Issue and Options 2023

Yes

We agree with the overall Vision and Strategic Objectives. The Vision provides a clear framework for strategic sustainable growth over the Plan period (to 2050). However, in combination, the Vision and Objectives are also broad enough to respond to change and provide flexibility, which is a vital requirement in ensuring that the Local Plan can respond to change and remain relevant over the course of the Plan period.

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Q-I2 Response: The Local Plan should contain enough flexibility to adapt to change over the course of the Plan period. To ensure that the Plan remains relevant for the duration, it would not be appropriate to set out all of the infrastructure requirements at all scales immediately. This would remove flexibility and could result in the Plan becoming hostage to fortune. If option 12a was taken forward it would need to be a relatively high level approach to the infrastructure requirements, so as not to prejudice opportunities in the future. In this context, option 12b would appear to be the most appropriate option to take forward. It would help to secure the delivery of any specific, targeted, strategic infrastructure identified as being required now, whilst enabling the Councils to adapt to changing circumstances and requirements in the future. Q-I5 Response: We agree that the development strategy needs to “be both deliverable and viable”. It is imperative that the Plan is able to deliver on its ambitions, in order to ensure that the social, economic and environmental objectives are met. Notwithstanding, it is important that the Plan appropriately acknowledges the significant investment that development can bring to local areas and, indeed, at scale, regions. In this context, it is also vital that development is not constrained through a lack of ambition or delivery of strategic infrastructure. The relationship between infrastructure, investment and development is reciprocal and not mutually exclusive. It is of paramount importance to the success of Strategic Plans that key infrastructure is in place to support the developments coming forward and the communities that they affect. Land at Red House Farm presents a superb opportunity for the Council to allocate development which has the capacity to help deliver a significant employment scheme, alongside addressing existing connectivity issues surrounding junctions 13 and 14 of the M40, through the introduction of an entirely new junction and the closure of these two, under-performing junctions.

Q-S7.2 - Response: Whilst we understand the reasoning behind removing the Green Belt in consideration of the holistic growth options at this stage, it makes it difficult to identify a specific strategy that will be appropriate from the options presented. Green Belt is not a neutral factor and will play an important role in the eventual consideration and choice of sites for allocation in the Local Plan. In this regard, a strategy which seeks to ensure that the right sites, in the right location, are identified for sustainable growth will have to consider Green Belt constraints. Sites which can deliver economic, social and environmental benefits without impinging on the Green Belt should be prioritised for allocation. Notwithstanding, of the options presented, a hybrid, synergising options 1-4 would, at this stage, seem the most logical approach. Option 5 (dispersed growth) does not appear sustainable as it disperses development too greatly across South Warwickshire, which would not encourage sustainable travel, as noted in the supporting text. Land at Red House Farm provides the opportunity to deliver significant, mixed employment development, with the associated benefit of a new motorway junction in a well connected location which, significantly and importantly, is outside of the Green Belt. Q-S10 - Response: It is important that the final growth option taken forward does not constrain economic growth, which (particularly in the logistics and warehouse sector) is greatly driven by market demand and accessibility to the Strategic Road Network. In this context, it is also important that there is a clear distinction drawn between considering sites for housing growth and employment schemes. Whilst connectivity is important for both housing and employment sites, the fundamentals of these connections are different. Housing schemes need to be well related to places where people will work and play. However, for employment schemes there is the added requirement of strategic connections to the markets they serve; this can be regionally, nationally and internationally.

Yes

We consider that the HEDNA provides a reasonable basis to begin identifying future levels of employment need. However, it should not be relied upon solely. As we noted in our representations to the previous consultation, the evidence base should not only focus on past trends, but consider, as far as possible, likely future impacts and cumulative effects of historical and ongoing shortages. The last few years have shown, albeit in unprecedented circumstances, how quickly change can come about. This has served to highlight the need for the ability to provide rapid responses to a changing context throughout all forms of Plan making. In this regard, the Local Plan should include sufficient flexibility to meet anticipated need and adopt to unanticipated changes. This requires the Plan to be ambitious in its growth proposals. Figures derived from the HEDNA should be set as minimum requirements and should not place a cap on the level of economic development to be delivered.

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Q-E2 Response: With regard to the low carbon economy, we believe that option E2a would be the most appropriate and sustainable option. However, any emerging policy should not be too prescriptive and risk stifling innovation. The transition to a low carbon economy is crucial, but this must be balanced with realistic ambitions and objectives. Businesses striving to deliver on sustainability objectives for a low carbon future should be encouraged to invest in South Warwickshire through innovative and exciting policy ambitions, which enable them to demonstrate their approach to addressing the climate emergency.In this context, there is not a ‘one size fits all’ approach to delivering a low carbon economy and the Local Plan should be clear that innovation is encouraged. Q-E3 Response: Of the options presented Policy E3c appears most sustainable. It allows flexibility in enabling employment training provision to be tailored to any site or development specific context. This is the process followed by other Councils, so there is a proven track record of this approach. Q-E7.1 Response: We agree with the ‘Core Opportunity Area’ identified in Figure 21 of the consultation document and the principle of Option E7.1a. The area identified is a logical focused area for strategic employment growth, covering the main towns and villages within South Warwickshire and incorporating the key junctions and accesses associated with the Strategic Road Network. The HEDNA identifies a need to meet strategic B8 requirements and highlights key locational considerations for assessing the appropriateness of sites. These include road accessibility; power supply; labour availability; and neighbouring activities. It states that there is the potential for the sub-region, specifically South Warwickshire, to play a greater role in providing strategic B8 development, including along the M40 corridor where there “is potential to consider provision at or close to junctions on this corridor within the sub-region”. The proposed Core Opportunity Area appears to positively respond to the HEDNA findings.The Red House Farm site is situated centrally within the Core Opportunity Area, which highlights not only its excellent strategic location for employment growth but also the opportunity for the site to improve connectivity along the M40 and provide an enhanced ‘Gateway’ into Royal Leamington Spa and Warwick within this wider area of opportunity.As noted in the supporting text, South Warwickshire benefits from various sites and businesses which already make a significant contribution to the local and regional economy. These sites and businesses should be protected and retained to allow South Warwickshire to achieve its full potential in both investment and economic output.Importantly, new sites, such as Red House Farm would not detract from the existing employment locations, rather, they would open up further opportunities for investment, both complementing and diversifying the offer available to businesses and investors. Q-E7.2 Response: Whilst the ambitions of including a policy to direct specific types of development to the existing major investment sites is rational, it could have unintended consequences of stifling investment opportunities by placing unnecessary restrictions on existing sites. It could also prevent other sites, which may better suit some occupiers’ requirements, from receiving investment. Consequently, we consider that Option E7.2b should be taken forward. Nevertheless, we agree with the supporting text which, with regard to the Gaydon Area/M40 Junction 12, states “Whilst well-located to the M40, we do not see this location as appropriate for strategic logistic uses (i.e. Use Class B8).” This location is an automotive hub and should be encouraged to capitalise on that status.

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