Issue and Options 2023
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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…" 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
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 Milcote Road (West), Welford-on-Avon 9.1. Rainier Developments is promoting land north of Milcote Road (West), Welford-on-Avon for residential development. 9.2. The land is currently a single agricultural field. The eastern and western boundaries are defined by existing hedgerows, the northern boundary by a tree belt and the southern boundary by Milcote Road. Immediately adjacent to the site to the west is a recent residential development (known as Milcote Close). There is also a large residential dwelling to the south of Milcote Road, opposite the Site. 9.3. The site is not in the Green Belt. The site is located within Flood Zone 1, land at least risk of flooding, and does not include any significant areas of surface water flood risk. The Site is not located in close proximity to the Welford-on-Avon Conservation Area or any designated heritage assets. 9.4. The site was assessed as part of the SHLAA 2021 Update (Welford-on-Avon, Site 9A). In terms of suitability, it concluded that the site was technically suitable for development but commented that in terms of environmental suitability that “Landscape Impact. Impact on settlement character. High quality agricultural land.” It also noted under scope for mitigation that the site forms part of a strategic gap between Welford and Weston in the made Neighbourhood Plan. 9.5. The technical suitability of the site is not disputed. In terms of landscape impact and impact on settlement character these are matters which could be resolved by a carefully considered, landscape-led design. The development of Milcote Close means that this site now directly adjoins the built-up area of Welford. Development of the site would not extend the settlement pattern beyond the eastern edge as established by Chapel Street and Pool Close to the north and Milcote Road to the south. 9.6. It is acknowledged that the site is included within strategic gap as defined by the Neighbourhood Plan. However, the site forms a relatively small part of this gap. The Site is well separated from Weston on Avon and is significantly smaller than the site of the proposed Gladman scheme referred to in the supporting text to Neighbourhood Plan policy HE6. This scheme included the adjacent, larger field and would have extended further east, beyond the existing settlement pattern. This proposal was also for a significantly larger number of dwellings than this Site could accommodate. This Site would be more akin to the development of the adjacent Milcote Close than the Gladman proposal and the larger agricultural field to the east does not form part of this Site. This would also reduce the amount of agricultural land which would be developed. 9.7. The accompanying Illustrative Masterplan (enclosed at Appendix 4) shows how the site could be developed, with built development shown towards the western boundary (adjacent to Milcote Close), with looser development across the site and a landscape buffer along the eastern boundary. The area adjacent to the northern boundary is also shown as a landscaped area which could accommodate sustainable drainage and an on-site play area. The Masterplan shows how the existing boundary planting could be retained and enhanced. The Masterplan shows how the site would read as a rounding off of the existing settlement and could be developed to form an attractive settlement edge to Welford-on-Avon. 9.8. The South Warwickshire Plan presents the opportunity to review all designations and ensure they remain appropriate. Welford-on-Avon is a sustainable settlement with a range of local services and facilities including a primary school, post office & convenience store, pubs and allotments. There is also access to public transports with bus stops providing a service to Stratford-upon-Avon. It is clear that Welford-on-Avon is a sustainable location and should be allocated appropriate growth as part of the South Warwickshire Local Plan to secure the continued viability and vitality of the settlement and deliver development to meet housing needs, including affordable housing. Land north of Milcote Road is suitable to deliver residential development, including affordable housing, and should be included as an allocation. 9.9. At this stage, the Sustainability Appraisal (SA) does not consider settlements outside of those identified as Broad Locations, Small Settlements and New Settlement Locations. Whilst it is acknowledged that the Plan is at an early stage and the SA will evolve as the Plan progresses, it should assess the settlements identified within the ‘dispersal’ option to ensure that reasonable alternatives have been properly considered. Summary 9.10. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.11. The site is not subject to any designations or constraints that would preclude the development. The Illustrative Masterplan demonstrates that an appropriate design could be achieved on site to deliver a sensitively designed scheme which responds to the site’s location. 9.12. The site is well located adjacent to the existing built edge of Welford-on-Avon and a sensitively designed scheme would respond to and reflect the settlement pattern established by existing development to the north. 9.13. 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. 9.14. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.15. Rainier have a land interest in the Site and are promoting the site for residential development. 9.16. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.17. 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. 9.18. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.19. 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.
Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why 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, environmentally 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 consultation the SA 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 SWLP1 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 and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements and excludes some settlements that should be considered as sustainable locations for growth, such as Ettington. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives.
