Issue and Options 2023

No

A Two Part Plan We have some concerns with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and allocate the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach is problematic as it will delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). The Local Plan Part 2 will need to be prepared to be in general conformity with the SWLP Part 1. It is unlikely that the Part 2 Plan will be adopted for at least two to three years following the adoption of the SWLP Part 1 even if their preparation overlaps. Indeed, the Stratford-on-Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not adopted. This means that no localised allocations will be in place until late 2027 at the earliest, given past planning performance it is likely to be much later than this. As a significant proportion of the housing allocations will not be in place for a number of years, this has the potential to significantly harm housing delivery. Preparing a two part plan will delay the delivery of much needed market and affordable housing and non strategic employment sites during first part of the plan period. This will make home ownership more challenging, has potential to increase house prices and worsen affordability and hinder affordable housing delivery. It could also stifle economic growth. This will directly conflict with the Draft Plan’s Strategic Objective of delivering homes that meets the needs of all the plan areas communities (SO 4) and developing Job Opportunities (SO 3). It could also result in a 5 year housing land supply shortfall and increase the number of speculative planning applications. The Plan Period We support the preparation of a plan that will run to 2050. Having an extended plan period will allow for the SWLP to properly respond to long term issues, and support the allocations of larger, strategic sites that will deliver over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies to respond to the fact that the local economy and housing needs are likely to change significantly during the course of the period 2050. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that in addition to the existing evidence base studies additional technical studies will be commissioned to inform the SWLP as required. One of the identified potential additional studies is a Green Belt study. We have no objection to the preparation of a Green Belt study. There are, however, a number of development opportunities available to the Council that are outside of the Green Belt. Suitable and sustainable non Green Belt development options should be prioritised ahead of Green Belt land release. For example, Spitfire control land at Stratford Agricultural Park to the immediate east of the Long Marston Airfield (LMA) new settlement. As detailed in our Call for Site submission, this site provides an opportunity to expand LMA, providing housing and supporting infrastructure to support LMAs services and facilities helping increase its self-containment. It is readily deliverable and in the control of a developer.

Yes

The Vision Spitfire support the Vision outlined in the Draft Plan. The objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities is fully supported. We agree that this should be done in a sustainable way, responding to the climate emergency, and the five overarching objectives will help ensure that development is delivered in the right locations provided that they are reflected through SWLP’s policies and allocations. The Strategic Objective We support and have comments on a number of the Strategic Objectives identified by the Draft Plan. These include: • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. There is the opportunity to include allocations in the SWLP that will deliver infrastructure that supports not just the proposed development, but also delivers onsite facilities that can benefit the local area as a whole. In addition, development can be delivered that can help support existing social infrastructure. For example, the Long Marston Airfield New Settlement is expected to provide 3,500 dwellings, alongside two primary schools and a secondary school. 3,500 dwellings will not support a new secondary school. Directing additional development to Long Marston Airfield will help support the secondary school and reduce its catchment area, as well as supporting the proposed shops. • Developing opportunities for jobs – We fully support this objective. Making residential allocations in locations that have easy access to employment opportunities by sustainable transport modes should be a preferred approach in planning to support economic development. Furthermore, an increased proportion of people now work from home. Residential and mixed use sites that can provide facilities to help supporting people working from home should be supported. • Delivering homes that meet the needs of all our communities – It is imperative that residential allocations of different sizes are made across the plan area to meet the housing needs of South Warwickshire and any unmet needs arising from neighbouring authorities. A range of housing allocations are required, from small scale sites that can deliver development promptly, to larger sites that can deliver significant amounts of housing over a longer period of time that will naturally have longer lead in times. Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. • Contributing towards a net zero carbon target – Development opportunities that can provide proportionate amounts of green infrastructure and have access to services and facilities by sustainable means, should be preferred locations for an allocation to help deliver this objective. • Connecting people to places – We actively support the objective of increasing and improving access by sustainable and active travel modes. Allocations that are located close to public transport opportunities, educational facilities, green spaces, and employment opportunities, or can provide these opportunities on site, should be preferred. • Protecting and enhancing environmental assets – We support the objective of protecting and enhancing environmental assets. The SWLP should look to support allocations that can provide appropriate biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.

The SA testing of Growth Options against the 13 criteria identified in paragraph 2.21 of the report is appropriate. These criteria reflect the objectives of the SWLP and the topics identified in Annex 1(f) of the SEA directives. The outcomes of the assessment process, however, needs to be treated with caution. The SA is a snapshot in time. It assesses the sustainability of the Growth Options and potential locations for allocations on the basis of the current services and facilities that are available and on existing constraints. For example, when assessing the Draft Plan policies, growth options and potential locations for development against Matter 11 – Education, regard has been had to existing education provision in the locality. It does not, however, consider how new development could improve local education facilities, through the provision of a new education infrastructure, such as new schools or the contributions that can be made to improve existing facilities. It is appreciated that this is a difficult process, until the current Call for Sites consultation is completed and responses reviewed, the local authorities will not have a clear understanding of what services and facilities are being promoted with the various development opportunities being presented. However, in due course this should be a key consideration for the local authorities in determining the preferred strategy, growth options and allocations within the SWLP. Climate Change While the assessment of the proposals against climate change objectives is required, there are concerns with the way in which this has been applied in the SA. It is advised at paragraph 2.4.6 of the SA that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses), are likely to increase greenhouse gas emissions in the plan area by more than 1% and adversely affect climate change in the future. Developments of between 50 to 500 dwellings could increase carbon emissions in the plan area by more than 0.1% and have a lesser effect on climate change. As a consequence, it is effectively concludes that larger schemes are likely to result in a greater amount of greenhouse gas emissions than smaller development proposals. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have a set housing requirement. That housing requirement will be delivered through various residential developments of different sizes. The greenhouse gas emissions from the construction operation of these properties will have a total accumulative effect based on the total number of houses built. This significance will be broadly the same, regardless of whether the houses are delivered through a larger number of small sites or a smaller number of large sites. The SWLP should consider the most appropriate way of delivering the houses in order to try to reduce greenhouse gas emissions because although larger developments may have relatively bigger higher emissions of greenhouse gases the amount emitted to deliver all the housing need will remain unchanged.. It is also suggested that development of greenfield sites for housing has a potential to lead to local, long term significant adverse effects in the form of increasing flooding, drought and storm events. This is not necessarily the case. Indeed, it is not uncommon for new development to introduce flood risk and drainage control measures that improve the flood risk and drainage situations locally. New developments must achieve greenfield run off rates and can often be used to address localised problems associated with flood risk. It is inappropriate for it to be immediately assumed that the development of greenfield sites can have adverse effects on flooding, drought and storm events. Biodiversity and Geodiversity The impact of development on biodiversity and geodiversity is a clear consideration in the SA process. However, the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in this report (paragraph 2.6.14) and detailed ecology surveys and assessments will determine, on a site by site basis, the presence of priority species and priority habitats (paragraph 2.6.12). The SA has, therefore, made assumptions about the sensitivity or otherwise of potential development options from an ecological basis linked to their proximity to identified assets. That being the case, the conclusions reached regarding the ecological sensitivity of development option needs to be treated with considerable caution. If more detailed site specific ecological information available from the Call for Site submissions this should be actively considered in the site selection process. Landscape The SA advises at paragraph 2.7.2 that detailed designs for each development appraisal are uncertain at this stage of the assessment. The landscape assessment is a desk based exercise which has not been verified in the field. Therefore, the nature of potential impacts on the landscape is uncertain. Furthermore, it is recognised and recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. Consequently, the landscape appraisal selection of the SA should be treated with caution as the evidence base is not complete. Cultural Heritage It is advised at paragraph 2.8.3 of the SA that impacts on heritage assets will largely be determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. At this stage, the risk of substantial harm to the significance of the heritage asset has been assessed based on the nature and significance of, and proximity of sites to, the heritage asset in question. It is also advised that whilst the Heritage and Settlement Sensitivity Assessment is being prepared, this assessment was not available for use at the time of undertaking the SA process. The conclusions of the SA must, therefore, be treated with caution. Where site specific heritage information has been provided with our Call for Sites submission, this should be considered in the site selection process. Environmental Pollution There is concern about some of the assessment criteria used within the environmental pollution section. Development proposals that are within 200 metres of a railway station are negatively scored. Development proposals located over 200 metres from a railway station have a neutral score. In addition, it is suggested within the SA that schemes within 200 metres of a major road may have adverse sustainability impacts due to road related air and noise emissions. These conclusions do not automatically follow as it is possible for sites within the metres of railway lines and main roads to achieve suitable noise and environmental air quality standards. This assessment criteria should be reconsidered. Natural Resources We are concerned with the SA approach towards assessing the agricultural land implications of development. Development proposals that include over 20 hectares of Grade 1, 2 or 3 agricultural land score a double negative while development proposals that include an area of land of less than 20 hectares of Grade 1, 2 or 3 agricultural land have a single negative impact. This is misleading as it the total number of houses that is relevant and not the number or size of the developments. The SWLP will have to allocate land to deliver a set amount of housing. This will be from a combination of brownfield and greenfield sites. The amount of agricultural land developed in the plan area as a whole is likely to be fixed, as the housing requirement will be fixed. Health Impact Development options are scored down if they are more than 800 metres from an area of green space, or 600 metres away from a public right of way or cycle path. Development proposals will, in all likelihood, provide onsite green space to meet their needs, and may be able to provide connections to nearby footpaths/cycle paths. Accessibility The SA accessibility assessment criteria for proximity to bus stops and food stores advises that sites that are more than 400 metres from a bus stop and sites that are 800 metres from the food store will receive a negative rating. Whilst this is a sensible starting point, large scale developments will, in all likelihood, provide new bus stops and convenience stores. Indeed, we would fully expect the local authority to require these larger schemes to include a local centre. As a consequence, the assessment criteria must be treated with caution as part of the site selection process. Similarly, development options that are located over 800 metres from a primary school have a negative rating. Large scale sites are likely to provide primary schools. Indeed, we would expect primary school provision to be a key component of any scheme providing 800+ dwellings. Economy The SA assessment criteria for economic opportunities penalises schemes that are more than 5km from a “key employment location” whilst positively scores sites that are within 5km of a key employment location. Large scale residential sites are, in all likelihood, likely to provide employment opportunities as part of the overall proposals. It is, therefore, inappropriate to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision. Initial Identification of Settlements The 30 settlements identified in paragraph 3.5.2 of the report are a combination of the main settlements, that expect to be able to deliver up to 2,000 homes, as well as smaller locations that might be able to deliver between 50 and 500 homes. We suggest that it would be prudent to also include the new settlement at Long Marston within the list of the settlements to be assessed as it is intended to deliver a significant amount of development and will include new services and facilities that will help sustain new development going forward. This matter should be re-considered.

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Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire As referred to earlier in our representations, it is our view that it would be preferable to prepare a single Local Plan rather than a two part plan. Adopting this approach would remove the complications identified on page 30 of the draft Plan regarding the way in which a two part plan could secure appropriate infrastructure provision with new developments. However, if the Council decide to pursue a two part Local Plan we suggest that the policies guiding the development of the strategic allocations identify the infrastructure requirements for the developments. Given the nature of strategic allocations the infrastructure requirements will vary from site to site. We support the recognition that the infrastructure requirements of the development strategy are critical in ensuring that development is truly sustainable. That being the case, as part of the site selection process one of the critical considerations should be the onsite infrastructure that is being proposed to support the development. Long Marston Airfield has planning permission for the development of 3,500 dwellings, employment land and supporting infrastructure. However, it is our understanding that there are currently highways infrastructure constraints capping the amount of development that can come forward on the site. These constraints effect the ability of the land south of Stratford-upon-Avon to accommodate any additional development. This is a matter that must be resolved to allow Long Marston Airfield to be delivered, and to allow development to take place in the general proximity of one of the plan areas most sustainable settlements. The SWLP should be prepared on the basis of a strategy that looks to resolve any highways constraints associated with development to the south of Stratford upon Avon. Alongside the site specific requirements, a general infrastructure policy could be included within the plan for windfall sites and other sites that come forward for development prior to the adoption of the part two plan. This would provide certainty to developers as to what infrastructure would be required as part of their development proposals. Q-I3 – Please select the CIL option which is most appropriate for South Warwickshire This matter should be kept under review. It is possible that the CIL system will have been replaced by the time the plan is adopted. If the Councils do pursue a CIL its requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. The impact on CIL on the ability of sites to secure affordable housing provision must also be considered. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability We support the recognition that the development strategy needs to be deliverable and viable and that there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The SWLP should play a key role in looking to support the provision of the infrastructure required to deliver new development. We note that all development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. We fully support this approach. It may be appropriate, in certain instances, for the SWLP to prioritise the funding of certain infrastructure improvements, such as those identified on page 32, over other planning obligations. These infrastructure improvements will help deliver key objectives of the SWLP and facilitate development generally.

Yes

Part 4 of the Draft Plan identifies a series of existing infrastructure schemes proposed across both plan areas. It is our view that it would be sensible to include a policy in the SWLP to guide the schemes. The policy should confirm the location of the works, which should be identified on the Policy Map, and the extent of the work involved. There should be a clear commitment to their delivery and an explanation as to how they will be funded. It should also be clear if developments are expected to contribute towards schemes as part of their planning obligation package. In addition, as referred to earlier in our submission, it is likely that there will be site specific infrastructure requirements for certain allocations. These should be identified in the allocation policy and, where appropriate, the allocation policy should cross-refer to wider strategic infrastructure projects where specific contributions are expected.

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Q-S1 – Please select the strategic green and blue infrastructure option which is most appropriate for South Warwickshire We fully support the Local Plan including policies on the provision of strategic blue and green infrastructure. However, the preparation of the Plan should not be delayed by the production of the Local Nature Recovery Strategy. In addition, the Local Nature Recovery Strategy will not be tested in the same way development plan policies will through the examination process. It is, therefore, our view that the preferred approach should be Policy S1a, identification of strategic green and blue corridors in the SWLP in advance of the preparation of a Local Nature Recovery Strategy, so that this policy can be brought forward in a timely manner and tested through the examination process. It is noted that page 34 of the Plan advises that it is anticipated that the Part 1 Plan will set out the development principles and associated blue and green infrastructure required for the broad locations that are identified, and the Part 2 Plan will provide more details on the strategic locations and also set out the development principles and details on the non-strategic locations identified for growth. As detailed elsewhere within our representations, we object to the preparation of a two part plan. However, if this is ultimately the preferred approach the Part 1 Plan should not defer to the Part 2 Plan for additional details on the strategic locations for growth as it may delay their delivery. The policy guidance for the strategic allocations contained within the Part 1 Plan should be sufficient for them to be brought forward immediately, without having to delay the preparation of applications until the completion of the Part 2 Plan. The Part 1 Plan will need to make it clear that the strategic sites can be brought forward for development upon adoption of the Part 1 Plan in order to ensure that there is a continue supply of housing and employment land. QS2 – Please select the intensification options which are most appropriate of the South Warwickshire Whilst we fully support making the best use of available sites, the plan needs to be realistic in terms of the ability of an intensification policy to deliver additional development. Page 39 of the Draft Plan advises that intensification can be achieved in a number of ways. We comment on these options as set out below: • Conversion of upper floors of buildings to residential use We have no objection to this proposal, however, permitted development rights and positive planning policies in general have facilitated in bringing the upper floors of buildings back into residential use for a number of years. The inclusion of a policy supporting such proposals is unlikely to result in any significant increase in dwellings. • Additional storeys and buildings This is an unreliable source of housing. There needs to be an understanding of whether buildings are structurally capable and designed in such a way to allow additional floors added to them. Also, there may be design implications and visual impact issues associated with the creation of additional stories. There have been permitted development rights in place for a number of years that allow for the development of two extra stories of accommodation on certain buildings, meaning that such schemes can already come forward in a number of instances. This is unlikely to be a significant source of supply. • Re-use of empty homes When a home is empty it is often for good reason. For example, an elderly person going into care accommodation with the hope that they may return home, or general churn in the housing stock. Furthermore, re-using an empty home is not a “net” source of supply unless once the property became vacant it was recorded in the housing land supply calculations as a loss of a dwelling, which we very much doubt it will have been. There is the potential for there to be double counting from this source of supply. • Infill in residential areas There are positive policies in place for filling the gaps in street frontage and developing disused garage blocks within the adopted Local Plans. A policy supporting infill development is unlikely to result in additional sites coming forward beyond those that are already available. We have significant concerns with the suggestion that car parks could be developed for housing. A car parking strategy would need to be prepared in order to establish whether these car parks are required, as removing car parks could impact on local shops and services where customers use the car parks, or reducing car parking space available in residential areas resulting in additional on street parking. In addition, all of these sources of supply would, in effect, be windfall sites. They are not a new source of supply that will be boosted by the inclusion of a policy in the SWLP. In terms of new developments there needs to be a realistic consideration of the net developable areas and densities that can be achieved. In order to secure high quality design, new developments will need to provide on site open space, green infrastructure and have the ability to satisfy biodiversity net gain requirements This is likely to impact upon the net to growth land ratio available. Indeed, if it is assumed that 40% of greenfield sites will be required for green infrastructure and biodiversity net gain offsetting, this is likely to reduce the total net developable area to around 50% of the gross when infrastructure requirements are considered. Indeed, we note that the plan’s ecological policies suggest that 50% of sites may need to be set aside for green and blue infrastructure (Option C9.1a). Furthermore, we expect the Plan will require a variety of house types to come forward, ranging from bungalows and apartments, to larger 3, 4 + bed properties. Sufficient car parking must be provided within residential schemes in order to try to avoid on street car parking. There will also be areas within the Plan, such as on the edge of settlements and villages, where densities will have to reflect the character of the surrounding area in order to provide a high quality design. In summary, whilst we have no objection to the inclusion of an intensification policy, it is our view that it is highly unlikely to result in significant additional development and should not be treated as a new source of housing land supply beyond that expected from windfalls. Q-S4.1 – Do you think the growth of some of our existing settlements should be part of the overall strategy? Yes. The growth of the existing settlements should be a key part of the growth strategy of the Plan. The SWLP’s housing and employment requirement should be delivered principally through the expansion of existing towns and settlements. The level of development directed to each of the settlements within the plan area should be influenced by a series of factors. This includes the level of service provision within each of the subject towns and the nature of the development opportunities being proposed in these locations. For example, expanding the Long Marston Airfield new settlement should be a key objective of the plan. Long Marston Airfield is relatively small for a new settlement. The Draft Plan advises that new settlements should provide 6,000 dwellings. Long Marston Airfield is allocated for and has planning permission for 3,500 dwelling alongside employment land and supporting infrastructure. Increasing its size will supports its school, services and facilities. It will increase the size of the workforce available to support the approved employment land. Further details on this matter can be found in our Call for Sites submission. Q-S5.2 – Do you think the new settlements should be part of the overall strategy? The development of new settlements can be an effective way of delivering a significant amount of housing and supporting infrastructure through the plan making process. However, new settlements that require a complete infrastructure package will, in all likelihood, take at least 5 to 6 years from the allocation plan to start to deliver housing. They must, therefore, be supplemented by smaller allocations. In terms of infrastructure thresholds, it is noted that it is advised that 6,000 dwellings is the minimum size of a new settlement. As referred to above, whilst Long Marston Airfield is identified as a new Settlement by the adopted Stratford on Avon Core Strategy it is 3,500 dwellings in size. Directing additional development to Long Marston would bolster its role as a new settlement, with additional footfall supporting its schools, services and facilities and helping to deliver critical infrastructure.

We support the preparation of the South Warwickshire Urban Capacity Study. It is a useful document to help understand the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements will be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. Certain brownfield sites may not be suitable for residential development on viability grounds, or unable to support a “full” S.106 package with reduced contributions towards affordable housing amongst other matters. This could be exacerbated by the introduction of NDSS policy and the other provisions of the emerging plan. That being the case, whilst we support the plan making the best use of previously developed land within the existing settlements as a possible location for residential development, these sites must be treated with caution. There is currently insufficient information available to establish the role these sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance accordingly.

Yes

Long Marston Airfield New Settlement has been omitted from the Settlement Analysis. This is a significant omission. It is identified as a potential location for a New Settlement by Figure 12, a potential Rail Corridor development option by Figure 16, a Sustainable Travel development option by Figure 17, an Economic Development opportunity by Figure 18, a Sustainable Travel and Economy Option by Figure 19 and a Dispersed Development option by Figure 20. Long Marston Airfield can fulfil a role under all of the SWLPs Growth Options. We are concerned that the failure for it to be included with the Settlement Analysis could hinder its assessment as a potential development location. This should not be the case.