Issue and Options 2023

No

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 North of Leamington Road, Long Itchington 9.1. Rainier Developments is promoting land north of Leamington Road (West), Long Itchington for residential development, inclusive of on-site green infrastructure. 9.2. The land comprises a single agricultural field. The northern, eastern and southern boundaries are defined by existing boundary vegetation and the western boundary adjoins an existing access track. The site is north of Leamington Road, the south of this road is characterised by residential development. To the east of the site, land north of Leamington Road is characterised by existing residential development. A site location plan is enclosed at Appendix 1. 9.3. The site is immediately adjacent to the village and would benefit from good access to local services and facilities including, for example, the Cooperative food store, various pubs, bus stops and the church. 9.4. The accompanying Illustrative Masterplan (see Appendix 3) shows how the site could be developed to deliver circa 60 dwellings. The built development would be concentrated towards the southern and central parts of the site, closer to Leamington Road. This would allow for a significant area of landscaping along the sites northern boundary. The Masterplan also demonstrates how the site could link to the adjacent site to the east which has also previously been promoted through the Site Allocations Plan. Rainier’s position that the sites could come forward either independently or in tandem as a coherent scheme remains unchanged. Sustainability Appraisal SA 9.5. This site is located in Long Itchington which is identified as a small settlement within the SA. The site lies within the area assessed around Long Itchington as shown at Figure C14.1. It is evident from this plan that the site is not subject to any overriding constraints. The site would form a logical extension to the existing settlement and would reflect the character of settlement which is effectively two broadly linear patterns of development either side of the A423. 9.6. The assessment of Long Itchington against the SA objectives is presented at Section C14.1 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 individual site. Each SA Objective is considered with specific reference to the site below: 9.7. SA Objective 1 Climate Change: The site is proposed for residential development and is in a small settlement identified within Growth Options 3, 4 and 5. The Site would benefit from good access to local services and facilities, reducing the need to travel to meet everyday needs which is reflective of the aspiration to deliver 20-minute neighbourhoods. 9.8. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There are elements of surface water flood risk along the sites eastern boundary, this could be addressed through suitable design and sustainable drainage systems. 9.9. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as or in close proximity of 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 notes the proximity of Debdale Wood and Spinney Ancient Woodland as a potential negative impact in the absence of any mitigation. This site is not within the 15m buffer requirement for ancient woodland and is some 1.3km away. The closest local wildlife site is to the north of the recreation ground and is well separated from the site. The majority of the local wildlife sites and priority habitats in Long Itchington are to the east and south of the settlement. 9.10. SA Objective 4 Landscape: Previous assessments prepared in support of the Stratford Site Allocation Plan have noted that the southern portion of the adjacent site (to the east) was considered deliverable and that suitable landscape and visual mitigation could be achieved. Rainier have made previous representations to this document and accompanying assessments that the same would be applicable to this Site and are confident that appropriate mitigation could be achieved. A Landscape Note (enclosed at Appendix 4) confirms that a scheme on this Site could incorporate an appropriate and robust strategy for landscape mitigation. 9.11. SA Objective 5 Cultural Heritage: The site is not located in proximity to any designated heritage assets. The majority of listed buildings in Long Itchington are located to the south, around Church Road. This is also the focus of the Conservation Area which includes part of Leamington Road, to the east of Chaters Orchard. The site is well separated from the designated assets and the CA by existing built development. 9.12. SA Objective 6 Pollution: The site is not located in proximity to an Air Quality Management Area. The A423 which bisects the settlement, running north/south generally through the middle of the village, is identified by the SA as the main pollution source. The site is well separated from the A423, including by existing development, and any associated noise and air quality mitigation required could reasonably be expected to be minimal. 9.13. SA Objective 7 Natural Resources: It is acknowledged that the land at Long Itchington is a mixture of Grade 2 and Grade 3 agricultural land. However, the site is reasonably smallscale compared to the wider agricultural land in this area and the loss of agricultural land associated with this site is not anticipated to be significant when considered in the wider context. The entire settlement is within a Mineral Safeguarding Area (MSA). In common with the agricultural land, the development of this site is not significant given the scale of the MSA. It is also notable that the site is immediately adjacent to existing residential development on Leamington Road and therefore is unlikely to be suitable to mineral extraction given the associated impact on 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: The site benefits from good access to existing recreation and greenspace within the village. The closest health facilities are in Southam, which is accessible by an existing bus service. 9.17. SA Objective 11 Accessibility and 12 Education: The site benefits from existing bus stops which provide a regular service to Southam, Napton on the Hill and Leamington Spa. It is important to note that development in settlements such as Long Itchington is important in supporting the ongoing viability of existing services and securing improvements. The village has a primary school, located on Stockton Road, with secondary and further education facilities located in Southam which is accessible by bus. 9.18. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities in the local area. Summary 9.19. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.20. The site benefits from a sustainable location on the edge of Long Itchington and is well placed to meet the housing needs of the village and the surrounding area. The site is wellplaced to ensure easy access to a range of local services and facilities including public transport. 9.21. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.22. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.23. Rainier have a land interest in the Site and are promoting the site for residential development. The Site has already been submitted as part of the Call for Sites exercise associated with the Scoping Consultation in 2021, and accompanying representations were also submitted. 9.24. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.25. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.26. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.27. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.

Nothing chosen

2.1. As set out in response to the Scoping and Call for Sites consultation, Rainier 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. Rainier 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.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, nvironmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, however it is recognised that at this stage the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

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Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.

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3.20. Wellesbourne is assessed as a whole for the purposes of the Settlement Design Analysis which forms part of the Council’s evidence. The site is not assigned a parcel number and so there is no specific connectivity ranking. The site should be assessed as part of the settlement analysis as it has been submitted through the Call for Sites process. The site is not identified as having any landform constraints. The adjacent Persimmon developments are identified as having a mix of inner suburb (40-60 dph) and outer suburb (20-40 dph) densities. It is likely that this site would reflect outer suburb densities.

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Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Wellesbourne is identified as one of 22 small settlements. It should be noted that the ‘small settlements’ are the only areas assessed at this stage aside from seven broad locations for developments (the largest seven settlements across the Districts) and potential new settlement locations. It should be noted that small settlements are sustainable locations for development. The Site would allow for a sustainable development close to existing services and facilities. 3.18. As set out in the Sustainability Appraisal at Table 5.1, Wellesbourne scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Wellesbourne against Education and Accessibility. This is discussed in more detail in following sections however Wellesbourne has a primary school and has the Wellesbourne Campus of the University of Warwick located north of the main village. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Wellesbourne would assist in supporting and likely enhancing the existing public transport provision which would mitigate any accessibility concerns. 3.19. It is clear that this Site(Call for Site ref: 463) is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.21. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.22. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.23. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.24. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.25. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.26. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.27. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.28. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.29. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward.. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.30. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.31. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.32. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.33. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.34. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.35. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.36. For example, the development boundary for Wellesbourne should be reviewed which would allow for the inclusion of this Site (Call for Sites ref: 463) within the development boundary to deliver sustainable residential growth.