Issue and Options 2023
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Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the sub-regional Strategic Distribution Needs, including through identifying some provision East of Junction 12 of the M40, will ensure the South Warwickshire plan takes a positive position on economic growth and in turn support the South Warwickshire Economy. Further to these over-arching needs, there is immediate demand for space within the District and CEG have very strong occupier interest for this area. Q-E3: Please select all options which are appropriate for South Warwickshire 4.6 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.7 Given that the scope of the South Warwickshire Local Plan is a Part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth, therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.8 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.9 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including Gaydon, and major road infrastructure aligned to the key settlements of Stratford - upon-Avon, Warwick and Leamington. 4.10 Therefore, to ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.11 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.12 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. 4.13 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.14 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.15 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.16 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Councils do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this, but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.17 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to the Gaydon/Lighthorne Heath new settlement which provide access to an emerging and growing labour market. 4.18 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the Automotive cluster further expands the likelihood for further associated distribution space is likely to increase. 4.19 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and this Site would help to realise the potential of the Gaydon area/M40 Junction 12 as a Major Investment Site.
Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The Iceni report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs. It is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the Strategic Distribution Needs, including through some provision at Gaydon/Lighthorne Heath, will ensure the South Warwickshire Plan takes a positive position on economic growth which in turn will support the South Warwickshire Economy. Issue E3: Diversifying the economy Q-E3: Please select all options which are appropriate for South Warwickshire 4.6 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.7 Given that the scope of the South Warwickshire Local Plan is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors. There is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.8 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.9 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including Gaydon and major road infrastructure aligned to the key settlements of Stratford -upon-Avon, Warwick and Leamington, specifically the M40 corridor. 4.10 To ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.11 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.12 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. Specifically, previous work undertaken by CEG and the Bird Group relating to the area subject to these representations consider that the site / area has the potential to become a regionally significant employment hub augmenting the current economic strengths associated with the Jaguar Land Rover / Aston Martin Lagonda operations. 4.13 Initial master planning and economic modelling of the land identified for employment (albeit for the benefit of JLR in current policy) in the adopted ‘Land at Gaydon / Lighthorne Heath Supplementary Planning Document ‘demonstrates that the Site can accommodate in the region of 2.8 million sq ft of employment floorspace. This has the ability to generate approximately £11.6 million in business rates; 6,000 direct full-time jobs and £1.0 Billion additional GVA to the local economy from the ongoing operation of the employment area. Importantly, it would contribute significantly to the identified Coventry and Warwickshire economic needs as set out in the 2022 Needs Assessment (prepared by Iceni); providing a range of employment activities in support of the supply chain activities associated with the Regions automotive and technology-based research and manufacturing industries. 4.14 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.15 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.16 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.17 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Council’s do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.18 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to Upper Lighthorne which provide access to an emerging and growing labour market. 4.19 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the automotive cluster further expands, the likely demand for further associated distribution space is likely to increase. 4.20 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and providing open-market commercial space at Gaydon/Lighthorne Heath would assist with realising the wider potential of Gaydon as a Major Investment Site.
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 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 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 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 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 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 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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Issue E1: Growing the South Warwickshire economy Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the sub-regional Strategic Distribution Needs, including through identifying some provision South of Junction 12 of the M40, will ensure the South Warwickshire plan takes a positive position on economic growth and in turn support the South Warwickshire Economy. Further to these over-arching needs, there is immediate demand for space within the District and CEG have very strong occupier interest in this Site for employment use. An application is being prepared accordingly. Q-E3: Please select all options which are appropriate for South Warwickshire 4.1 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.2 Given that the scope of the South Warwickshire Local Plan is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.3 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.4 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including the Gaydon and major road infrastructure aligned to the key settlements of Stratford – Upon-Avon, Warwick and Leamington. 4.5 Therefore, to ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.1 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.2 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. 4.3 This Site, south of Junction 12 of the M40, could play a significant role. Initial master planning undertaken by CEG has identified that the Site has the capacity for circa 90,000 sqm of commercial floorspace. Economic modelling has confirmed that this could generate in the region 1,900 full-time equivalent (FTE) jobs on site and 1,000 indirect FTE jobs through the supply chain. The approximate operational economic output (GVA) is estimated at £398 million. This would contribute significantly to the local economy and to the identified Coventry and Warwickshire economic needs as set out in the 2022 Needs Assessment prepared by Iceni. 4.4 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.5 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.6 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.7 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Council’s do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.8 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to the Gaydon/Lighthorne Heath new settlement which provide access to an emerging and growing labour market. 4.9 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the Automotive cluster further expands the likelihood for further associated distribution space is likely to increase. 4.10 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and Land at Junction 12 would help to realise the potential of the Gaydon area/M40 Junction 12 as a Major Investment Site.
