Issue and Options 2023

Issue S2: Intensification Intensification provides several benefits such as tackling climate change, reducing travel and promoting active travel. The recent NPPF consultation also outlines a move towards greater intensification of brownfield land being sought at a national policy level. Developing an intensification policy would enable a higher number of dwellings on the Greenhill Street site, subject to appropriate heritage and townscape and residential amenity matters being addressed. This would result in greater numbers of affordable housing being delivered to the area, which is a top priority for the Council.

Issue S3: Using brownfield land for development Given the scale of the national housing crisis, a combination of approaches for spatial planning is likely to be required. Furthermore, within the context of the Government’s levelling up agenda, it should be recognised that housing shortages and significant affordability issues remain. The Urban Capacity Study published as part of this consultation concludes 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.’ The emerging plan will therefore need to consider brownfield land in conjunction with greenfield release. Brownfield sites are frequently found within towns and urban areas, where there is good availability of services, and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. Opportunities for densification of existing brownfield sites in locations well served by public transport should clearly be maximised wherever possible. The potential redevelopment of the Greenhill Street site offers such an opportunity for the Councils to deliver a significant number of dwellings within the town centre, close to public transportation.

Issue E9: Supporting our changing town centres The existing Town Centre Boundary for Stratford-upon-Avon includes areas which are not primarily in retail use, while the Primary Shopping Area is focussed on a small number of central streets. The Greenhill Street Site is within the Town Centre Boundary though not within the Primary Shopping Area under existing policy. The consultation document states that a Town Centre study is being undertaken which will look at how much retail will need to be planned for over the Plan period as well as the functionality and vision for Town Centres. This will also look to identify locations of where more detailed information/Area Action Plans may be required. The results of this will be used to inform the Preferred Option. The emergence of this evidence will be useful to inform the strategy for the ground floor units on the Greenhill Street Site. Orbit are keen to work with the Councils to develop an appropriate scheme for the Site which retains active frontages at ground floor level.

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Issue C4: New buildings Net Zero Carbon policies are seeing increasing take up across new Local Plans and are likely to become common policy requirements in the future. Many authorities are following the London Plan approach to Net Zero Carbon which requires offsite contributions for Net Zero where it cannot be reached onsite. Often it is difficult to meet Net Zero carbon on residential sites with as roof spaces are not sufficient for the amount of PV required, even with a fabric first approach taken into account. Therefore, any emerging policy needs to consider an offsetting fund where it cannot be reached on site. Option C4.1c is the most appropriate approach for the Council to take on this issue with regard to the Greenhill Street Site. This will enable the development industry to adapt to the higher standards over time, and should give time for the costs of meeting the standard to come down. It is imperative that the Council’s consider these layered climate change policies against the delivery of affordable housing in this country, which is already constrained by viability, particularly with brownfield locations. Therefore, a phased approach enables developers time to adjust and supports the delivery of vital affordable housing to the District. Issue C6: Whole Life-Cycle carbon assessments Similar to the preceding issue, Orbit is supportive of detailed climate change policies overall but seeks flexibility and phasing of their introduction to retain the viability and deliverability of sites. A Whole LifeCycle Carbon Assessment considers a building’s carbon impact on the environment and are most usefully undertaken once a building has been constructed but prior to occupation. It should therefore be questioned whether requiring them at planning stage will result in submission of high-level reports which are not sufficiently detailed or accurate. The viability of such a policy would need to be tested during the plan making stage. The Councils therefore need to thoroughly consider at what point in the planning process is the most suitable for Whole Life-Cycle carbon assessments to be required to ensure that they get the most out of the process without placing unnecessary burden on developers at too early a stage in the development process.

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Issue C10: Climate Change Risk Assessments At the planning stage, where decisions such as exact materials and finishes haven’t been made there often isn’t sufficient information available to consultants to make these reports accurate. There is no existing industry guidance on what a Climate Change Risk Assessment should include and cover within it. In addition, Iceni, who have experience with writing such reports, find that the information included would likely be covered in other elements of a planning submission, such as a Flood Risk Assessment or Energy and Sustainability Statement. There are therefore concerns that this is another technical, yet unnecessary, report, which will largely summarise the work of other technical reports. Moreover, most Council’s do not have the in-house abilities required to assess these reports, and therefore rely on the use of external consultants to undertake these assessments, at the cost to the applicant. This would only further increase the cost of submitting and determining an application for the Greenhill Street Site.

Conclusion On behalf of Orbit, we thank you for the opportunity to input into the South Warwickshire Local Plan Issues and Options consultation. Orbit wish to commend the Council’s for the ambitious raft of climate change policies they are considering. Nevertheless, they request detailed consideration of the impact that these policies will have on the cost of submitting planning applications and the viability of sites going forward. The ambition of the Council in regard to the climate must also ensure that sufficient affordable homes are delivered within the area. The allocation of the Greenhill Street site for redevelopment to a mixed-use scheme is proposed by Orbit. As noted in the Call for Sites submission for the Site, further details will be provided in due course as the appropriate masterplanning and technical work progresses, and it is anticipated that the proposals will be shaped by extensive engagement with the Local Planning Authority and other key stakeholders. In the meantime, it is imperative that the emerging strategic policy context provides sufficient support and flexibility to enable the ambitious vision and potential for this site to be achieved.