south of M40 J15 will be able to meet these as follows: • A climate resilient and net zero carbon South Warwickshire – Rainier will ensure that any development proposed on the Site will be climate responsive, addressing both operational outputs and embodied carbon so that it does not create more emissions that are offset or stored up. • A well-designed and beautiful South Warwickshire – The design evolution for the Site has been informed by landscape and visual considerations, which has identified key points to be implemented, to ensure that any future development of the Site will be well-screened and there will be no detrimental impact on the surrounding area. • A healthy, safe, and inclusive South Warwickshire – The Site is highly accessible, with good access to existing bus services. Also, the delivery of employment use on the Site will enable several Key Deliverables across the region, for example enhancing the existing cycle route 41, and providing new pedestrian connections, as shown within the Vision Document. • A well-connected South Warwickshire – The Site is very well-connected, in close proximity to the M40 Motorway, which presents an opportunity to support the Midlands Engine (a demonstration of the government’s commitment to making the Midlands a powerful engine for economic growth). • A biodiverse and environmentally resilient South Warwickshire – The Site largely comprises two fields which are considered to be of little ecological value. Issue V2: Vision for Places 3.6 Figure 6 of the Plan sets out the ‘Suggested location for Visions for Places within the Development Plan’; however Rainier have concerns that there is no specific definition for what comprises ‘strategic’ or ‘non-strategic’, i.e., a definition for which policies and site allocations would fall under SWLP Part 1 and SWLP Part 2 respectively. 3.7 It is therefore recommended that the SWLP Part 1 Plan is amended to include a definition for ‘strategic growth’, for example regarding strategic employment sites, these should be defined as sites of 5 hectare or over, and/or 20,000 sqm of office floorspace to be considered in the SWLP Part 1 Plan, and all smaller sites to be considered in the Part 2 Plan. Issue V3: Strategic Objectives 3.8 The proposed Strategic Objectives set out further detail for how the Local Plan Vision will be delivered in South Warwickshire. We support these objectives and have therefore set out how the delivery of employment development on the Site can meet them (where relevant), whilst focussing on high quality design: • Providing infrastructure in the right place at the right time – Future development will present an opportunity to promote active and sustainable travel, enhancing connectivity and infrastructure for business. Opportunities will also arise for multi-purpose green and blue infrastructure including buffer screen planting, ponds, SuDS, and enhanced biodiversity. • Developing opportunities for jobs – One of the key deliverables for the Site is to create jobs that are accessible locally, building on South Warwickshire’s strong and diverse economy. • Contributing towards Net Zero Carbon targets – Rainier are committed to ensuring that the new development will not cause a net increase in carbon emissions and it will be resilient to a changing climate. This includes the provision of an EV charging hub on site. • Creating attractive places – As illustrated on the Preliminary Site Layout Plan (in the Vision Document), the scale and diversity of potential development on the Site seeks to deliver a commercial masterplan which recognises the importance of the buffer zones to protect adjacent conservation and ecological zones. Consequently, the development will be built to a high quality, catering for employment needs and which respect the setting of the surrounding settlements. • Protecting and enhancing our heritage and cultural assets – The Site does not contain any designated heritage assets; however, beyond the Site there are several designated heritage assets, and Sherbourne Conservation Area is located to the west of the Site. The Vision Document therefore appraises how this context provides distinctive place-shaping opportunities for future development and identifies the specific elements that will be considered in the evolution of the proposals for the Site. • Improving the health, safety, and quality of life of our communities – Development of the Site has the potential to deliver wider benefits to the community, including an improved cycle way along the A429, a new pedestrian path linking Sherbourne and Bamford Village, potential to reduce traffic noise, and a significant country park (as shown in Appendix A of the Vision Document) which provides a buffer from Sherbourne Conservation Area. • Connecting people to places – The Site is ideally located for access to the wider SRN and connections to the whole of the UK, including the A429 (a major road connecting Warwick to Cirencester), M40 Motorway (London to Birmingham Motorway), and the A46 (providing access to Cheltenham, Broadway, Stratford-on- Avon, Coventry, Leicester, Newark and Lincoln). • Protecting and enhancing our environmental assets – It is Rainier’s intention to maximise opportunities for enhancements across the Site and specifically, the proposed employment development can mitigate impacts on issues such as drainage, heritage, landscape, and biodiversity and deliver real benefits for the community.

3.9 Whilst a Sustainability Appraisal (‘SA’) has been prepared to support the emerging Plan, Rainier are concerned that the five potential options for growth in the area are all related to housing growth, no option explores how employment needs will be met (this is an issue with the wider plan, as per our response to Q V3.1 and Q S7.2 and the plan’s need to focus equally on housing and employment growth). 3.10 The SA should therefore consider separate options for how employment needs will be delivered and met.

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Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types, and location of development 3.11 Rainier support Option I2a which would result in the SWLP Part 1 Plan setting out the infrastructure requirements for all scales, types, and location of development, to be applied equally across South Warwickshire. 3.12 In light of the new growth required across South Warwickshire up to 2050, new infrastructure is also needed to support this growth, and this should be considered as a strategic matter, as there will be cross-boundary infrastructure requirements. 3.13 Part 1 of the SWLP seeks to set the Vision, Strategic Objectives and Strategic Policies for South Warwickshire and therefore the infrastructure that is required to accommodate this strategic growth should be considered now, at this stage of the plan making process. 3.14 If infrastructure delivery was left to Part 2 of the SWLP, this would create a risk of a fragmented approach to infrastructure delivery across South Warwickshire, which could ultimately stall potential development sites in the future. 3.15 It is therefore recommended that the emerging Part 1 Plan sets out the infrastructure requirements for South Warwickshire now, where strategic site allocations are identified, alongside the infrastructure requirements for the entire plan area. This approach is in accordance with Paragraph 8 of the NPPF which acknowledges the importance of coordinating the provision of infrastructure with the objective of building a strong, responsive, and competitive economy.

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Q-I4.1: Should we include a policy to safeguard specific infrastructure schemes within the SWLP? 3.16 Yes, Rainier would welcome a policy in the emerging Plan that seeks to safeguard specific infrastructure schemes across South Warwickshire. 3.17 Paragraph 11 of the NPPF states that growth and infrastructure should be aligned and as such a safeguarding infrastructure policy is required in the emerging Plan, to align with the strategic growth policies. This approach would also support the overarching Vision and Objectives of the Plan.

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Q-S1: Please select the option which is the most appropriate for South Warwickshire. Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced 3.18 Rainier consider Option S1a to be the most appropriate for South Warwickshire, where information can be used from the soon to be updated Sub-Regional Green Infrastructure Strategy, as well as additional evidence, to help identify Green Infrastructure corridors which can be used to help determine the growth strategy for the wider area. 3.19 Furthermore, Rainier recommend that the plan identifies which Green and Blue Corridors identified within the Plan could be utilised as Suitable Alternative Natural Green Spaces (‘SANGs’). This is due to the statutory requirements of Biodiversity Net Gain (‘BNG’), which requires all new developments within South Warwickshire to compensate for any impacts on habitat, either through enhancing existing habitats or by creating new ones (if impacts are unavoidable). 3.20 It would therefore be beneficial for the Plan to identify the appropriate SANGs that can be used by the developments (that are unable to deliver BNG on-site) which will help South Warwickshire meet its growth needs over the next few years, in advance of the Local Nature Recovery Strategy being produced.

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Q-S3.2: Please select the option which is most appropriate for South Warwickshire 3.21 Rainier support the principle of using brownfield land for development, however it should be acknowledged that there is insufficient brownfield land capacity to meet the growth needs of South Warwickshire up to 2050. Rainier therefore support Option S3.2c above. 3.22 As recognised within the plan itself, brownfield sites are frequently found within town centres, and can therefore often accommodate a higher density development. However, a strategic employment site needs to be located in strategic locations, adjacent to the SRN and other transport options. 3.23 It is therefore recognised that although brownfield land could be prioritised for some development types within the plan (for example, residential development), it is not always the most suitable option for other uses such as employment. Ultimately, the plan should seek to prioritise the most sustainable and suitable sites to meet the growth needs of South Warwickshire.