Issue and Options 2023
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New searchQ-S1. Please select the option which is most appropriate for South Warwickshire Option S1a. It is vitally important that the South Warwickshire Local Plan addresses and facilitates nature recovery straight away rather than waiting until a Local Nature Recovery Strategy (LNRS) is adopted. The Local Plan policy (and supporting text) should refer to the forthcoming LNRS and, ideally, should explicitly put measures in place to incorporate the LNRS into the Local Plan once the LNRS is adopted. As indicated in the consultation documents, the existing Warwickshire, Coventry and Solihull Sub-regional Green Infrastructure Study can be used to inform the green / blue infrastructure policies. Consideration should also be given to other relevant guidance and policy measures including: • The Government’s aspiration to ensure that 30% of land is managed for nature by 2030.4 • The Government’s Environmental Improvement Plan 2023,5 including the targets to: o restore or create 500,000 hectares of wildlife rich habitat by 2042; o increase tree canopy and woodland cover from 15.4% to 16.5% of total land area in England by 2050. • Natural England’s Green Infrastructure Framework;6 • South Warwickshire Climate Action Support,7 including the target to increase forest coverage by 24% by 2030. • The Cotswolds Nature Recovery Plan.8 4 https://www.gov.uk/government/news/pm-commits-to-protect-30-of-uk-land-in-boost-for-biodiversity 5 HM Government (2023) Environmental Improvement Plan 2023 6 https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx 7 Warwick and Stratford-on-Avon District Councils (2021) South Warwickshire Climate Action Support 8 Cotswolds National Landscape Board (2022) Cotswolds Nature Recovery Plan Q-S2. Please select all options which are appropriate for South Warwickshire Option S2a. Intensification of development provides significant potential benefits. For example, it can help to increase the number of people who live within, say, a 10-minute walk, of key services, facilities, employment opportunities and public transport options. 9 This, in turn, should help to reduce the need to travel by car and, in doing so, help to reduce greenhouse gas emissions. However, the capacity of different settlements to accommodate intensification of development will depend on the character of the individual settlement. As such, it is important to develop design codes for each character area. Intensification should not be delivered at the expense of green infrastructure, including biodiversity, or to the detriment of historic environment designations (and their settings) such as Conservation Areas, listed buildings and scheduled monuments. If intensification is being considered within the Cotswolds National Landscape and its setting, this should not be to the detriment of the natural beauty of the National Landscape, including its special qualities, local distinctiveness and views from (and to) the National Landscape. 9 This concept is commonly referred to as the ’20-minute neighbourhood’ Q-S3.2. Please select the option which is most appropriate for South Warwickshire Option S3.2a. The need for development to be in a sustainable location is more important than the principle of prioritising development on brownfield land. This is because the sustainability of the location (i.e., proximity to services, facilities, employment and public transport) is a key component of mitigating the impacts of climate change. Developing brownfield land that is not in a sustainable location is likely to result in higher levels of greenhouse gas emissions (for example, through car use) than development in a sustainable location. Q-S4.1. Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes. This growth should be focussed on those settlements / neighbourhoods that are – or have the potential to become - ’20-minute neighbourhoods’, providing key services and facilities. Q-S5.2. Do you think new settlements should be part of the overall strategy? Yes. New settlements (away from protected landscapes) have the potential to play a key role in helping to secure ’20-minute neighbourhoods’ and, in doing so, help to reduce greenhouse gas emissions relating to commuting, for example. Q-S7.2. For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: • Option 1: Rail Corridors: Neutral • Option 2: Sustainable Travel: Neutral • Option 3: Economy: Neutral • Option 4: Sustainable Travel and Economy: Appropriate strategy • Option 5: Dispersed: Inappropriate strategy. A key consideration in identifying the most appropriate growth option is the greenhouse gas emissions that will result from each option and the extent to which each option helps to mitigate and adapt to the impacts of climate change. As outlined in response to Question Q-S5.3, the ‘sustainable travel and economy’ growth option appears to perform the best in this regard. Options 1-3 also provide some benefits, in this regard, as they locate development close to public transport or employment. Option 5 (Dispersed) clearly performs the worst in relation to greenhouse gas emissions. It is more difficult to identify a clear preference based on the results of the Sustainability Appraisal12, although Option 5 (Dispersed), again, clearly performs the worst in this regard. The Sustainability Appraisal indicates that Option 5 (Dispersed) performs relatively well in relation to ‘Sustainability Appraisal Objective 4: Landscape’ on the basis of the overall scale of development being more thinly spread and distributed. However, this does not take into account the fact that Option 5 would result in considerably more development within and adjacent to the Cotswolds National Landscape.13 For example, Options 1-5 don’t indicate any growth (over 50 dwellings) in settlements within the Cotswolds National Landscape, whereas Option 5 would result in: • 150-350 dwellings in one National Landscape settlement (Ilmington); • 50-150 dwellings in each of five National Landscape settlements; • 150-350 dwellings in a settlement adjacent to the National Landscape (Quinton); • 50-150 dwellings in each of two settlements adjacent to the National Landscape (Tysoe and Great Wolford). This scale of development would not be appropriate in these relatively small settlements given that national planning policy states that the scale and extent of development in AONBs should be limited. This scale of development is also likely to harm the character, local distinctiveness and natural beauty of these settlements. This should not be taken to mean that we think that there should be no development within the Cotswolds National Landscape. It just means that the relatively small settlements in (and directly adjacent to) this part of the Cotswolds National Landscape are unlikely to be suitable areas for accommodating 50+ dwellings. See our response to Question Q-S8.1, below, for further comments on this issue. All five growth options identify that 5,000+ dwellings would be provided at Long Marston Airfield / Meon Vale. It would be useful if a more exact figure could be provided for each of the growth options as this would help with identifying the potential impacts of this development on the Cotswolds National Landscape. Further recommendations in relation to this development are provided in response to Question Q-S5.3. 12 A summary of the sustainability appraisal for the five growth options is provided in Table 7 of the Issues & Options consultation document (pages 59-60). 13 Option 5 is shown in Figure 20 of the Issues & Options consultation document (page 72). Q-S8.1. For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? No, we do not think that a threshold approach is appropriate. With regard to potential development within the Cotswolds National Landscape, we recognise that the Cotswolds is a living and working landscape and that maintaining thriving local communities is essential to the long-term future of the National Landscape. Providing housing that meets the needs of the local communities within the Cotswolds National Landscape plays an important role in achieving these aspirations. However, these aspirations should be delivered in a way that is compatible with and, ideally, positively contributes to the statutory purpose of conserving and enhancing the natural beauty of the National Landscape. Housing delivery within the National Landscape should also focus on meeting affordable housing needs, particularly with regards to housing that is affordable in perpetuity, such as social rented housing. Windfall housing proposals outside the settlement boundaries should be based on robust evidence of need arising within the National Landscape, for example, a housing needs survey for the specific settlement / parish. Further guidance on this topic is provided in the Board’s Housing Position Statement.14 In the current Stratford-on-Avon Core Strategy, the hamlet of Upper Quinton, which lies within the Cotswolds National Landscape, is included within the Local Service Village boundary for Lower Quinton, which lies outside of the National Landscape. We do not think that this is appropriate. Government guidance states that AONBs ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.15 In the context of Quinton, this means that Upper Quinton is unlikely to be a suitable area for accommodating the housing needs associated with Lower Quinton, which is a much larger settlement than Upper Quinton. 14 Cotswolds National Landscape Board (2021) Housing Position Statement 15 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041. Q-S8.2. For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? As indicated in response to Question Q-S8.2, we do not think that a threshold approach is appropriate. However, it is worth noting that the issue of thresholds is relevant when considering whether a proposed development within the Cotswolds National Landscape constitutes ‘major development’, in the context of paragraph 177 of the National Planning Policy Framework (NPPF). The Board’s Landscape-led Development Position Statement16 provides a checklist of topics that should be taken into account when deciding if a proposal constitutes major development. One of the considerations in the checklist is whether a proposed housing development would increase the size of a settlement – or increase the number of dwellings in a settlement - by more than 5%. As such, if a proposed development would increase the number of dwellings by more than 5%, this makes it more likely that the proposal would constitute major development. 16 Cotswolds National Landscape Board (2021) Landscape-led Development Position Statement. See Appendix 5, including footnote 36. Question Q-S9. Please select the option which is most appropriate for South Warwickshire Option S9a would be most appropriate as this would enable the settlement boundaries to be finalised once any non-strategic allocations have been identified and taken forward.
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Q-E2. Please select all options which are appropriate for South Warwickshire Options E2a and E2c. We consider that both of these options are essential components of tackling the climate emergency. Q-E4.1. Please select the option which is most appropriate for South Warwickshire Option E4.1a. Diversification is essential for ensuring that rural areas continue to thrive and make a positive contribution to the local economy. Having a specific policy supporting diversification will help to achieve this. Within the Cotswolds National Landscape and its setting, this diversification should be delivered in a way that is compatible with - and, ideally, positively contributes to – conserving and enhancing the natural beauty of the area. Q-E4.2: Please select the option which is most appropriate for South Warwickshire Supporting small-scale employment opportunities is essential for ensuring that rural areas continue to thrive and make a positive contribution to the local economy. Having a specific policy supporting small-scale employment opportunities will help to achieve this. Within the Cotswolds National Landscape and its setting, these small-scale employment opportunities should be delivered in a way that is compatible with - and, ideally, positively contributes to – conserving and enhancing the natural beauty of the area.
Don’t Know. Paragraph 61 of the National Planning Policy Framework (NPPF) requires the ‘standard method’ to be used for calculating housing need unless ‘exceptional circumstances’ justify an alternative approach. It is not clear if the justification for the proposed alternative approach constitutes exceptional circumstances. We are pleased to see the acknowledgment, in the Issues and Options consultation document, that the standard method and HEDNA figures do not reflect any assessment of whether those needs can be met within each local authority area. In this context, it is important to note paragraph 11b and footnote 6 of the NPPF, which identifies certain exemptions to the requirement to meet the following needs through the plan-making process: (i) objectively assessed needs; and (ii) needs that cannot be met within neighbouring areas. In other words, there are circumstances in which the housing requirement figure (i.e., the amount of housing that should be provided for once relevant constraints have been factored in) could potentially be less than the housing need figure (i.e., the unconstrained assessment of housing need). This is expanded on in the Government’s ‘Natural Environment’ planning practice guidance, which states that: . The NPPF’s policies for protecting Areas of Outstanding Natural Beauty (AONBs) ‘may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process’; and . AONBs ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.17 For the second of these points, we interpret this to relate to both: (i) unmet needs arising from neighbouring local authority areas; and (ii) unmet needs arising within the local authority area but outside of the Cotswolds National Landscape. These points should be factored in when considering an alternative approach to the ‘standard method’ and / or when determining the housing requirements for the area and the spatial distribution of this housing. 17 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041 Reference ID: 8-041-20190721
In particular, we support the statement the following statement from the Issues and Options consultation document: . Given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas (e.g., Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt. This would be consistent with paragraph 11b of the National Planning Policy Framework (NAAONB) and with the Government’s ‘Natural Environment’ planning practice guidance23, particularly given the following factors: .The Cotswolds National Landscape occupies a small proportion of South Warwickshire (approximately 8%). . The Cotswolds National Landscape is the part of South Warwickshire that is furthest from Birmingham, the Black Country or Coventry. . A large proportion of the Cotswolds National Landscape within South Warwickshire consists of the Cotswold escarpment, escarpment outliers or high wold. The escarpment and high wold (including the views associated with them) are ‘special qualities’ of the Cotswolds National Landscape. The views associated with the escarpment outliers are a key feature / characteristic of that landscape character type. 23 https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041 Reference ID: 8-041-20190721.
In principle, the housing shortfall would best be accommodated by applying Growth Strategy Option 4 (Sustainable Travel and Economy), focussing on suitable areas that are relatively close to the urban areas where this shortfall arises and / or close to public transport options that provide good connectivity with these areas, having regard to (but not necessarily excluding) potential constraints such as Green Belt.
