Issue and Options 2023

No

There is in fact no specific “Sustainability objective” and certainly no objective.

It seems to us that the Plan lacks a “moderate positive impact” key likely impact as you only have two positives and effectively three negative impacts so we believe that the chart is deficient and should be amended.

ISSUE I2: INFRASTRUCTURE REQUIREMENTS AND DELIVERY We would comment that focusing new infrastructure on existing transport routes such as the M42 and particularly Junction 3 would be the best use of scarce resources. In addition, the positive linking of new employment in and around locations such as Junction 3 of the M42 is very important. We have included a new site in the Call for Sites on the south-east side of Junction 3 of the M42 east of the A435 which we believe is an excellent location for the provision of distribution facilities and a logistics park which could provide much needed employment in this area and the provision of the sustainable requirement for electrical lorry and van charging. Q – I2: Please select the option which is most appropriate for South Warwickshire In the list of options there should be a much stronger Economic focus on the sustainable benefits of providing new employment as set out in our reply above. ISSUE 5: VIABILITY AND DELIVERABILITY Q – I5: Please add any comments you wish to make about infrastructure, viability and deliverability This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assessed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.

ISSUE S1: GREEN & BLUE CORRIDORS Q – S1: Please select the option which is most appropriate for South Warwickshire Whilst the focusing on green and blue corridors is one way of considering Spatial Growth, there is no reference whatsoever to the need to consider Economic growth and the benefits of economic growth in those corridors. This is particularly helpful in identifying recovery areas and linking that back to economic growth. Economic growth can provide very substantial Green infrastructure particularly in proper and reasonable balanced Masterplanning of development. Comment on the options Firstly this is a poorly worded question because what is required is a new policy that links Environmental protection, environmental enhancement and economic benefits flowing from development that would both assist protection and enhancement. ISSUE S2: INTENSIFICATION Q – S2: Please select all options which are appropriate for South Warwickshire There needs to be a clear policy context between major urban areas and rural settlements where the issues of density are both fundamentally different. Each site has to be judged on its own merits and the benefits that it could bring with economic growth, employment and sustainable electrical charging points for lorries, vans and cars which needs to be properly balanced against environmental protection and enhancement. ISSUE S7: REFINED SPATIAL GROWTH OPTIONS In requesting consultees to choose one of the five listed options there needs to be a new option focusing on sustainable travel, economy employment and road corridors. Q – S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire Please see our answer above to Issue S7. This is a much better planning approach to growth and sustainability as we have indicated in Issue S7 above. ISSUE S10: ANY OTHER DEVELOPMENT STRATEGY ISSUES Q – S2: Please add any comments you wish to make about the development distribution for South Warwickshire As mentioned at the start of our representations, there should have been a development strategy focusing on the M42 and the landholdings in that area that form part of this emerging South Warwickshire Local Plan.

No

This emerging Local Plan needs a fundamentally new approach to the provision of employment land requirements, particularly in terms of the Plan period to 2050. Covid brought a substantial increase in the number of people working from home and particularly those who use broadband and the internet and can work from their own homes. The South Warwickshire Local Plan should have properly commissioned a new employment and economic study from independent consultants which should focus on providing focused growth for those employment activities related back to growth in the national economy. Without this independent Study we believe that the approach taken is imbalanced and particularly at a critical time generally after Covid. In addition, this study should also focus on the opportunities to provide employment in a sustainable form along existing road corridors such as the M42 and the A435. Generally economic growth comes from the provision of both large and small new businesses expanding and we made the point above about the benefits of our new Call for Sites on the south-east side of Junction 3 of the M42.

CHAPTER 5: DELIVERING SOUTH WARWICKSHIRE’S ECONOMIC NEEDS ISSUE E1: GROWING THE SOUTH WARWICKSHIRE ECONOMY Q – E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? This emerging Local Plan needs a fundamentally new approach to the provision of employment land requirements, particularly in terms of the Plan period to 2050. Covid brought a substantial increase in the number of people working from home and particularly those who use broadband and the internet and can work from their own homes. The South Warwickshire Local Plan should have properly commissioned a new employment and economic study from independent consultants which should focus on providing focused growth for those employment activities related back to growth in the national economy. Without this independent Study we believe that the approach taken is imbalanced and particularly at a critical time generally after Covid. In addition, this study should also focus on the opportunities to provide employment in a sustainable form along existing road corridors such as the M42 and the A435. Generally economic growth comes from the provision of both large and small new businesses expanding and we made the point above about the benefits of our new Call for Sites on the south-east side of Junction 3 of the M42. ISSUE E2: A LOW CARBON ECONOMY Q – E2: Please select all options which are appropriate for South Warwickshire Given our reply under Q E1.1 above, the ability now to provide low or zero carbon employment growth together with environmental recycling should be the aim for new employment locations and particularly in sustainable settlements and not just in the major towns for South Warwickshire. ISSUE E4: SUSTAINING A RURAL ECONOMY Q – E4.1: Please select the option which is most appropriate for South Warwickshire Bearing in mind our replies on the various issues above relating to the economy, sustainability, sustainable travel and new employment provision to assist rural diversification of the economy. ISSUE E6: PROTECTING SOUTH WARWICKSHIRE’S ECONOMIC ASSETS Q – E6: Please select the option which is most appropriate for South Warwickshire This question is again poorly worded because there are no specific options but where in a sustainable rural location new business opportunities provide themselves, particularly in conjunction with motorway and motorway-related services such as logistics and distribution, then support should be given through this emerging Local Plan for such opportunities.

No answer given

CHAPTER 10: A WELL-CONNECTED SOUTH WARWICKSHIRE ISSUE T2: SUSTAINABLE TRANSPORT ACCESSIBILITY ACROSS SOUTH WARWICKSHIRE Q-T2: Please select the option which is most appropriate for South Warwickshire Bearing in mind the statement at the beginning of these representations, together with the answers that we have given above, we would reiterate proper and reasonable consideration should be given to the landholdings within the emerging South Warwickshire Local Plan south of Junction 3 of the M42 and to the east of the A435 for new employment provision. ISSUE T3: ROAD TRAVEL, EMPLOYMENT, AND FREIGHT Q-T3: Please select the option which is most appropriate for South Warwickshire For the reasons given above, this emerging Local Plan should focus on the M42 Motorway and the A435 on its eastern side and the benefits that can be provided by new employment and new business opportunities. In addition, there will be provision needed for overnight accommodation and through facilities to assist the drivers using this proposed new logistics and distribution park.

No

ISSUE V3: STRATEGIC OBJECTIVES Q – V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q – V3.2 to comment. There is in fact no specific “Sustainability objective” and certainly no objective.

It seems to us that the Plan lacks a “moderate positive impact” key likely impact as you only have two positives and effectively three negative impacts so we believe that the chart is deficient and should be amended.

ISSUE I2: INFRASTRUCTURE REQUIREMENTS AND DELIVERY We would comment that focusing new infrastructure on existing transport routes such as the M42 and particularly Junction 3 would be the best use of scarce resources. In addition, the positive linking of new employment in and around locations such as Junction 3 of the M42 is very important. This is particularly so where there could be provision for motorway-related services such as budget hotels, fast food and with that the provision of electrical charging points which could cater for cars using both the M42 and the A435. We have included a new site in the Call for Sites on the north-east corner of Junction 3 of the M42 which could provide both employment and the sustainable requirement for electrical car charging. Q – I2: Please select the option which is most appropriate for South Warwickshire In the list of options there should be a much stronger Economic focus on the sustainable benefits of providing new employment as set out in our reply above. ISSUE 5: VIABILITY AND DELIVERABILITY Q – I5: Please add any comments you wish to make about infrastructure, viability and deliverability This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assessed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.