Issue and Options 2023

1.0 Introduction 1.1 This representation statement has been prepared in response to the South Warwickshire Local Plan Issues and Options Consultation January 2023 on behalf of Border Holdings (UK) Ltd. 1.2 The representations are made in the specific context of the land at Manor Fields Farm, to the South East of the A46, in Stoneleigh which is being promoted as an employment allocation. 1.3 As part of the Call for Sites exercise that took place in May / June 2021 the Manor Fields Farm site was originally submitted as a proposed housing site (Site Reference 33). However, the company withdrew the site as a proposed housing option in December 2021. In response to the continued rise in national importance of freight and distribution land and the importance the Government attaches to catering for good sites to support growth, the company is promoting the site for employment use (now identified under Site Reference 366). 1.4 The site forms part of a larger landholding being promoted to support the expansion of Kingswood Business Park and is known as Stoneleigh Park Expansion Land (Site Reference 99). Border Holdings support the proposed employment site option put forward by Kingswood Business Park which includes the Border Holdings land. 1.5 The site at Manor Fields Farm lies to the north west of Stoneleigh and immediately to the east of Kings Hill Park which is a strategic urban extension site to the south of Coventry. The site is also proximate to a new access onto the A46 Trunk Road providing excellent connections with the strategic highway network. Stoneleigh Park lies to the south of the site. 1.6 The site accords with the tests outlined in the National Planning Policy Framework whereby the site is deliverable because:- • It is Available – Border Holdings (UK) Ltd have control over the whole site and therefore it is available now. • It is Suitable – the site is in a sustainable, suitable location which makes the use of existing infrastructure, is proximate to Coventry and Warwick and the strategic road network and is of a size that can support the delivery of large scale logistics and distribution floorspace. • It is Achievable – The site is available now and has no known delivery constraints. 1.7 Alongside this representation statement a site promotion document, indicative masterplan and highways statement have been prepared. These documents should be read in conjunction with this Statement. 1.8 The site promotion documents demonstrate that the site is suitable, available and achievable for employment use and can be supported as a proposed employment allocation as part of the Stoneleigh Park Expansion Land put forward by Kingswood Business Park. 2.0 Site Description 2.1 The Manor Fields Farm site is currently in agricultural use and lies to the north east of Kenilworth, north west of Stoneleigh and south of Coventry. The site lies to the in close proximity to a new access to the A46 Trunk Road and connection with the strategic highway network. The site is therefore well placed to meet the growing need for logistics and distribution floorspace. 2.2 The site also lies immediately to the east of a strategic urban extension site known as Kings Hill Park which will is proposed to deliver 4,000 new homes and associated infrastructure, which is on the other side of the A42. As part of this scheme, it is intended to create a cycle way and footpath, which will also traverse a further large area of housing, allocated in an existing local plan, via an underpass leading to the subject proposed employment land. There is therefore an obvious synergy between extensive areas of housing and place of work, which will be accessible by means other than the private car. Connecting these areas constitutes sound planning practice. 2.3 The site fronts onto the A46 to the west with the Kings Hill Park site beyond. Agricultural land lies to the north, east and south. Stoneleigh Park lies further to the south of the site. Access into the site would be taken from the east via the B4115 and onto the new A46 junction. 2.4 Whilst the site lies within the Green Belt, opportunities for large scale logistics and distribution development within the settlement limits are rare. Urban extension sites will therefore be required to meet this need. 2.5 The development of the site is achievable. There are no known technical constraints that would prevent the site from coming forward. The site lies within Flood Zone 1 and therefore is at the lowest risk of flooding. An initial Transport Statement has been prepared and demonstrates that access into the site is achievable and there is sufficient capacity within the local highway network to support the development of the site. Conclusion 4.1 This Statement provides comment on the South Warwickshire Local Plan Issues and Options Document. 4.2 Border Holdings (UK) Ltd are promoting land at Manor Fields Farm in Stoneleigh for allocation for employment use (Site Reference 366). The site forms part of a larger landholding being promoted to support the expansion of Kingswood Business Park and is known as Stoneleigh Park Expansion Land (Site Reference 99). Border Holdings support the proposed employment site option put forward by Kingswood Business Park which includes the Border Holdings land. 4.3 We support the identification of Stoneleigh Park as a Major Investment Site and within a Core Opportunity Area in the Issues and Options Document and the proposal to include a policy which directs employment to the Core Opportunity Area. 4.4 The Issues and Options Document does not identify specifically identify Stoneleigh Park as a location for employment land growth on any of the maps which sit alongside the spatial distribution options. Whilst it is identified as an Existing Major Investment Site there is no clear indication that this is also a location where employment growth should be distributed. The expansion of Existing Major Investment sites should be part of the overall strategy, particularly when the site lies within the Core Opportunity Area which is to be a focus for employment growth. 4.5 The Manor Fields Farm site is available for development and is in a suitable location to deliver distribution and logistics floorspace alongside an allocated strategic housing site providing genuinely local employment opportunities. There are no known technical constraints that would prevent the delivery of the site and therefore the site is deliverable. 4.6 The allocation of the Manor Fields Farm site would accrue a number of benefits:- • The site could deliver between circa 45,900 sqm of logistics and distribution floorspace in a sustainable location on the edge of Coventry. • The allocation would contribute to meeting the growing need for large footprint units which are well located to provide access to the strategic highway network. • The site would be readily accessible to the Kings Hill strategic housing site and provide employment opportunities for local residents in a sustainable location. • The development of the site can be accommodated and make effective use of existing infrastructure. • The site can be accessed from the existing highway network and is proximate to the new access onto the A46 Trunk Road. • The site is being promoted for development with a willing landowner as part of the larger Stoneleigh Park expansion land. 4.7 We would welcome discussions with the Councils preparing the emerging Plan to support the allocation and delivery of this site.

Nothing chosen

Issue V3: Strategic Objectives 3.2 One of the Council’s proposed strategic objectives is to meet South Warwickshire’s Sustainable Development Needs and in particular developing opportunities for jobs to build upon the strong and diverse economy. 3.3 We support the Council in identifying that developing opportunities for jobs should be a strategic objective of the plan.

Q-S 10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 3.4 The Issues and Options Document sets out 5 different growth options (rail corridors, sustainable travel, economy, sustainable travel and economy, and dispersed). For each of the options an indicative scale of growth is shown for each settlement in terms of dwelling numbers and employment land. 3.5 Each of the proposed options identifies a varying number of locations where new employment growth will be focused. In relation to Stoneleigh Park this is only identified as an Existing Major Investment Site, it is not identified as a site where growth is proposed in any of the options. We suggest this is a missed opportunity. In Chapter 5 of the consultation document the Council is proposing policies which seeks to direct employment growth to the Core Opportunity Area and Existing Major Investment Sites, but this is not duly reflected in the spatial strategy options which only identifies Stoneleigh Park as an Existing Major Investment Site. 3.6 The maps showing the potential locations and scale of growth for each of the 5 spatial distribution options should acknowledge the potential for growth through the expansion of Existing Major Investment Sites. Q-E7: Please select the option which is most appropriate for South Warwickshire Option E7. 1a: Include a policy directing employment to the Core Opportunity Area 3.12 A Core Opportunity Area has been identified which comprises the 5 main towns, the A46 Trans Midlands Trade Corridor and the central section of the M40 along with the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre, Stoneleigh Park and the automotive hub at Gaydon. 3.13 The Core Opportunity Area looks to attract inward investment to drive the South Warwickshire economy as well as encourage inward investment in the most accessible parts of South Warwickshire. 3.14 Major Investment Sites within the Core Opportunity Area include the Stoneleigh Area and Stoneleigh Park. 3.15 The supporting text highlights that the Stoneleigh Park site will be significantly impacted by HS2 and this provides an opportunity to reassess the use and purpose of the site and the density of development within it. 3.16 It is also stated that there is also a potential opportunity for a new site access stemming from the new A46 Stoneleigh Junction which would reduce traffic impacts through the village. 3.17 We welcome the inclusion of the Stoneleigh Area and Stoneleigh Park as a Major Investment Site within the Core Opportunity Area and support a policy that would direct employment growth to this area. Q-E7.2 – Please select the option which is most appropriate for South Warwickshire Option E7.2a: Include a policy relating to additional economic growth at the major investment sites 3.18 We would support a policy that seeks to allocate additional land for specific employment uses at the major investment sites including Stoneleigh Park. 3.19 There is increasing national support for well-located distribution sites. Stoneleigh Park, which lies to the south of the Border Holdings site is identified as a Major Investment Site on the South Warwickshire Key Diagram. The site and wider area that is being promoted as an extension to Stoneleigh Park is ideally located to meet the need for logistics and distribution floorspace. 3.20 The site provides an opportunity to support employment growth in a well placed strategic location. The Government’s “Future of Freight Plan” (June 2022) highlights the significant shortage of strategic employment land. Suitable logistics sites need to have close proximity to motorways and major A-roads and be situated away from residential areas. 3.21 The Border Holdings land is ideally placed to meet the needs for strategic employment land for the South Warwickshire Joint Local Plan as well as being optimally located to provide nearby residential areas with employment opportunities which are not reliant on private car use. 3.22 The Manor Fields Farm site is being promoted as part of a larger sustainable strategic employment allocation (Site Reference 99) that will assist the Council in meeting the increasing need for logistics and distribution floorspace in an area where significant new residential development is being delivered.

Nothing chosen

Q-E1.1 – Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 3.7 The Issues and Options document provides a table from the HEDNA which identifies a need for 23 hectares of office floorspace and 322.3 hectares of General Industrial floorspace. There is no figure set out in this table for storage and distribution uses. The supporting text states that a proportion of the 709 hectares of strategic B8 employment land (warehousing and distribution) identified for the wider Coventry and Warwickshire sub-region will be required at a time when there is a national shortfall of such sites. 3.8 The HEDNA undertakes a separate analysis for storage and distribution uses and considers the growth in this area and the changing needs of storage and logistics operators and highlights the need for sites to be identified that are in good quality locations which relate well to the strategic road / main A-road network, have adequate power supply, are accessible by public transport and where there are no neighbouring uses which could restrict the operation of the warehouse. 3.9 We consider the HEDNA provides a reasonable statistical starting point for the consideration of future employment land aspirations. It is stated that the two Councils are also preparing an Economic Strategy for South Warwickshire which the Council will need to ensure is reflected in the final figures proposed in the local plan.

selected

selected

selected

selected

selected

selected