Issue and Options 2023

Introduction and Overview We write on behalf of CEMEX UK Operations Ltd (CEMEX). CEMEX is a global supplier of construction materials. CEMEX has extensive land holdings within Warwickshire which include the former Southam Cement Works which is promoted for an employment led Garden Village through the emerging South Warwickshire Local Plan (SWLP) and a ‘call for sites’ submission has also been lodged separately. A site location plan is enclosed at Appendix 1. The Former Southam Cement Works site is a part brownfield part greenfield site and extends to a total of circa 105 hectares. It is identified as a Large Rural Brownfield site in the Adopted Core Strategy 2016 (Policy AS.11). Whilst the site lies to the north of Southam (a Main Rural Centre) and to the south of Long Itchington (a Category A Local Service Village). The Reg 18 SWLP identifies Policy AS.11 as a Part 1 policy that will be reviewed, with either an identical policy, adjusted or new policy. The site has an active operational life of 20-25 years, rather than continue with Policy AS.11 as a ‘redundant land’ policy, in our view the SWLP should progress a new ‘live’ policy that facilitates the phased release of the site to encourage organic employment growth ahead of the release of the operational land. The provision of residential accommodation in this context would enable a mixed-use co-ordinated scheme over the plan period. The opportunity for an employment led Garden Village on the site and surrounding land is considered further below and in ‘the Opportunity’ note enclosed at Appendix 1. The SWLP Reg 18 consultation includes a number of questions. We provide detailed responses in respect of the relevant questions below. Proposed Approach to Online Form and Consultation Portal We have completed the Online Forms on the SWLP Consultation Portal for the site as requested by the Council. However the Online Form is overly restrictive. For questions which require an option to be chosen, there is not always an opportunity to pick neither option. Therefore, we have artificially selected options in order to register an interest to comment, whilst cancelling out these choices, our detailed comments are set out in the covering letter below and we request that that they are considered by Officer’s in full, as well as the enclosures listed. Whilst we appreciate the Council’s desire to gather quantitative data, we would suggest that there needs to be the option to provide additional commentary otherwise the results of the consultation are notrepresentative.

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Q-V3.1: Do you agree that the Vision and strategic Objectives are appropriate? Q-V3.2: If no, please indicate why. The strategic objectives are broadly supported, and we consider they will combine to promote sustainable development within South Warwickshire in line with the aims of the National Planning Policy Framework (NPPF). However, in our view there is a need for the SWLP to be more visionary and clearer in its objectives that relate to growth. For example, reference to ‘allowing for growth in new homes’ to meet needs should be strengthened to reflect Paragraph 60 of the NPPF which refers to the need to support the Government’s objective of ‘significantly boosting the supply of homes’. We would also comment that there is a need to encourage employment growth and job creation. There is a need for up to date data to inform the level of growth to be planned for. Moreover a positive approach that enables existing businesses, such as CEMEX, to invest, expand and adapt as per the NPPF Paragraph 80.

Q-I2: Paragraph 11(a) of the NPPF makes clear that all plans should inter alia seek to meet the development needs of their area and align growth and infrastructure. Moreover Paragraph 34 also states that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such a s that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. There is a need to understand the infrastructure requirements from the growth strategy across the plan area through the preparation of an Infrastructure Delivery Plan or such other similar report. This is needed to inform the approach to the SWLP. In respect of Option I2b the commentary notes that this option would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts . Part 2 of the Plan will need to be consistent with the growth strategy set out and adopted at Part 1 therefore the infrastructure needs would already been known to an extent. Moreover, the IDP is a ‘live’ document that can evolve and be updated at Part 2. Q-I3: We consider that Option 13a is preferrable as it enables a consistent approach for the delivery of the sustainable growth and the required infrastructure across the whole plan area. Indeed, a similar approach was taken by South Worcestershire Councils (Malvern Hills, Worchester City and Wychavon) who prepared a joint Local Plan and then common CIL Charging Schedules. The CIL charging schedule was supported by an IDP as highlighted above. This provides a consistent approach across the plan area.

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Q-S2: As set out at Paragraph 124 of the NPPF, planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate, however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-S3.2: The NPPF clearly identifies at Paragraph 120 that planning policies should give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 141 highlights that before concluding that exceptional circumstances exist to justify Green Belt boundaries, consideration should be given as to whether the strategy inter alia makes as much use as possible of suitable brownfield sites and underutilised land. The test is therefore one of ‘suitability’. The prioritisation of brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area is a logical approach. Again, we would suggest that there is a need to understand existing housing and employment need in the first instance to then understand what the appropriate policy response is to meet that need. In this instance there is an opportunity to review the approach to AS.11 Large Rural Brownfield Sites to move from a ‘redundant land’ policy, to a new ‘live’ policy that facilitates the phased release of brownfield site’s such as the Former Southam Cement Work. This has the opportunity for these sites to transition to other uses, contribute to growth, rehabilitate degraded land, facilitate improved connections and achieve growth in an organic way. Q-S7.2: All of the above questions relate to growth strategy and where new development should be directed. Growth Options 1 and 2 rely on the creation of new settlements (6,000 new dwellings or more) linked to the achievement of new or reopened rail corridors. New settlements have long lead in periods, often rely on complex land assembly and in this instance are reliant on notable infrastructure funding and delivery outside of the control of the districts. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are unlikely to contribute to growth until towards the end of the plan period. There is a pressing need for delivery of housing and economic growth now therefore we would caution against an approach that seeks to rely on meeting a substantial proportion of housing need through standalone settlements. In our view to meet a range of housing and economic needs and provide a sufficient and deliverable supply of housing land, a mixture of the different options would be preferable. Southam is cited as a settlement/location that may feature within Growth Options 3, 4 and 5. As per Table 20 of the SWLP, the intention is to include a review of Policy AS.11 in Part 1 of the SWLP. This means either adopting an identical policy, adjusting or re -working the policy or creating a new policy on the same subject. As such, the development of the Former Southam Cement works site would be compatible with and supportive of a number of the above Growth Options and intention to review AS.11. A separate note has been prepared on ‘The Opportunity’ for an employment led Garden Village at the former South am Cement Works, enclosed at Appendix 1. This draws on the Garden City movement of the 20th century, and the history of the site, with the existing Model Village to the west constructed in phases in the early 20 th Century to house workers at the Southam Cement Works. The underlying concepts of the ‘garden village’ have been reimagined more recently with the ’15-Minute City’ or ’20-Minute Neighbourhood’. All relate to the creation of compact connected places where people can meet their everyday needs with in a short walk or cycle. This includes a range of local jobs within eas y commute. The core principles of the opportunity at the former Southam Cement Works includes: • A range of local jobs within easy commuting distance; • Mixed tenure homes, and housing types, that meet identified local need and affordability; • Beautifully designed homes with gardens, reflecting local character and materials. • Development that enhances the natural environment, maintaining and enhancing the existing green infrastructure network and wider opportunities for biodiversity net gain; • Prioritisation of low carbon and energy efficient technology with the aim of achieving a climate resilient development; • Supporting walkable recreation and shopping facilities; and • Improve connections with wider facilities in Long Itchington and Southam making walking, cycling and public transport the most attractive forms of transport. We would welcome the opportunity to meet with the Council to review the above, the opportunitie s for the site as per AS.11 Large Rural Brownfield Sites and the SWLP Reg intention to review this policy. Moreover, understand how the revised approach to AS11 could relate to Southam falling within the Core Opportunity Area where Q-E7.1 explores the potential for employment growth. In our view there is an opportunity for a policy approach that facilitates the phased redevelopment of the site and wider land holding for an employment led Garden Village that supports and intensifies employment and mixed use together with housing in a manner consistent with CEMEX’s long-term commitment to the site and the District as a long standing business and employer. We would suggest that a Masterplan, with phasing options, would be the vehicle by which to test the above Garden village principles. It would be useful to discuss the above proposition with Officers, the scope of the masterplan and the strategy for consultation and engagement. It would also be useful to discuss the relevant evidence base that should be prepared and how that might relate to that being assembled to support the local plan review and support consideration in the emerging SA.

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Whilst we suggest that more up to date evidence is needed and will be subject to more detailed review as the SWLP develop. However, we welcome the data provided to date which identifies a clear need to plan effectively for employment growth. The HEDNA provides details of the market needs and uses different data in order to anticipate office, industrial and warehousing net land needs until 2050. The HEDNA concludes that in the round the labour demand models best represent future needs for office floorspace (paragraph 11.3) the findings for Stratford on Avon are summarised in the following tables: Summary of Labour Demand – Net Land Needs 2021 – 2041 ha. (Table 9.4) Offices Stratford on Avon 5.2 Total 30.3 Summary of Labour Demand – Net Land Needs 2021-50 ha. (Table 9.5) Offices Stratford on Avon 7.2 Total 42.0 The above show that there is a need for offices in Stratford on Avon and a significant need across the region as a whole. In addition these offices will need to be high quality and meet occupiers needs. In terms of industrial and warehousing space, Paragraph 11.10 states that the completions data is likely to be the best representation of market needs for the next phase of plan making , particularly for the short/medium-term. For 2021-41 this equates to a need of 132.9 ha. for Stratford on Avon and 1029.8 ha. total need (see Table 9.12). For 2021 – 50 there is a forecast need of 192.7 ha. for Stratford on Avon and total need of 1493.2 ha. (see Table 9.13). The HEDNA also notes that consultation suggests that B8 demand is very strong, and that there is a need for separate allocations for B1c/B2 where land is delineated from sites going for B8 in order to support the manufacturing sector. There is a strong manufacturing sector in the sub-region which needs to be provided for (paragraph 11.11). Overall there is a need for employment floorspace across all three sectors, the site at Southam would be able to assist in meeting this need. We would welcome discussions with Officers as to the role that the site can play in meeting growth objectives.

Q-E7.1: The SWLP highlights that this policy would look to direct employment growth to the Core Opportunity Area with areas outside of this, providing opportunities for more local investment. Supporting Figure 21 Core Opportunity Area sets out the spatial extent of the Core Opportunity Area and includes Southam and the Former Southam Cement Works site. We would welcome employment development in this location as it represents a logical location for employment which follows the principles of a 20minute neighbourhood . Again, we would welcome further discussions with Officers.

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Q-H3: The matters set out above are of importance and should be reflected in the Local Plan Part 1.

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Biodiversity Net Gain has been introduced into national guidance; it aims to leave the natural environment in a measurably better state than it was to start with. It should be reflected in Local Plan Part 1.