Issue and Options 2023
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New searchIssue B1: Areas of Restraint Please select the option which is most appropriate for South Warwickshire Q-B1 Option B1a We consider that Areas of Restraint are an effective policy tool for ensuring development is kept free of identified development parcels. This has been a long-standing policy commitment in Stratford and, for consistency, this should be applied to Warwick too. It would allow for a hierarchical approach, which is embedded in the NPPF, and as such would be consistent with national policy. The precise Areas of Restraint should be the subject of thorough evidence base testing and consulted upon as the SWLP advances. Issue B5: Environmental Net Gain Q-B5 a We consider that the work should be undertaken by the Council to explore and potentially pursue and integrated Environmental Net Gain Policy which will support natures recovery. We are aware of the governments Environmental Improvement Plan 2023 which seeks to halt and reverse the decline in nature – in the reaching of this goal, there should be a reduction in environmental pollution which would include noise, water quality, soil, carbon capture. One policy to deal with these elements seems sensible. As always though, any such policy would need to be evidence tested and thoroughly consulted upon. There would also need to be an awareness of the implications on viability – if overly onerous, the policy could act as a real dis-incentive for developers, who would seek instead, to build outside of South Warwickshire. Issue B8: Agricultural Land Q-B8.1 Do you agree that the plan should include a policy avoiding development on best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefits of development? Yes. We recognise the importance of BMV in considering development proposals. However, any such loss of BMV needs to be balanced with the competing – and highly important – need to deliver housing and other development. Any policy which restricts the loss of BMV would be inappropriate, and beyond the scope of the NPPF which would fail the tests of soundness. It is however appropriate to provide a policy which recognises the importance of BMV but allows for its loss where it is outweighed by the need for new development. Issue B9: Protecting Biodiversity and Geodiversity assets Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites? Yes – although SSSIs are protected by national policy. Paragraph 175 states that plans should distinguish between the hierarchy of international, national and locally designated sites, and on this basis such a policy should be included.
We agree with the proposed broad content of the Part 1 plan, which would deal with the vision, strategic objectives, growth strategy and strategic policies. This approach, would in our view could expedite the plan making process, provide clarity and certainty for developers and allow a focus on the strategic priorities. However, we do continue to have reservations as indicated to our response to the scoping consultation, repeated below. In splitting the Local Plan out as envisaged, it is important that the part 1 Local Plan progresses on its own LDS programme/timetable and advances to adoption as expediently as is reasonably possible. It would not be appropriate for the part 1 Local Plan to be delayed to tie in with an LDS programme in relation to other elements of the Development Plan. It is also important that the part 1 Local Plan is the subject of its own examination – by way of example, in North Essex the three Councils submitted both their part 1 and part 2 Local Plans concurrently, and because the part 1 Local Plan was significantly delayed at examination stage (and significantly altered through the examination) it caused a follow-on significant delay to the part 2 Local Plan without the Councils being able to make any changes to part 2 plan content. It is also the case that deferring all allocations to later parts of the Development Plan relies upon those later parts being found sound. Were that not to be the case, the result would be a defined development strategy and housing and other development needs but no delivery mechanism absent of any positive allocations to implement the part 1 requirements. This is precisely the trap South Kesteven fell in to with their Development Plan – the Core Strategy identified a development strategy heavily reliant on Grantham (with over 50% of the entire plan period housing to be delivered at Grantham) and allocations deferred to an AAP. The AAP was found unsound at examination, and with no ability to deliver housing at Grantham the Council were faced with unplanned housing applications to determine.
It is important to have in mind that South Warwickshire is to grow and evolve in the plan period to 2050. Change is inevitable, and the planning process functions to support sustainable growth and should not be applied to stymie or otherwise place unnecessary obstacles in the way of new development. Thus, tackling the climate emergency cannot be at the expense of delivering new housing, employment and retail and other space. We consider that the Vision has been modified to better reflect this important principle, and one of the six Strategic Objectives now relates to meeting sustainable development needs. This is welcomed and reflects our earlier submissions. However, we consider that this should be further amended to make clear that development needs must be met in any event, and that it is for the plan to set out how this is achieved sustainably.
The SA prepared to support the Issues and Options explores reasonable options in relation to: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. • 116 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. Each option has been assessed/scored against each of the 13 SA objectives in relation to 1. climate change; 2.flood risk; 3. biodiversity and geodiversity; 4. landscape; 5. cultural heritage; 6. pollution; 7. natural resources; 8.waste; 9. housing; 10. health; 11. transport; 12. education and 13. economy. The comments below relate first of all to the housing numbers and then to the growth options and broad locations around main settlements. Housing numbers Two reasonable alternatives to establishing housing number calculations have been undertaken. Option 1 – the HEDNA trend- based projections which point to a need for 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum in Warwick – total of 1,679 dwellings per annum. Option 2 – uses the Standard Method and identifies the need of 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum in Warwick – total of 1,239 dwellings per annum. It is reported within the SA that using the HEDNA figure would more accurately represent local housing need and would better meet the needs of the various members of the community (including affordable homes, student accommodation, older people’s accommodation, specialist housing and custom and self-build plus gypsy and traveller and travelling show people communities). Both options have a similar negative impact on climate change, biodiversity, pollution, natural resources and potentially waste. Option 1 would likely have a greater adverse impact on landscape and townscape character due to higher housing numbers. Both options have a similar minor positive impact on 11 – transport, by the location of new housing in closer proximity to workplaces. The consideration of housing numbers does not provide any locational information and so the impacts in relation to climate change, cultural heritage, health, education is uncertain. Whilst overall, at this stage option 2 appears to perform better overall, we would support the use of the higher HEDNA figure which will allow flexibility within the overall development strategy. This will enable the plan to accommodate a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry. Growth options As set out in the SA, scores each option against the SA objective, which indicates that each option is likely to perform better than others. All perform positively in relation to employment and housing and so, at this stage, no stage should be ruled out in our view. The broad locations for proposed new development have also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratford-upon-Avon and Warwick. These locations were further analysed to test distances from GP surgeries, schools, public transport etc, to remove land within flood zones 2 or 3, AONB, Grade 1 agricultural land, scheduled monuments, SSSI, Registered Parks and Gardens and Ancient Woodland. These broad locations all perform similarly against the SA objectives and at this stage, we would consider it too early to discount any broad locations without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. The same principle is considered appropriate in terms of reasonable alternatives put forward in relation to small settlement locations. Early indications within the SA consideration in relation to New Settlements suggest that this growth option would perform poorly against climate change overall and waste, use of natural resources and landscape; some performing poorly against flood risk, pollution, health, education and biodiversity and local wildlife sites. Whilst this option would achieve up to 6,000 dwellings, thereby resulting in a significant contribution towards meeting the housing need, and seen as being a major positive impact on housing provision, these large-scale developments invariably take years to come to fruition, requiring major investment in all types of infrastructure before housing can come forward. Numerous local plans relying on this type of option have failed. This option, in our opinion therefore is the least favoured and potentially should be ruled out at this stage.
Q-I4.1 Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes, in part. We consider that it is appropriate for a policy to safeguard specific infrastructure schemes within the SWLP, where those infrastructure schemes have been evidenced through the plan making process. Where infrastructure schemes have not been evidenced, it would be inappropriate for the plan to specify and safeguard such schemes, since these would not be justified having regard to the tests of soundness embedded in the NPPF. Where specific infrastructure schemes are safeguarded, the policy must be sufficiently flexible to be adaptable to changing circumstances. For example, one such infrastructure scheme which may be safeguarded is the improvement of the A46 at Bishopton and Wildmoor junctions. We are aware that scheme proposals for junction improvements are evolving, and the land take required may change over time. Where a plan showing the extent of safeguarding is embedded in the SWLP it should be made clear that the precise extent of safeguarding may change (either extending or shrinking) due to changing circumstances.
Issue I2 Infrastructure Requirements and Delivery Q12a: This option, to set out infrastructure for all scales, types and location of development within Part 1 of the Local Plan is considered is preferred. This would allow the requirements to be applied equally across the District and provide developers with more certainty when coming to consider implications for proposed development/proposed sites across both Stratford and Warwick. Issue I3 CIL Q-13a: This option for CIL is preferred, which would set a single levy for the whole of South Warwickshire. This would give developers greater certainty regarding likely development costs.
