Issue and Options 2023

Thank you for the opportunity to submit representations to the Issues and Options stage of the South Warwickshire Local Plan Part 1. Stoford have prepared these representations following discussions with the Birmingham & Solihull Rugby Football Club, and adjoining landowners, covering some 50ha of land to the south east of Junction 3, M42. The land is on the edge of Stratford District’s boundary with Redditch/Bromsgrove and is in part bound by the A435 which is a key investment corridor for the neighbouring Districts and one of only two locations where the M42 can be accessed from within South Warwickshire. Stoford are supportive of the decision by the two Council’s to prepare a Joint Local Plan and see this as an opportunity for the key infrastructure linkages that serve both Districts, being maximised and underpinning a spatial strategy. The M42/M40 and rail connectivity within the Districts’ offers the potential to be the basis for some of the Local Plan’s key strategic employment sites. Stoford participated in the earlier stakeholder events held in 2022, and it was interesting and helpful to undertake the exercise of considering the spatial distribution of growth, and to see how this has now informed the five spatial options presented in the consultation material, and the consideration of new settlements. Clearly the challenge for the Local Plan is accommodating growth, but also considering how the Green Belt will interplay with that. The majority of the railway stations for example – that are crucial to achieving active travel and addressing climate change through non motorised single occupancy trips, are located within the Green Belt, as are junctions 3 and 3a of the M2, and junctions 16 and land west of 15 of the M40. In our view, in order to maximise the opportunities presented by the M42 and connections from there to the wider motorway network, and to encourage increased commuting by rail, development sites will also be required to be released from the Green Belt within South Warwickshire in addition to non-Green Belt sites adjoining existing towns/settlements. New Settlements Issue S5 within the consultation material concerns the potential for new settlements and the contribution these can make towards the necessary growth required over the Plan period. The adopted Stratford Core Strategy included two new settlements, and these have since commenced development and are positively contributing towards the delivery of new homes, and jobs within Stratford District. Gaydon Lighthorne Heath was one of these, located on the edge of the District and adjacent to the M40. The location of our promotion site at J3 of the M42 is similar in nature – being located close to a motorway, on the edge of the District – but is equally in our view more attractive as an option for development, given the proximity of local rail connections. Our enclosed promotion document includes circa 50ha of land that Stoford consider could be developed for strategic employment uses. Adjacent land could contribute towards a new settlement – noting the potential option A1, within Figure 12 of the consultation material that identifies a possible location for such a settlement being between the areas of Earlswood and Henley in Arden. Stoford agree with question S5.2 of the consultation material, that new settlements should be part of the overall strategy and it is important these are linked with new strategic employment land too, in order to maximise the potential for these settlements to be sustainable and reduces the need for travel. Stoford also support the potential to look at rail corridors and the role that they can have in supporting potential locations for development. Where rail corridors (and stations) are located alongside other key infrastructure such as motorways and A roads, there are opportunities for these locations to be explored for sustainable development. Stoford advocate that land to the southeast of junction 3, M42 is such a location. The attractiveness of this location for commercial development, particularly industrial and logistics is unique for this stretch of the M42 within Stratford, given it is the only junction with this motorway within South Warwickshire. Green Belt Boundaries We note that Issue S6 introduces the potential for a Green Belt review. We agree with the commentary on page 56 of the consultation material that states ‘In identifying locations for development across South Warwickshire including those currently within the Green Belt, the need to address climate change and deliver a sustainable pattern of development is a critical factor.’ We agree that when determining the spatial strategy for South Warwickshire that the most sustainable strategy should include options that release land from the Green Belt, where that land is well connected with infrastructure and has the potential to deliver jobs, and potentially homes, with travel options that can be non-motorised.

Viability and Deliverability Issue I5 within the consultation material seeks comments regarding sites being viable and deliverable. It is important that allocations are deliverable and market attractiveness and location will have a significant role to play in deliverability. It is notable for example that Startford-on-Avon’s 2016 Core Strategy allocated 10ha of land at Atherstone Airfield which still remains without planning permission. The site is located away from the main motorway and A road network and it is therefore less attractive to the market than other sites such as Redditch Gateway which have been part completed and the residual (south site) commences construction this Spring. The land that Stoford are promoting to the south east of junction 3, M42 is more akin to Redditch Gateway. The A435 is a strong link to the M42, and in turn the location is attractive for companies seeking direct access to the midlands motorway network. In addition, the significant benefits of this location are the opportunities for pedestrian and cycle connections that can be improved to serve the local railway stations of Earlswood, Wood End and Danzey – which are on the direct line through to Stratford, Birmingham and intervening stations.

Yes

Yes

No answer given

Appropriate strategy

Nothing chosen

Appropriate strategy

Nothing chosen

Nothing chosen

selected

selected

selected

selected

Economic Needs The HEDNA shows that 345ha of office and industrial land is required across South Warwickshire to 2050. In addition, South Warwickshire will take a proportion of 709ha that the HEDNA identifies is required to be distributed for B8 purposes. Stoford await the Council’s apportionment of this figure before offering further comment on whether the needs of the two Districts are being catered for sufficiently. Stoford note the options at Q-E3 within the consultation material, and we support a policy approach that sets out the overall employment land requirement, as opposed to a criteria based policy that would limit provision to certain sectors. It is important that the Plan remains flexible, and able to respond to changes within the market, especially given the prior of the Plan to 2050. Core Opportunity Area and Major Investment Sites Within Issue E7 of the consultation material, the matter of the Core Opportunity Area (COA) (Figure 21) and Major Investment Sites is discussed. The supporting text on page 88 states: The Core Opportunity Area looks to attract inward investment to drive the South Warwickshire economy as well as encourage inward investment in the most accessible parts of South Warwickshire. Stoford believe that the COA could be extended to include the area of land centered around junction 3 of the M42. This could extend either side (north and south sides) but would enable this key motorway junction, served by local rail stations including Earlswood and Wood End, to deliver on this aim of attracting inward investment and being one of the most accessible areas within South Warwickshire. The strong rail connections, bus route (along the A435) and motorway junction underpin this view. We accept that the area if selected may not necessarily be joined to the COA proposed boundaries, however this should not detract from the facts that this location is comparable and in many cases performs better in terms of sustainability, than other areas on the fringes of the proposed COA. Therefore, in response to Question E7.1 of the consultation material, as it currently stands, directing employment (which we take as all employment) to the COA proposed, is rather limiting and does not take the Plan to a position whereby opportunities for responding to market signals and securing strategic employment sites within walking and cycling distances of rail stations are taken account of. Stoford do acknowledge the role of the COA, however this should either be extended to fully apply to the most accessible parts of South Warwickshire (which it currently doesn’t); or, any such policy for directing employment to the COA, should not be limiting in its approach. Therefore, being clear that there are places currently not in the COA, that offer equal or better levels of accessibility and have a stronger market facing presence. Stoford also support the proposition of question E7.2, that recommends Major Investment Sites (MIS) could cater for additional employment needs. We would add that the suggestion of sites being used for ‘specific employment uses’ only is exercised with caution. We note the JLR site at Gaydon Lighthorne Heath for example and how this site has been effectively kept aside for one specific end user. In locations where this is associated with a major employer already located nearby, this is understandable to a degree, however new MIS if pursued should not stand mothballed and undeveloped from one five-year period to the next. Any criterion should allow for the review of the site and the specified uses, thus allowing for changes within the market sectors to be fully accounted for and not ruled out because of an overly restrictive policy/allocation. Further details on the suitability of land south east of junction 3, M42 are included within the enclosed Vision Document, submitted alongside this letter of representation.