Issue and Options 2023
Search form responses
Results for Warwickshire Property and Development Group search
New search2.29 Special Landscape Areas (B3) 2.29.1 Three options are presented in relation to Special Landscape Areas (SLAs) (B3a – maintain SLAs in Stratford on Avon district and introduce SLAs into Warwick District, B3b – maintain SLAs in Stratford on Avon but don’t introduce them into Warwick and B3c, discard SLAs and bolster landscape policy. Given the intention to create a Joint Local Plan it would make sense for option B3c to be adopted. 2.30 Environmental net gain (B5) and Wildbelt designations (B6) 2.30.1 Options relating to net gain are discussed, the first B5a is an ‘integrated approach’ with a policy covering air quality, water quality and carbon capture – biodiversity net gain would still be required. Option B5b is to have separate policies relating to biodiversity, air quality etc. It is suggested that option B5b is preferable – keeping the requirement for biodiversity net gain separate from other requirements will help provide clarity. 2.30.2 Wildbelts are discussed under B6 as a new approach to aiding nature recovery. From the information provided it appears that these could also act as wildlife corridors and stepping stones, which the NPPF (paragraph 179) already encourages, alongside areas identified by national and local partnerships for habitat management, enhancement, restoration and creation – it therefore appears that the NPPF provides a policy hook for local policies aimed at achieving these objectives. 2.31 Links to the Minerals Plan (B7) 2.31.1 It is agreed that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP. 2.32 Agricultural Land (B8.1) 2.32.1 Question B8.1 asks: “do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development?”. It is noted that the Government intends to produce a new suite of national development policies, and this may well be covered in there. The NPPF provides policy at paragraph 174b and a specific Local Plan policy that repeats national policy is not considered to be warranted. 2.33 Protecting biodiversity and geodiversity (B8.2 and B9) 2.33.1 Question B8.2 is: “should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites.” 2.33.2 From the explanatory text in the I&O part of the driver for the question appears to be that the two existing local plans have similar policies with different wording. It makes sense to have one policy covering the different designations that are in the area, the degree of protection given to such sites would need to be consistent with paragraph 175 of the NPPF. This principle would also apply to any policy referenced under Question B9.
2.34 Climate change mitigation (S5.1 and S7.1) 2.34.1 The evidence in relation to Carbon dioxide emissions requires further justification. The study appears to make assumptions about factors like the take up of electric vehicles (EVs) and the rate of retrofitting of existing buildings under each of the growth options. These assumptions appear to have a significant bearing on the emissions associated with each option. For example, operational building emissions are assumed to decrease at a slower rate under the Rail Growth option but the rational for this is not explained: “Transport and operational buildings emissions slowly decrease in the Rail growth option in line with the decarbonisation of the national grid as shown in Figure 4 and Figure 5, however operational buildings emissions decrease at a slightly slower rate than other growth options.” 2.34.2 As noted above, take up rates for Electric Vehicles also vary by scenario, e.g. “In terms of transport emissions, long and short distance trip car mode share reduction in 2050 was assumed to be 8% (Table 4) compared to 10% in the Rail option, as more new settlements were assumed to still be on the road network, slightly higher private car use is still assumed. With a higher private car reliance assumed, naturally higher EV uptake rates were assumed as shown in Table 4. Ultimately the higher EV rates meant that ‘Car driver’ emissions began to fall in-line with the carbon intensity of the grid which meant that total transport emissions fell at a faster rate despite ‘Car driver’ still taking up the highest percentage of the transport mode split by 2050.” 2.34.3 The assumptions underpinning the evaluation of the options therefore require greater justification.
3. Land off Bush Heath Road, Harbury 3.1.1 In Appendix B we have provided an overview of the Land off Bush Heath Road Harbury (the Site) and details of key development opportunities and constraints that have been considered to inform a concept masterplan scheme design which is also presented. 3.1.2 Harbury is a sustainable settlement served by public transport with an existing range of social and community facilities and services, and therefore a logical location for focusing further development thru the new Joint Local Plan. 3.1.3 The site is available and deliverable, and offers an important opportunity to bring forward new homes to meet local and district needs in a timely way whilst also securing wider community benefits in the form of new POS, new community allotments and dedicated parking for its users and for the adjacent sports pitches.
More information is required on the locations that are being assessed as locations for new settlements to confirm their suitability. The assumptions about the capacity of sites promoted by landowners/developers should also be made clear in the evaluation of any location. This also applies to the locations for growth considered around settlements that are discussed in later sections of the SA (Sections 4, 5 and 6). Where locations are not being actively promoted, they should not be treated as reasonable alternatives unless it can be demonstrated that they are developable. Sites that do not meet the criteria in Annex 2 of the NPPF should not be treated as reasonable alternatives.
Please refer to detailed response. The vision is too narrowly focused on the main settlements and needs to ensure that a comprehensive vision for the plan area is included for which provides the basis for preparing Local Plan 2s (LP2s) for each district. A comprehensive vision that relates to the plan area as a whole should be one of the key drivers for preparing a Joint Local Plan. The discussion in relation to the spatial strategy in the I&O document is considered too limited in scope and overly focused on the main towns. It is also crucial that the Part 1 Plan provides a coherent strategy for LP2s and updates to Neighbourhood Plans, including infrastructure requirements. The vision and spatial objectives should be clear that the principle of the Green Belt remains, and it will continue to shape new development, especially with regard to its fundamental aim of preventing urban sprawl by keeping land permanently open (NPPF paragraph 137).
