Issue and Options 2023
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2.21 Biodiversity net-gain (C9.1) 2.21.1 Providing biodiversity net gains is consistent with paragraph 174 of the NPPF and the Environment Act 2021. It is suggested that the policy under 9.1a is couched in these terms rather than having an arbitrary maximum percentage of paved/hard surfaces on site – which may not achieve the intended objective of a net gain in biodiversity.
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2.22 Climate change mitigation (10.1 and 10.2) 2.22.1 The requirement for proposals to include a climate change checklist for major developments (as defined in the NPPF) is supported (C.10.b). 2.22.2 Question C10.2 asks for any additional comments in relation to Climate Change Risk Assessments. It is suggested that the Council’s should prepare the checklist and associated guidance and ensure that it is proportionate to the development that is proposed.
2.23 Water Quality (C11) 2.23.1 It is suggested that existing policies in relation to water quality can be carried forward. This could be kept under review as the evidence base for the Local Plan evolves. 2.24 Flood risk 2.24.1 The plan should adopt a sequential approach in line with paragraph 161 of the NPPF: “All plans should apply a sequential, risk-based approach to the location of development – taking into account all sources of flood risk and the current and future impacts of climate change – so as to avoid, where possible, flood risk to people and property.” 2.24.2 This approach should be reflected in the search for sites and identification of preferred sites.
2.25 Design Guidance (D1 and 2) 2.25.1 The I&O identifies three approaches to the use of design guides (D2a – a comprehensive guide for the whole area, D2b – guidance for specific places, D2c – guidance for strategic locations / sites). Of the options presented, option D2c is considered the most appropriate and proportionate. The character of the plan area is far too varied to warrant a single guide for the whole area and bespoke guidance for settlements would also be a huge undertaking given the number of settlements that might be included. 2.26 Density (D3) 2.26.1 Various approaches to density are set out. D3a is a general policy, which does not identify specific density requirements, D3b-d outline different approaches to identifying density at the settlement level. It is considered that the plan area is too diverse to be prescriptive about densities. The approach set out in D3a is considered proportionate. Any policy should highlight the need to optimise density, having regard to the existing character of an area, open space requirements and other development considerations.
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2.27 20-minute neighbourhoods (T1) 2.27.1 The concept of 20-minute neighbourhoods is supported but policies relating to this should recognise the importance of choosing the right location in the first place and making existing settlements more self-contained, i.e. those with high quality public transport (rail and high frequency bus corridors), leisure, education services and for access to higher order services and employment. The concept should also be applied across all suitable settlements, rather than being restricted to areas of new development. The Local Plan should explore the potential for encouraging 20-minute neighbourhoods across the plan area. This means greater granularity in relation to the spatial strategy will also be required. 2.27.2 Option T1b, which includes reference to the principles of a 20-minute neighbourhood within a broader overarching policy, is supported. 2.27.3 It is noted that reference is also made to ‘similar’ design approaches, e.g. Building for a Healthy Life, such approaches would be complimentary to the 20-minute neighbourhood approach but would only relate to new development. The 20-minute neighbourhood concept has potential to be applied at the settlement level (through a top-down approach) – including the retrofitting of facilities and services to address any existing shortfalls. Building for Healthy Life is primarily concerned with how new development can be integrated into existing settlements (bottom-up approach). The London Borough of Newham provides an example of where a strategic approach is being taken to the application of the 20-minute neighbourhood concept across the plan area. 2.28 Sustainable Transport (T2 and T5) 2.28.1 Two options are presented T2a envisages changes to parking standards – with less provision in those areas with good active/public transport links, such as the main urban centres. T2b appears to encourage the take up of more sustainable forms of transport, without associated restrictions on car parking. Given the rural nature of much of the plan area it is suggested that car parking restrictions are not appropriate for much of the area. The approach under T2b is therefore considered appropriate. 2.28.2 T5 asks for any additional comments about a well-connected South Warwickshire. Directing development to locations that have access to a range of services and facilities and public transport that are close to the main urban centres and planned employment growth will help achieve the desired outcome. It is considered that Harbury represents such a location.
