Issue and Options 2023
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New searchQ-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Don't Know The term corridor for rail is a little confusing given the distance between stations. It might be more relevant in describing a bus-based corridor where stops are much more frequent. The plan should also look at planning for new and improved bus services in rural areas and examine how growth for both housing and employment might be used to achieve this. Q-S5.4: If not, what approach would you take? Given limitations over capacity, frequency and level of service on the rail network it is probably misplaced to use the rail network as the ‘predominant’ rationale behind the locational strategy, but that public transport should be one of several factors used to steer the locational strategy. This point is of heightened significance post Covid context, where working from home is far more prevalent and, where road transport is required to become carbon free in the foreseeable future. This suggests that greater importance in decisions on the locational framework should relate to quality-of-life considerations. These would tend to favour more development taking place in smaller developments dispersed across the plan area. The existing pattern ofdevelopment would continue maintain the health of the main existing settlements where regeneration activities would need to be concentrated. A dispersed pattern of development would help to sustain and enhance existing services across the plan area and, could help to improve bus services in those areas that do not have immediate access to rail services.
The emissions analysis is high level and shows relatively little difference between the alternatives. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. Assuming mitigation could be put in-place under each of the options then other considerations should have greater weight.
Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced There should be sufficient existing technical evidence already available to identify the corridors. There would also be scope for these to be modified, as necessary as the local plan progresses. If this approach is taken it is important that maps and images are at a scale and have sufficient clarity so that the status of specific land parcels can be distinguished. Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy It seems unlikely that the scope for any reduced synergy would be very significant and, as mentioned above, there is scope to reduce that as the local plan progresses towards adoption. Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b would appear to be the most realistic, and achievable option. It is of some concern that the consultation document identifies some of the potential climate change benefits that can arise from intensification while at the same time failing to recognize potential dis-benefits such as adding to congestion in already congested areas and undermining the character and appearance, as well as the attractive of urban areas though over-intensification. In addition, since all development should be carbon-free by 2050 the differential impacts on climate change between different locations should be significantly reduced. The plan appears to be predicated on a principle that development in urban areas is preferable in climate change terms that development elsewhere. This appears to be a principle based on assertion rather than definitive evidence. It could lead to the degradation of attractive urban environments which would be counter-productive. Q-S3.2: Please select the option which is most appropriate for South Warwickshire These options and the analysis behind them appear somewhat confused and focused towards urban concentration. As highlighted earlier in this response, the evidence to conclusively prove those options are the most sustainable and have the least impact on climate change and CO2 reduction is based more on assertion rather than on conclusive evidence. We also feel that the term 'prioritise’ may not be the most suitable, not least because of its uncertain meaning. Perhaps ‘make best use of’ would be a better terminology. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? A 10 dwelling limit generally seems appropriate although any such limit should also be caveated to enable developments of more than 10 dwellings in exceptional circumstances or where criteria have been met in terms of sustainability and perhaps provision of additional infrastructure, otherwise potential developments of 11-49 dwellings which might be acceptable on all other grounds would have been excluded from the local plan process. Q-S9: Please select the option which is most appropriate for South Warwickshire The development strategy should enable a proportion of development to come forward outside strategic sites with a capacity of 50 or more dwellings. The scale of small scale dispersed growth should be disaggregated across the plan area to provide the basis for Neighbourhood Development Plans and the review of settlement boundaries where this is necessary. However, it is important that identification of suitable sites is not unduly delayed and the potential identification and release of an appropriate scale of development where sites have been taken through the Call for Sites should not be unduly delayed. Ideally, where it is known that settlement boundaries require amendment then these settlements should, at the very least, be identified in the plan. If, having identified these settlements then it should be accepted that land might be released adjacent to the extant development boundary. This would provide a strong incentive for Neighbourhood Development Plans and or Site Allocation Plans to be put into place. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire The level and distribution of growth should be clearly set out in the plan to provide a sound basis for Neighbourhood Development Plans.
The levels of employment land requirements appear somewhat mismatched with the distribution of population implying that the supply of land is a significant driver to the level of ‘need’ or requirement identified. This supply-led approach also appears to place a significant degree of support to the provision of larger strategic sites. The 5 options all identify potential locations for 11 strategic employment sites that would collectively meet the 345 ha ‘need’. It is important that the plan should identify opportunities across the piece including smaller and sites of differing quality so that the needs of businesses of all types can be accommodated. Of particular concern must be the provision of sites and buildings that provide opportunities for entrepreneurial activities to encourage start-up and grow on space. The opportunity at Holly Farm Business Park would provide such opportunities and we submit these are likely to be much more attractive to many businesses than location on a strategic employment site. In terms of distribution, there would appear to be a need for additional provision in the Warwick part of the plan area.
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