Issue and Options 2023
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- Issue S2: Intensification - We support option S2A. This would support higher density development in the existing urban areas, which are more suited to this type of development. - Issue S3: Using Brownfield Land for development - QS3.2 -We support option S3.2a. An ‘in principle’ support for brownfield development only where it corresponds with the growth strategy and would assist to deliver the vision and strategic objectives. - Issue S4: Growth of existing settlements - The growth of existing settlements should be a central pillar within the overall growth strategy. This ensures making best use of existing infrastructure, delivering more sustainable patterns of development that seek to protect more of and the character of the open countryside. Please see full response to this at Q-S7.2. - Issue S6: A review of Green Belt boundaries - We note that there is no Question on this at this stage but would repeat our response on this matter made at the Local Plan Scoping Stage that a Green Belt review is critical to the core evidence base which will be required to underpin the South Warwickshire Local Plan. We also note that 54% of respondents at the scoping stage supported the exploration of growth opportunities in the Green Belt. - Issue S8: Small scale development outside of the chosen spatial growth option - We do not agree with a threshold approach for settlements falling outside the chosen growth strategy, as there is no planning justification for this, each application should be determined on its merits. Furthermore, a standardized approach is difficult as settlement sizes vary enormously. For example, a standard limit of 10 dwellings may be appropriate in a very small settlement, but would be far too low for most settlements. A limit of 10 units also results in no affordable housing being provided. If the Council do decide to include a threshold, we would suggest that this should be linked to and expressed as a percentage of the size of the existing settlement rather than a standard number of dwellings. - Issue S9: Settlement Boundaries and infill development - We support Option S9b. It is clearly essential that the Part 1 Plan should include a fresh review of all settlement boundaries. This issue of settlement boundaries raises the problem of pursuing a 2 stage Local Plan which we do not support. See our full response to Chapter 12: Plan Context.
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Issue E2: A Low Carbon Economy - We support Option E2a as the there is a need as part of the wider green agenda to promote the principle of a low carbon economy. However, such policies should not be overly prescriptive as much of the guidance for sustainable design comes through national policy and building regulations which ensures a consistent approach across the country. Local policies or requirements above national policy may discourage economic growth in South Warwickshire. Issue E3: Diversifying the economy - We support Option E3d. Local employment should always be supported but we do not consider it necessary for planning policies to include specific local employment strategies, which can in some instances conflict with employment law and often the operational requirements of successful businesses, which may act as a deterrent to those choosing to locate in South Warwickshire. Where these are in place in other authorities the effectiveness is very questionable and the related planning conditions/s106 obligations just add more unnecessary red tape. Issue E5: Lack of business accommodation - Option E5b. We do not support the inclusion of policies which dictate employment unit sizes. Whilst we understand the rationale, the reality is that the market supplies business units of all sizes and responds to market needs and gaps. If there is an under supply in one area, the market will respond. For example, A.C Lloyd has recently developed 61 SME business units all under 100 sq.m on a site in Tachbrook Park, Warwick. This scheme wasn’t delivered because planning policy required it, rather because there was an identified market shortfall of such units in the area and therefore it was market driven. Planning Policy should not get involved in commercial market requirements and should allow flexibility on sites for the market to deliver to meet actual needs and demands. Issue E6: Core Opportunity Area and Major Investment Sites We support Option E6a, to include a policy which generally protects South Warwickshire’s economic assets where they remain suitable and viable, but such policies must always be written flexibly to allow for changes in circumstances and provide criteria for acceptable land use change. Issue E7: Core Opportunity Area and Major Investment Sites - We support Option E7.1a for the inclusion of a policy that would direct employment to the identified Core Opportunity Area, as identified. This will help provide spatial clarity to the economic strategy, focussing economic activity near to the main existing towns and settlements, near to existing infrastructure and strategic links, and near to where we believe the majority of new homes should be located. - We support Option E7.2a. As part of a comprehensive approach to economic growth, we consider it would be appropriate to include a policy to support additional economic growth at existing major investment sites. This would make best use of existing infrastructure and support existing business clusters. Any such policy would have to be criteria based and should not exclude new investment locations being brought forward in appropriate locations.