Issue and Options 2023
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New searchIssue B5: Environmental Net Gain Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these The requirement for sites to provide a 10% Biodiversity Net Gain (BNG) will come into force in November 2023, as dictated by the Environment Act. Terra consider that there is no justification for an Environmental Net Gain Policy going above and beyond this. The delivery of a biodiversity net gain needs to be considered on a site-by-site basis, as the ability to deliver a net gain of greater than 10% will be dependent on the baseline habitat conditions. The Environment Act will ensure that every new site achieves a 10% minimum BNG, so there is no need to pursue any higher requirement than this.
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Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Yes, Terra generally agree that the Vision and Strategic Objections are appropriate. However, Terra would ask the Councils to consider the below points: • Developing opportunities for jobs The COVID pandemic highlighted that there is a need for economic diversification within the area, particularly for Stratford-on-Avon. Terra agree that developing opportunities for jobs should be a priority, and that the South Warwickshire area has access to a range of transport corridors which can support this diversification. However, Terra consider that the Councils will need to ensure that economic development is carefully balanced with a delivery of residential development. The M40 corridor, and land to the east of Junction 12 in particular, offer a good opportunity to capitalise on the existing travel corridors and employment developments. Within the Core Strategy, Stratford-on-Avon allocated a New Settlement at Gaydon/Lighthorne Heath along with an expansion for the Jaguar Land Rover (JLR) campus. The allocation sought to provide 100ha of land for the expansion of JLR as well as 4.5 ha for the expansion of Aston Martin Lagonda (AML), securing a large amount of employment land along with 3,000 homes to facilitate the new settlement. This capitalises on the existing employment opportunities at JLR and highlighted the importance of this industry in the authority. From the Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA), it is clear that the highest need for General Industrial space is within Stratford-on-Avon. The HEDNA makes recommendations for meeting the Strategic B8 need within Chapter 11, which should be based on the following key locational considerations: • Road accessibility • Power supply • Proximity to Rail Terminals • Labour availability • Neighbouring activities Land east of Junction 12, M40 is well located to the motorway at Junction 12 of the M40. This Junction currently serves traffic to and from the JLR campus and is well place to continue to serve additional growth within the area. Additionally, it is in close proximity to readily available labour from the proposed new settlement at Gaydon/Lighthorne as well as the existing surrounding settlements(Lighthorne, Lighthorne Heath, Gaydon, and Bishop’s Itchington) and proximity to larger settlements, such as Birmingham. Land east of Junction 12, M40 would be suitable for providing a mixed use new settlement with a employment and residential provisions as well as other supporting infrastructure which capitalises on previous growth strategies secured in the Core Strategy at Gaydon/Lighthorne. This aligns closely with the Councils’ aspirations for employment focused growth. The HEDNA envisages that there will be a greater potential role for South Warwickshire in delivering strategic B8 growth that has been seen historically1. This means that the Council will need to think carefully as to where new employment growth will be located to ensure it is delivered in the most sustainable way. • Delivering homes that meet the needs of all our communities Terra support the Councils’ aspirations to support housing growth through the SWLP and ensuring that residential development provides a diverse mix of homes. The November 2022 Coventry &Warwickshire Housing & Economic Development Needs Assessment (HEDNA) highlighted that the population of Stratford-on-Avon has grown by 9.6% since the 2011 census data was collected, which is the third highest rate behind Rugby (10.1%) and Coventry (19.7%), therefore there is a clear requirement for additional housing within the authority. As both Stratford-on-Avon and Warwick are constrained by Green Belt, it is sensible to address housing need through a Joint Plan particularly as the authorities are closely linked.
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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 If this detail was included within the Part 1 Local Plan then the requirements would be establishedwhich apply equally across South Warwickshire. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy In this option, the focussing only on infrastructure relating to the growth strategy would mean thatrequirements in other locations would not be set until the Part 2 plan was adopted. In the interim, theexisting Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. The delivery of supporting infrastructure is fundamental to the delivery of any site, whether strategic or nonstrategic. However, the Part 1 Plan seeks to focus more so on the strategic growth elements. Therefore Option 12b would be more appropriate. However, Terra believe that both options should be amalgamated in some form to ensure that infrastructure delivery is suitably accounted for. The Councils run the risk of neglecting smaller settlements which are in need of infrastructure improvements if they focus purely on the strategic options. Further, leaving infrastructure provisions to a Part 2 Plan could cause significant delays if the Part 2 Plan is delayed or, indeed, the strategy changes and this is not continued with. This could therefore worsen any existing or future problems if there are delays. Therefore, Terra believe that it would be more appropriate to identify the infrastructure requirements through the Part 1 Plan, with any additional detail being introduced through the Part 2 Plan. 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 A single Levy for the whole of South Warwickshire could provide developers with greater certainty regarding likely development costs. It is possible to charge different rates of CIL in different zones within a single Levy. Option I3b: Each District Council to produce its own Levy Separate Levies could have the potential to better respond to different conditions in different areas of South Warwickshire, with the potential that reviews could be undertaken more easily to react to changing circumstances. Terra agree that a single Levy should be applied to the entire South Warwickshire Authority as this will enable to Councils to deliver their joint strategy in an effective way. The charge should additionally be zoned to enable it to react to varying markets and viability conditions. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability As detailed above, Land to the East of Junction 12, M40 as identified at Figure 1 is available and suitable for development. If the Council do wish to allocate sites for new settlements, a strategy which was adopted previously by Stratford-on-Avon, the Councils should be clear on the expectations of supporting infrastructure (including education, health, transport, Green Infrastructure) and affordable housing provision. This will feed into viability assessments for the delivery of the New Settlements, so these provisions need to be identified as early as possible.
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Terra agree with the general principle of safeguarding land to deliver infrastructure schemes. This strategy was taken within the Stratford-on-Avon Core Strategy where the Council identified a number of projects. However, some projects, namely the Stratford South Western Relief Road, have yet to be realised due to environmental and physical constraints as well as fundamental funding gaps. Further, a number of the allocations within the Core Strategy have been held to the delivery of the Relief Road which has compromised their delivery. Terra agree it is important to forward Plan for fundamental infrastructure projects and appropriately safeguard land in order to realised them, but Terra would caution the Councils relying on the delivery of these projects too heavily prior to assessing the realistic deliverability.
Q-S5.2: Do you think new settlements should be part of the overall strategy? Terra believe that new settlements should be part of the overall strategy. Stratford-on-Avon have successfully delivered new settlements, such as Meon Vale, as part of their previous strategy and the new settlement at Lighthorne Heath/Gaydon is currently in development. Figure 1 demonstrates the location of Land east of Junction 12, M40 which is available for a new settlement. Terra would welcome the Councils to consider this location for providing a new settlement.
Terra agree in part that rail corridors should be considered. As part of the previous consultation on the Scoping Document, the Councils put forward a number of Growth Options for the industry to respond to, which included the below: • Option A: Rail Corridors • Option B: Main Bus Corridors • Option C: Main Road Corridors • Option D: Enterprise Hubs • Option E: Socio Economic • Option F: Main Urban Areas • Option G: Dispersed Terra still contend that the Councils should incorporate the benefits of each growth option to suitably meet the requirements of the merged district. Whilst Terra agree that, in a climate emergency, focusing on rail corridors as a preferred approach could reduce reliance on private car use through sustainable transport planning, focusing solely on Rail Corridors limits the growth option and could potentially neglect the needs of the entire district, including the rural areas. This is particularly as large areas within the district do not fall within the identified rail corridors. The Council should ensure that they explore all options for providing new infrastructure along the existing rail lines if this is to be the main focus. Land to the east of Junction 12, M40 is in close proximity to an existing railway line (Banbury – Leamington line and the Kineton – Fenny Compton line). If this site is identified for a new settlement, this could include provision of a new station in close proximity along the existing rail lines. If the rail corridor option is carried forward as the preferred option, this should also be balanced with improving other forms of sustainable transport, including bus services or introducing further initiatives, such as the Stratford Greenway. Increasing connectivity and opportunities for active travel not only encourages healthier living, but also increase a scheme’s sustainability and future proofing of developments. This is particularly important as the rail system can be unreliable and is not always the most convenient mode of travel. Further, many areas within the district fall outside of a rail corridor.
