Issue and Options 2023
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New searchYes, growth of existing settlements in South Warwickshire is considered to be imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. Further, growth of existing settlements will support the sustainability and vitality of existing services, providing support to existing communities, which in turn has the potential to enhance placemaking and sustainability. Whilst the potential for new settlements in South Warwickshire is recognised, they will not ensure delivery of growth in the early part of the Plan period or sustain and enhance the vitality and sustainability of existing settlements. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages; those needs cannot be directly met sustainably in isolated settlements.
General Observations 2.2. Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stra tford-on-Avon District Council and Warwick District Council up to 2050. Paragraph 22 of the National Planning Policy Framework (NPPF) requires that all strategic policies should have a minimum timeframe of 15 years from point of adoption. While the SWLP is compliant with Paragraph 22 there is concern that a plan period to 2050 may be too ambitious in so far as it may be difficult for the plan to adapt to change. A further concern is that in establishing a 25-year plan period, the SWLP will make decisions that are so long term that it could compromise meeting the development needs of the area. By way of example, the SWLP could allocate a site which would genuinely take 20 years to deliver as a key part of its development strategy and given the magnitude of such sites could lead to smaller sites, in deliverable locations, not coming forward to meet housing needs in the intervening period. 2.3. Section 1.4 of the Consultation Document confirms that it remains the Council’s intention to prepare a two-part plan. The Respondent’s main concern regarding a two-tier system is the inevitable delay in plan-making that will occur as a result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans, there will also be no flexibility in this second-tier documents to make changes to the development strategy to reflect updated evidence needs. This is a particular concern given the projected end date of the plan being some 25 years hence. 2.4. The suggested timetable for the SWLP’s preparation is also considered to be highly ambitious. Given that most Local Plans take more than a year to be Examined by the Secretary of State it is considered very unlikely that Part 1 will be adopted before 2027 and potentially beyond if there is slippage between the public consultation stages indicated in Figure 2 (Page 16) of the Consultation Document.
2.6. The Respondent is in general agreement with the vision and strategic objectives set out in the Consultation Document but considers that the delivery of market and affordable housing to meet housing needs, including unmet need arising from neighbouring authorities, should be given greater emphasis in the Council’s Vision for the Local Plan (V1). 2.7. The respondent would suggest the following amendment: “The vision is to meet South Warwickshire’s sustainable development needs to 2050, including new market and affordable homes, while responding to the climate emergency. Where appropriate and agreed, this should include unmet need from neighbouring authorities. The plan will provide homes and jobs, to boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time. Five overarching principles will determine how this development is delivered:” 2.8. With regards to V3: Strategic Objectives, the role that all current settlements can play in meeting housing needs should be recognised. 2.9. Furthermore, in recognition that it may not be possible to fully off-set carbon emissions in all cases (see comments made later in this Statement), the Council should consider updating the strategic objective of “Contributing towards Net Zero Carbon targets” to refer to “Minimising net carbon emissions arising from new development as far as practicable” (or similar).
Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development 2.10. The Respondent considers Option I2a as being most appropriate to ensure a consistent approach across the plan area and avoid disconnect between the SWLP and current extant Local Plan policies. 2.11. While the Respondent would not object to the utilisation of a combination of S106 Planning Obligations and Community Infrastructure Levy (CIL) as per the current system, any policy must reflect the provisions of the CIL Regulations 2010 (as amended) and particularly Regulation 122, which requires S106 obligations to be fairly and reasonable related in scale and kind to development. Q-I3: Please select the option which is most appropriate for South Warwickshire Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan 2.12. The Respondent considers that a single CIL for the whole of South Warwickshire is most appropriate since it will provide greater certainty to developers. While the Consultation Document indicates that separate levies could better respond to different conditions in different areas of South Warwickshire (i.e., the Stratford-on-Avon and Warwick Districts), in the Respondent’s view, this can equally be achieved through the implementation of different charging zones where these are justified. 2.13. The Consultation Document confirms that an Infrastructure Delivery Strategy (IDS) will be prepared which will set out the key pieces of new infrastructure needed to deliver the Councils’ growth strategy and how such infrastructure will be delivered. The Respondent is supportive of this action and considers the preparation of an IDS to be an essential component of the evidence base. Q-I4.1: Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Y/N/DK 2.14. Yes. The Respondent considers it sensible to include a policy that safeguards land that will facilitate the delivery of key infrastructure projects where this is justified. The Respondent recognises that safeguarding would be difficult to achieve post adoption of the SWLP and is best considered at an early stage of the plan preparation process to ensure that the growth strategy is capable of being delivered. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 2.15. Completion of a robust and comprehensive Plan Viability Assessment will be essential to ensure that the SWLP is viable and deliverable in a timely manner. The Respondent considers that both an IDS and Viability Assessment should be prepared at an early stage and used to inform a preferred strategy. Any such documents should be made available for comment as part of the Preferred Options Public Consultation.
2.21. The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). 2.22. The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “….whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (Section 4.6, Page 37, own bold) 2.23. While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). 2.24. In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. 2.25. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the Urban Capacity Study (Paragraph 4.6).
