Issue and Options 2023

No

The Part 1 Plan seeks to cover a very broad range of issues and topics, some of which (as identified through the representations above) are considered to introduce matters which go beyond current national requirements and / or are not yet fully understood (such as “wildbelts”). The logic for following a 2-part Local Plan production process, which necessitates the allocation of fewer sites within the SWLP area in the Part 1 Plan, is also questionable. The NPPF10 requires Local Planning Authorities (LPAs) to plan for, and allocate, sufficient sites to deliver the strategic priorities of the area. BDWH considers that it would be more efficient for the South Warwickshire LPAs to achieve this via progressing a single Local Plan. This would ensure that there is suitable confidence that the infrastructure to deliver all of the housing supply is available and has been suitably planned for. It is not considered to be either necessary or efficient for the emerging Local Plan to be split into two parts. It should also be noted that the Government is seeking to speed up the Plan-making process (as evidenced by some of the proposals being mooted through the Levelling Up and Regeneration Bill) and this does not align with the sort of two-part approach being sought by the South Warwickshire authorities. It is therefore considered that the production of a single Local Plan would be the simplest and most transparent option for enabling the South Warwickshire authorities to provide certainty and demonstrate at the earliest opportunity that it has an up-to-date deliverable Development Plan that can achieve the NPPF site allocation and land supply requirements, backed up with a robust plan for the delivery of infrastructure. 10 National Planning Policy Framework (2021). Paragraph 23.

Savills has undertaken an initial review of the Sustainability Appraisal (SA) which has been produced to inform the Issues and Options consultation version of the emerging South Warwickshire Local Plan (SWLP). The SA has, at a high level, reviewed the sustainability credentials of a number of Broad Areas being considered for development. The land being promoted by BDWH to the north west of Warwick Parkway Railway Station is at the southern end of Broad Area B.30. Savills considers that the SA scoring for the BDWH sub-area is more positive than the stated scoring for Broad Area B.30 as a whole. The Savills proposed scoring for the BDWH sub-area is presented alongside the SA in the table included within the remainder of this Appendix. Below (left) we have included a plan of broad area B.30 – Warwick Northeast, the southern end of which includes the BDWH land at Warwick Parkway (right). It should be noted BDWH acknowledges that a number of the proposed revisions to the SA conclusions relate to its reliance on desktop evidence for a wider broad area, rather than evidence base scoped to review specific sites. [See page 15 to 19 of PDF version of representation - not possible to reproduce table here due to formatting]

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A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it is may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then the Part 2 will need to be in conformity with the SWLP. Itis possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. We are concerned this will delay the delivery of much need smaller housing sites. The Plan Period The preparation of a plan that will run to 2050 is sensible. Having an extended Plan Period will allow for the SWLP to properly respond to long term issues, and support the allocations of larger strategic sites that will deliver homes over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies that can respond to the fact that the local economy and housing needs are likely to change during the course of the period up to 2050.

Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP including a Green Belt study. There are, however, a number of non Green Belt settlements in the plan area that are suitable for an allocation. Salford Priors is located outside of the Green Belt. As detailed within these representations it is a sustainable location for development. BTL control land at Bomford Way, to the north of Salford Prior, that is ideally suited to residential development. As detailed in our Call for Sites submission is a readily deliverable housing site that should be preferred location for residential development.

Yes

The Vision The Vision outlined in the Draft Plan is appropriate, as are the objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities. Delivery of the SWLP should be achieved in a sustainable way that responds to the climate emergency and meets the five overarching objectives. This will ensure that the right development will be delivered in the right places. The Strategic Objective A number of the Strategic Objectives identified in the Draft Plan are appropriate and should be translated into policy in the following ways. • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. The land in BTL’s control at Salford Priors is well served by existing infrastructure and be brought forward for development promptly. • Developing opportunities for jobs is an entirely appropriate objective. – There are a number of large villages in the plan area, such as Salford Priors, that have employment sites, services and facilities that create job opportunities. The plan should look to direct housing allocations to these locations to ensure that there is a workforce available. The SWLP should also look to support business in rural areas to help ensure the sustainability of the smaller settlements. • Delivering homes that meet the needs of all our communities. – Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. While the focus should be larger strategic allocation that can make meaningful contributions to the housing need, smaller allocations will still be required to allow smaller settlements to meet their needs. Salford Priors is well placed to deliver development in this regard. • Contributing towards a net zero carbon target – Development opportunities that can provide green infrastructure and have access to services and facilities by sustainable means, such as walking and cycling should be preferred locations for allocations. • Connecting people to places – This is an important objective that will increase and improve access by sustainable and active travel modes. Allocations that are located close to public transport opportunities, educational facilities, green spaces, and employment opportunities, or can provide these opportunities on site, should be preferred. • Protecting and enhancing environmental assets – The SWLP should look to support allocations that can provide significant biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.

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Q-I2: The infrastructure requirements for the development strategy are critical in ensuring that development is deliverable and truly sustainable. One of the critical considerations in the site selection process should be the presence of onsite infrastructure at the site or the ability for development to provide it. Q-I3: The CIL requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. Q-I5: The development strategy needs to be deliverable and viable and there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The allocation should be ‘deliverable’ as defined in the Glossary of the NPPF. It is appropriate that development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. BTL’s land interest at Salford Priors has previously been identified as a Reserve Housing Site by the Preferred Options Stratford on Avon Site Allocations Plan demonstrating that it has been considered to be a sustainable and deliverable housing site. It should be a priority location for an allocation.

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Yes

There are a series of existing infrastructure schemes proposed across both plan areas. It would be sensible to include a policy in the plan confirming the nature and location of these schemes.

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