Issue and Options 2023

Q-E.1.1 – Do you think the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? The HEDNA advises at Table 6.5 – Projected Growth in Employment by District, that Stratford-on-Avon and and Warwick District’s employment levels are expected to increase by 11% and 14% respectively during the Plan period. The Draft Plan highlights that South Warwickshire has been successful over many years in attracting major employers across a range of high value sectors, notably vehicle design and engineering, software and games development and HQ and professional and financial services. It has also benefited from a robust tourism sector, linked to its various cultural assets such as Stratford-upon-Avon and Warwick Castle. The area benefits from a strong strategic highways network including the M40 and A46 that make it an attractive area to invest. The HEDNA states that the strategic road network lends itself to logistics operations and there is strong interest from occupiers, but there is concern that logistics do not maximise the economic potential for South Warwickshire. It is also advised that the area has failed to capitalise on the strength of existing sectors and skills of the workforce. In accordance with the findings of the HEDNA the Draft Plan confirms that the South of Coventry Area has started to see and will continue to see considerable change. This includes the sub-regional employment site to the south of Jaguar Land Rover’s Head Quarters at Whitley that is under construction. Warwick University is situated within this area and can help facilities high quality job creation. Coventry Airport is also located within the area. A planning application has been granted for a gigafactory for battery production on the airport site to support the country’s shift towards electric vehicles and ultimately carbon neutrality. This development would have the potential to complement existing facilities in the area including the Battery Industrialisation Centre on Whitley South, facilities at JLR and Warwick Manufacturing Group at the University. Significant transport infrastructure improvements have been implemented, are ongoing and are being explored in the area. These include a new bridge over the A45 and transport improvements to connect JLR/Whitley Business Park to the new sub-regional employment site comprising Whitley South and Coventry Gateway. A new £38m scheme under construction will see a new bridge across the A46 and realigned slip roads forming the basis of a new signalised gyratory system at the Stoneleigh Junction of the A46. Further transport investment is being considered in the area, including whether the Very Light Rail project led by Coventry City Council that could serve the university and development in this area. The potential for a new railway station near Kenilworth is being explored. A potential transport corridor, potentially incorporating Very Light Rail and to cater for other sustainable travel modes connecting the new Stoneleigh Junction to Warwick University and with strategic connections towards the proposed HS2 Interchange at UK Central in Solihull is also being explored. The SWLP should seek to maximise the employment opportunities presented by high value sectors in this location. The HEDNA confirms the opportunity for the local economy to grow. As detailed in our call for sites submission, Stoneleigh Park and Kings Wood Business Park should be key allocations to facilitate employment growth and take advantage of the opportunities to grow high quality jobs in this location. We support the HEDNA’s conclusions that a minimum of 345.3 hectares of land for office and general industrial uses is required, however, it is not clear from the conclusions of the HEDNA how research and development floorspace and other forms of floorspace have been considered. For example, it is advised that there is a need for separate allocations for B1(c) – Light Industrial (now Use Class E(g)(ii)), alongside B2 allocations. However, the employment land needs tables in the HEDNA (Tables 15.2 and 15.3) and Table 8 of the Draft Plan, specifically to office and general industrial land, with no reference to research and development or light industrial land. It should be clarified if the 345.3 ha employment land required includes research and development and light industrial land, or if there is a separate requirement for these types of land. We also support the recognition that in addition to this Stratford-on-Avon and Warwick district should play an active role in delivering a proportion of the 709 hectares of strategic B8 employment land required in the Coventry HEDNA area during the course of the plan period. This should form a separate element of overall employment allocation. As a final point, it is our view that the employment requirements of the plan should be treated as absolute minimum. The emerging plan is expected to run until 2050. It is highly likely that there will be significant changes in the economy during the course of the next 27 years. The emerging plan should include a suite of flexible policies designed to support economic growth throughout the plan area and maximise the opportunities presented by the plan area. Option E3a – Should the SWLP include a policy expanding on SDC’s current existing policy? We support the inclusion of a policy in the SWLP that sets out the principles for economic growth and also provides a minimum employment land requirement, as referred to above. In this regard we note that it is advised that South Warwickshire has an existing high skilled and qualified workforce that should be supported. This is in combination with a large number of people employed in hospitality, retail and tourism sectors. It is imperative that the SWLP makes provision for a range of different employment types in a variety of locations to boost the local economy. Option E3b – Should the SWLP have separate policies for individual sectors? Given that the plan period is scheduled to run to 2050 the SWLP’s employment policies need to be flexible and capable of adapting to changing circumstances as the local and national economy evolves. That being the case, whilst we have no particular concerns with inclusion of policies in the SWLP for individual sectors, however, they cannot be overly prescriptive. The policies in the SWDP should be designed to support all forms of employment development and not put in place any form restrictions that could prevent economic growth in sustainable locations. This would reflect the objectives of paragraph 81 of the NPPF, that states that planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential. Option E3c – Should the SWLP include a policy that secures employment strategies through S.106? It is suggested that the SWLP could include a policy that seeks to reserve certain jobs for local people. This is problematic. In the first instance, we are concerned that such a policy may not be fair or legally appropriate, given that it would prevent people from outside a certain geography applying for jobs. In addition, what constitutes a “local person” is not clear. This approach could also have a potential to reduce the amount of labour available to support the local economy. It could prevent people from outside the plan area moving to South Warwickshire for work. Q-E4.1 – Sustaining a Rural Economy We support the inclusion of a policy in the SWLP that seeks to support the rural economy. This approach is in accordance with the guidance contained in the Supporting a Prosperous Rural Economy section of the NPPF. Stoneleigh Park is a large scale employment site that is over 100 ha in size. It is one of the largest employment sites in the plan area and has historically had a rural activity focus. However, Stoneleigh Park needs to evolve. HS2 now passes through the Park making it less suitable for a variety of the uses that have taken place there historically. Furthermore, as a consequence of HS2 and extant planning permissions there are now large parts of the wider estate that comprise, or could become, previously developed land that will need to be repurposed. These sites are well suited to large scale employment development. The site falls within the Economic Strategy for South Warwickshire Area and is in close proximity to the large scale residential development, including Kenilworth and the built up edge of Coventry. There is the opportunity to deliver large scale new employment development in a highly sustainable fashion. Further details of this matter can be found in our Call for Sites submission in respect of Stoneleigh Estate. Q-E6 – Should the SWDP include policies that protect South Warwickshire’s economic assets We fully support the inclusion of a policy in the SWLP that seek to protect the growth of South Warwickshire’s economic assets. We also fully support the identification of Stoneleigh Park as one of these economic assets. As detailed in our Call for Sites submission, Stoneleigh Park is a key employment site both nationally and regionally. It supports a large number of jobs and businesses. Its role has, however, been significantly affected by HS2. HS2 has reduced the amount of land available on site for events and has also made it a less attractive location for certain businesses that are adversely affected by high speed rail. It is, therefore, essential that the SWLP includes a policy supporting the growth and evolution of Stoneleigh Park as a consequence of HS2 and the changing economy. In addition to the Park itself, it is necessary to include positive policy guidance in respect of the estate as a whole. HS2 has resulted in the creation of a large compound area within the estate that is previously developed land. Furthermore, planning permission has been granted for other buildings outside of the estate boundary that can introduce significant new development into the Green Belt. The SWLP should include a policy to guide the development of these sites to ensure that the best use is made of these brownfield assets. Indeed, the HS2 compound in particular should be re-purposed once it is no longer required by HS2 and brought forward for a beneficial use. The compound is located next to the A46 where the Stoneleigh Junction has been upgraded. It also benefits from road infrastructure put in place with the HS2 works. As detailed in our Call for Sites submissions, it can help create a new gateway to Stoneleigh Park, provide a bypass to Stoneleigh village and facilitate for regeneration of the wider area. Q-E7.1 – Should the SWLP include a policy directing employment to the Core Opportunity Areas We fully support the SWLP including a policy that directs employment development to the Core Opportunity Areas. We welcome the acknowledge that “Stoneleigh Area” is designated a Core Opportunity Area by the emerging Plan. Stoneleigh Park is a major site in the Green Belt and the home of the number of important countryside organisations. The Park plays an important role in hosting events and shows and is established part of both the local and national rural economy. We also welcome recognition that the Park will be “significantly” impacted by HS2 and this necessitates changes to the Park. The SWLP provides an opportunity to assess the use and purpose of the site and the density of development within it. It also provides the opportunity to explore and improve access to and through the site with potential benefits if the main entrance is repositioned to the north-western section of the Site with access coming from a new A46 Stoneleigh junction. This would redirect traffic through Stoneleigh Park and have a positive impact on Stoneleigh village. Q-E7.2a –Should the SWLP include a policy relating to additional economic growth at Major Investment Sites We fully support a policy directing additional employment growth to the Major Investment Sites and the identification of Stoneleigh Park, an existing Major Investment Site (Site 8). As detailed above and as referred to in our Call for Sites submission, this site is ideally placed for significant new employment development.

selected

selected

selected

Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire In our view it is not necessary for the SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.

Yes

Yes, the range of topics identified is appropriate for a strategic design policy. South Warwickshire has a large plan area, comprising large towns, a variety of villages of different size, hamlets and significant areas of countryside. It is, therefore, imperative that a design policy is flexible to recognise the different environments across the plan area, delivering high quality schemes.

selected

selected

selected

selected

Nothing chosen

Q-D2 – Please select a design code option which is appropriate for South Warwickshire It is our view that a single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. It is our view that the most appropriate approach would be to include policy guidance within the site specific allocation policies where appropriate making it clear how the allocations are expected to respond to their surroundings. If necessary, design codes could also be produced for specific settlements and locations that have a particular design issues that need addressing.

Nothing chosen

Q-B5 – Please select the environmental net gain option that is most appropriate for South Warwickshire Whilst we have no particular difficulty with the inclusion of environmental net gain policy within the SWLP, it is noted that the Draft Plan’s supporting text advises that there is “much work to be done to explore environmental net gain further”. In order for the SWLP to include the policy of environmental net gain, its implications need to be fully understood, in terms of both the site selection and development control process. Its requirements would need to be factored into the viability work being undertaken in the plan in order to establish what impact it would have on the deliverability of allocations and the masterplanning process generally. Q-B6 – Should the South Warwickshire Local Plan introduce wild belt designations? The wild belting approach means that land would be specifically designated for environmental enhancement. The wild belts would be designated areas of land which are currently of low biodiversity value where works could be undertaken to support nature’s recovery, including creating new habitats or bringing nature back. It is questioned how this is deliverable, given that the land is likely to be in private ownership. Whilst a policy could be put in place there can be no mechanisms to require a landowner to maintain or manage their land in a particular way. Whilst we have no specific concerns of the concept, it undeliverable as we understand it and as such it is not a realistic objective of the plan.