Issue and Options 2023

No

MAOL is supportive of a Vision and Strategic Objectives that are focused on sustainable growth, which, reflective of the National Planning Policy Framework (NPPF), should be at the heart of the SWLP. Our client also considers that the ‘guiding principles’ generally represent sound aspirations for achieving greener, fairer and more connected growth. However, and insofar as our client’s interests are concerned, MAOL considers that the Vision and Strategic Objectives should provide a clearer statement on what will be achieved through the delivery of the SWLP and what South Warwickshire will look like in the future. Notably our client considers that: 1 The Vision and Strategic Objectives should clearly articulate that the delivery of strong and vibrant communities will need to be “balanced” with the protection and enhancement of the natural and built environment. This is one of the main challenges for South Warwickshire where the unique and high quality urban and rural environment, including significant heritage assets, distinguishes it from many other areas within the region. 2 Whilst the SWLP must seek to maintain this balance, development needs must also be met in a sustainable way. Given the importance of tourism in South Warwickshire, MAOL considers that the “development needs” must include reference to people who visit, as well as those who live and work in the Districts. 3 To provide a positive policy framework, the Vision should specifically “support growth”, including for tourism, provided it is sustainably directed and takes place at the right location at the right time. Or client considers that the Strategic Objectives should be developed to provide clarity on how they will be met by the SWLP. This could include a spatial dimension. There is also a disconnect between strategic objectives for growth and strategic objectives that link back to the guiding principles. For example, “Enriching the tourism potential” is under the heading “A well designed and beautiful south Warwickshire” but is clearly also linked to enhancing economic prosperity. This disconnect may be overcome by deleting the subheadings shown in blue text and explaining that the strategic objectives are not mutually exclusive but will work together to guide future development. With reference to specific objectives: 1 The objective at point 3 on “Developing Opportunities for Jobs” should provide a clear statement on how growth in employment opportunities will be delivered by the SWLP. This should include reference to: i Capitalising on South Warwickshire’s heritage assets to ensure a thriving destination fortourism/culture. ii “Supporting” rather than “Delivering” Opportunities for growth, including tourism, to reflect the role of the SWLP in providing a framework for future development. 2 The objective at point 7 on “Protecting and enhancing our heritage and cultural assets” should be a standalone strategic objective because it cuts across other strategic objectives. The wording needs to be developed to: i Explain that heritage assets and their setting will be conserved and enhanced in a manner appropriate to their significance. ii Acknowledge the close connection between the historic environment and economic activity. A great many of South Warwickshire’s business and jobs are dependent on, attracted to or based in historic buildings and spaces. iii Recognise the historic environment’s potential for investment in order to secure sustainable growth. iv Reference “conserving” rather than “protecting” as per the NPPF. 3 The objectives at point 8 on “Enriching the Tourism potential” should include reference to: i Supporting a longer season through the promotion of South Warwickshire as a year-round destination for tourism and recreation. ii Encouraging a tourism/cultural offer that is attractive to a wide range of age groups.

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No

Q-E6: Please select the option which is most appropriate for South Warwickshire: Option E6a: Include a policy which protects South Warwickshire’s economic assets. Warwick Castle is rightly identified as one of several unique economic assets that form the foundation of South Warwickshire’s economy. Insofar as Warwick Castle is concerned, MAOL agrees that the SWLP should provide a policy that seeks to maximise and capitalises on its economic potential. In this context, our client supports a policy that protects the Castle as an “economic asset”. However, and in addition to economic assets being protected, any policy should explicitly provide “support”. This means supporting development that clearly demonstrates economic benefits, accepting of course that other impacts, including on heritage assets, need to be weighed in the planning balance. We have commented separately on the need to for tourism to be recognised a key economic driver. Issue E10: Tourism Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? No. MAOL strongly objects to the suggestion that tourism should not be addressed in the SWLP Part 1. We have explained that South Warwickshire is a key destination for tourists and tourism makes a very significant contribution to the area’s economic prosperity in terms of the jobs that it provides, and the visitor spend that it generates. We have also explained that the Tourism and Recovery Plan should inform the formulation of policy in terms of recognising the importance of tourism, providing support for recovery from the Pandemic and building for the future. The importance of tourism to the economy means that it must inform the strategic growth strategy and be supported by the SWLP Part 1. This could be through references to “supporting tourism” in other strategic objectives on jobs and economic prosperity or as a standalone policy.The Councils suggest that tourism should only be addressed in Part 2 of the SWLP because “it is not felt that tourism plays a spatially strategic role”. Whilst there may be no “spatial” context, tourism is clearly of strategic significance for South Warwickshire’s economy and must, therefore, be supported at a strategic level. Moreover, the rationale for deferring to Part 2 holds no weight because as one would expect, many other non-spatially specific policies are proposed for inclusion in Part 1 - covering issues as wide ranging a supporting the green economy, promoting net zero carbon, water quality and protecting/enhancing heritage assets.

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Q-C3.1: MAOL has no objection to a carbon offsetting policy. The Councils will need to provide evidence to support the calculation for a cash in lieu contribution to a carbon offsetting fund to ensure it is fair and reasonable to the type and scale of development proposed. Without it, there is a risk that the Policy will not be found sound.

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MAOL recognises that its operations impact upon the environment and is committed to regular monitoring, auditing and reviewing activities with a view to identifying opportunities for sustainable environmental improvement, in line with strategic business goals. Our client also recognises that the planning system has a crucial role to play in delivering effective action on climate change and supports the Council’s commitment to reducing carbon outputs as a positive response to the Climate Emergency Action Plan. Our client does not comment on the technical requirement around achieving net zero but is keen to ensure that any policies are flexible enough to deal with different/changing circumstances and so that development specific and site specific/context issues can be fully considered. For example, any development within the grounds of Warwick Castle would need to consider the varied challenges of managing an historic site. Also, there may be technical and financial viability issues associated with net zero, particularly if applied to proposals for the conversion or change of use of existing buildings. As a general point, the Issues and Options consultation includes a lot of technical details around climate change. Our client agrees that the SWLP Part 1 should consider how the climate emergency will be met and that climate change should be at the heart of decision making. However, the SWLP Part 1 should avoid being overloaded with detailed requirements which will either come in Part 2 or can be satisfactorily addressed through National Policy/Building Regulations. Rather, consideration should be given to the inclusion of a strategic policy which requires appropriate mitigation for climate impacts to be embedded in all development proposals and explains in broad terms how the SWLP will support the Councils’ ambitions toward a reduction in carbon emissions to net zero.

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MAOL supports the principal of biodiversity net gain and is keen to ensure that any policy can be implemented on a site by site basis. It should not, therefore, include site specific requirements e.g. larger developments to have less than 50% of the wider site consisting of hard surfaces.

Yes

Q-D5: MAOL agrees that the SWLP should include a high-level strategic policy that seeks to conserve and enhance heritage assets. We have explained that there is a close connection between the historic environment and economic activity and that the historic environment’s potential for investment should be supported in order to secure sustainable growth. Any policy should, therefore, recognise that: 1 Historic assets play a key role in promoting a strong tourism/cultural offer, which is an important part of the South Warwickshire economy. 2 Historic assets should be supported to grow and improve to maintain their attractiveness and integrity. 3 At the same time, any development must ensure the conservation and enhancement of heritage assets and their setting in a manner appropriate to their significance. We do not comment on the use of Heritage and Settlement Sensitivity Assessments to determine the impact development may have on the heritage assets within various settlements.

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