Issue and Options 2023
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New search2.1 The concerns with the Sustainability Appraisal (“SA”) relate to the overall approach for how options have been assessed and specific concerns that Gaydon/Lighthorne Heath and land within its proximity has not featured within the assessment process. 2.2 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Councils decide the over-arching distribution strategy in the SWLP and refine options to specific locations. This is particularly important given that certain specific locations have not been assessed in detail and therefore a fully informed evidence base will not underpin the plan. 2.3 When examining the conclusions in detail there are inconsistencies and errors which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives;despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travelscores a single positive whereas Sustainable Travel and Economy scores a single negative. For Natural Resources this is justified based on the Sustainable Travel option potentially promoting higher density development. For Landscape this is on the basis that this option is likely to feature urban extensions to areas that are already built up and may be less sensitive to effects on the Landscape. However, given that the Sustainable Travel and Economy option also focuses on areas which are already established and has the potential for higher densities, including key employment centres, this rationale is equally applicable to this option and its scoring should be adjusted accordingly. 2.4 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be questionable considering the NPPF (para 176) attaches the highest status of protection on conserving and enhancing the landscape and scenic beauty of AONBs. 2.5 In terms of specific concerns, these relate to the lack of recognition Gaydon/Lighthorne Heath receives within the assessment despite the area being the location of Jaguar Land Rover’s principal design and engineering centre and Aston Martin Lagonda’s headquarters, significant residential growth and an existing 100ha allocation for commercial use (solely for the expansion of JLR). This is disappointing given the current policy status of the New Settlement (a Main Rural Centre), the extant employment within the area associated with JLR and AML, and the acknowledged employment opportunity through the 100 Ha allocation in both policy and the adopted SPD for the area as referenced earlier in these representations. 2.6 Gaydon/Lighthorne Heath is a 3,000 home new settlement allocated in the Stratford-on-Avon District Core Strategy. The development features a range of services, facilities and green infrastructure and the Site is now coming forward with over 250 homes occupied. 2.7 The Core Strategy recognises the eventual sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.” 2.8 The settlement hierarchy for Stratford-on-Avon District in the extent Local Pan clearly recognises the transformative nature of this new settlement to the local area. For the purposes of this plan, particularly as the plan is looking to cover a period to at least 2041, Gaydon/Lighthorne Heath should now be considered as a Main Rural Centre and should be considered alongside other Main Rural centres such as Alcester, Shipston-on-Stour and Southam. The SA identifies broad locations at these settlements and therefore for consistency the same approach should be taken at Gaydon/Lighthorne Heath. 2.9 Furthermore, the Gaydon area/M40 Junction 12 is identified as a Major Investment Site within the Issues and Options consultation and therefore specifically identified for it’s potential to attract further inward investment and economic growth. Consequently, the SA should assess options for further development in these locations. 2.10 Therefore, to ensure consistency with other equivalent settlements and to reflect the status of the area as a Major Investment Site, the SA should assess this area as a potential development option. This will ensure that a range of development scenarios are assessed, and that the most suitable and justifiable strategy is taken forward in the plan.
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4.21 We are supportive of the principle of the allocations being carried over into the SWLP as this provides an important starting point in meeting the identified needs. However, it is important to note that the site that is the subject of these representations is currently a substantial part (90ha) of the 100ha allocation that is specifically for the use of Jaguar Land Rover under policy GLH in the Core Strategy. 4.22 This allocation, uniquely, is solely for Jaguar Land Rover’s benefit despite them having no commercial control of the majority of the allocation. Furthermore, there are no review mechanisms in-place within the Core Strategy for this to be released to the open-market. The allocation was specifically identified for Jaguar Land Rover as a consequence of representations made to the Core Strategy about the critical importance of the allocation to the operation of JLR, with the interim Inspectors report (para 125) confirming that “JLR told the Hearing that the allocation being sought in the CS is ‘…about keeping JLR in the UK’”. 4.23 Despite these representations, since the examination in 2015 and the adoption of the Core Strategy in 2016 (nearly 7 years ago), no such proposals have been submitted to Stratford-on-Avon District Council by Jaguar Land Rover. 4.24 Therefore, it is considered that the user-specific nature of this allocation needs to be re-considered with the userspecific restriction removed. Without this user-specific reference being re-considered there is a considerable risk that the allocation could actually be harmful to the local economy through stifling the opportunity for furthereconomic growth and inward investment in this sub-regionally significant and accessible location, therefore undermining the spatial and economic strategy of the plan. Furthermore, reviewing the role of allocations is recognised in the NPPF (para 122) where land should be re-allocated to a more deliverable use if it is not going to come forward for its identified use. 4.25 The removal of the user specific policy restriction would not prejudice the ability of Jaguar Land Rover to secure land within the allocation, should land be needed. As noted above, JLR have invested heavily in the creation ofnew warehouse and manufacturing space elsewhere within the region on land not specifically allocated for this purpose. 4.26 As part of this process, the Council’s are urged to consider the potential of the site to provide opportunities for further unrestricted development given the proximity to the Upper Lighthorne New Settlement which these representations have confirmed benefits from strong housing delivery, a range of services and facilities and will have the equivalent of Main Rural Centre status. Aligning jobs and housing growth has the benefit of further enhancing this area as a sustainable location for strategic growth and would take forward the original concept when it was first promoted by CEG as part of the Core Strategy process in 2012/13. This was reflected in the ‘Core Strategy - New Proposals consultation’ (August/September 2013).
No answer given
2.1 The concerns with the Sustainability Appraisal (“SA”) relate to the overall approach for how options have been assessed and specific concerns that Gaydon/Lighthorne Heath and the wider M40 Junction 12 area has not featured within the assessment process. 2.2 In terms of the overall approach to how the 5 broad options have been assessed (chapter 7 of the SA), we recommend that these findings are treated with considerable caution when the Council’s decide the over-arching distribution strategy in the SWLP and refine options to specific locations. This is particularly important given that certain specific locations have not been assessed in detail. 2.3 Furthermore, when examining the conclusions in detail there are inconsistencies and errors which raise question marks over the assessment’s robustness. For example, regarding both the Landscape and Natural Resources objectives; despite the extremely close alignment between these 2 options on the indicative diagrams. Sustainable Travel scores a single positive whereas Sustainable Travel and Economy scores a single negative. For Natural Resources this is justified based on the Sustainable Travel option potentially promoting higher density development. For Landscape this is on the basis that this option is likely to feature urban extensions to areas that are already built up and may be less sensitive to effects on the Landscape. However, given that the Sustainable Travel and Economy option also focuses on areas which are already established and has the potential for higher densities, including key employment centres, this rationale is equally applicable to this option and its scoring should be adjusted accordingly. 2.4 Moreover, specifically for the Landscape objective, the Dispersed option scores a single positive compared to a single negative for both the Economy and the Sustainable Travel and Economy options. This is despite this being the only option that features development within the Cotswold AONB. This scoring outcome appears to be incorrect considering the NPPF (para 176) places the highest status of protection for conserving and enhancing the landscape and scenic beauty of these areas. 2.5 In terms of specific concerns, these relate to lack of recognition of Gaydon/Lighthorne Heath receives within the assessment despite the area being the location of Jaguar Land Rover’s principal design and engineering centre and Aston Martin Lagonda’s headquarters, significant residential growth and an existing 100ha allocation for commercial use (solely for the expansion of JLR). 2.6 Gaydon/Lighthorne Heath is a 3,000 home new settlement allocated in the Stratford-on-Avon District Core Strategy. The development features a range of services, facilities and green infrastructure and the site is now coming forward with a number of houses completed and occupied. 2.7 The Core Strategy recognises the eventual sustainability and significance of Gaydon/Lighthorne Heath through the supporting text to policy CS.15 which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.” 2.8 The settlement hierarchy for Stratford-on-Avon District in the extant Local Plan clearly recognises the transformative nature of this new settlement to the local area. For the purposes of this plan, particularly as the plan is looking to cover a period to at least 2041, Gaydon/Lighthorne Heath should now be considered as a Main Rural Centre and should be considered alongside other Main Rural centres such as Alcester, Shipston-on-Stour and Southam. The SA identifies broad locations at these settlements and therefore for consistency the same approach should be taken at Gaydon/Lighthorne Heath. 2.9 Furthermore, the Gaydon area/M40 Junction 12 is identified as a Major Investment Site within the Issues and Options consultation and therefore specifically identified for it’s potential to attract further inward investment and economic growth. Consequently, the SA should assess options for further development at these areas. 2.10 Therefore, to ensure consistency with other equivalent settlements and to reflect the status of the area as a Major Investment Site, the SA should assess this area within its assessment of development options. This will ensure that the plan is underpinned by robust evidence.
No answer given
