Issue and Options 2023
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- Q-B5: We support option B5c. We do not think the Local Plan is the right place for such policies which are being set at a national level already. - Q-B6: No, we don’t see the need further level of designation beyond the current suite of Local, Regional and National Wildlife designations. - Q-B7: Yes, policies from the Minerals Plan should not be replicated. - Q-B8.1: Policies should simply cross reference with national policy. There is no need for additional guidance. - Q-B9: No, national guidance and law already exists to protect such areas and should not be duplicated.
We strongly disagree with the approach of starting with a high-level, strategic part 1 Local Plan. Although the Plan could be split, we strongly believe the Part 1 Plan should include Development Strategy, Strategic Policies and Specific Site Allocations. The only aspect that we would agree could be split out to a Part 2 are the Detailed Development Management Policies.
-As per our response to the Scoping Consultation we maintain that the Site Allocations should be included in Part 1 of the Plan as this aspect of the Plan is of the most interest to the general public. By splitting the Allocations out from the Development Strategy, it will most likely lead to disengagement amongst most people and would not provide any clarity to communities and landowners. This strategy would in fact prolong uncertainty for these groups. -Furthermore, splitting the Allocations from the Strategy will also result in more speculative, unplanned development coming forward given that both Stratford District Council’s Core Strategy and Warwick District Council’s Local Plan are both over 5 years old. The outcome of the proposed approach will result in a repeat of what occurred in Stratford in the period of 2012 – 2016 whereby substantial unplanned development came forward in the District, particularly in the villages, whilst the Core Strategy was being prepared. This did not lead to a positive outcome for communities. There is a concern that the proposed two-part plan approach will result in further unplanned development, particularly as the timescales for the Part 2 plan has not yet been confirmed.
- Q-I3: We have concerns regarding CIL which has not been equitable in its implementation to date. The current system results in smaller (non-strategic) residential development sites effectively being hit twice through both the levy and s106 agreements. In terms of the options going forwards, it is difficult to see how CIL could be agreed separately under a joint Local Plan and therefore a South Warwickshire approach seems sensible but it is critical that it includes different zones within the levy to take account of different market areas.
The HEDNA is an appropriate starting point for identifying future levels of employment need across South Warwickshire. The HEDNA is a policy off document and assesses the needs arising within South Warwickshire only. It is therefore an appropriate starting point for identifying employment needs across the area before any “policy on” decisions are taken. Although there is some concern that the methodology employed underplays the total needs. Our main concern about the HEDNA as currently drafted is that it does not provide any account for non-strategic B8 development within the district level requirement and also over simplifies strategic employment needs as being solely for B8 uses. In reality of the market, at a local level is that employment parks provide a range of B2 and B8 uses and likewise at a strategic level there are some B2 requirements that are more than local. We therefore disagree with the way the needs have been categorised and there is a need to recognise the fluidity between Use Classes B2 and B8 in the market.
Yes the HEDNA appears to provide a reasoned basis for departing from the Standard Method based on the 2014 household projections and we have no objection to using a trend based approach as is suggested as it is fully justified and explained. It provides a useful starting point for identifying future levels of housing need across South Warwickshire.
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Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. This approach is consistent with national planning policy and basic sustainability principles to ensure that housing is focused in existing settlements, such as Bidford-on-Avon, where there are existing services and where there is a need to ensure vitality. South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-onStour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements. Bidford-on-Avon is categorised as a ‘Main Rural Centre’ in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. The settlement hierarchy is defined below: 1. Main Town: Stratford-upon-Avon 2. Main Rural Centres (including Bidford-on-Avon) 3. New Settlements 4. Local Service Villages 5. Large Rural Brownfield Sites 6. All other settlements 7. Local Needs Schemes Therefore, Bidford-on-Avon is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-upon-Avon district. Bidford-on-Avon is a large village which contains a range of local services and facilities, including a supermarket, convenience store, primary school, pharmacy, restaurants and public houses. There is an established industrial estate, which supports a wide range of jobs, to the north of Bidford-on-Avon off Waterloo Road. Given the need to accommodate development needs for housing within South Warwickshire, in addition to meeting the housing shortfalls from outside of South Warwickshire, Bidford-on-Avon is clearly a sustainable location to accommodate additional housing growth. The promotion site is a suitable location for housing by reason of the fact it comprises previously developed land close to the defined Built-up Area Boundary of Bidford-onAvon and is within walking distance of a main bus corridor. The scale of development is appropriate to Bidford-on-Avon, due to its position within the settlement hierarchy as a Main Rural Centre. Any scheme brought forward on this site would be designed to respect the existing settlement and be fully integrated. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing which is well-located in relation to the village and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.
