Issue and Options 2023
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New searchThis is a representation from the Liberal Democrat Group of Stratford District councillors. It is noted that consultation is for a high level, long term plan and such the detail effect of policies will take time to emerge. This response does not preclude individual members and residents making representation that relate to local areas.
The declared 5 overarching Principles are supported: Climate resilient and net zero carbon, well-designed and beautiful, healthy, safe and inclusive, wellconnected, biodiverse and environmentally, resilient. The objective that the plan is to be environmentally led with appropriate infrastructure for new development is welcome. Conversely the ‘call for sites’ process, which has become somewhat repetitive, tends toward ‘developer led’ outcomes. As the plan proceeds, it is important that concept of the balance in favour of environment and community leading is not eroded towards being ‘developer led’. It must take into consideration true local influences.
New Settlements With caveats, we support a new settlement approach. It is clear that the housing numbers, whatever they are they will be too large to be sensibly met by adding housing around existing settlements as has occurred for decades (centuries even) with consequent pressure on infrastructure. New settlement(s) are needed with proper infrastructure.
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Housing Numbers A fundamental driver for additional development is housing pressure. This derives from a national picture and government methodologies. These can be seen as transient: future population estimates have emerged to be flawed and the Government’s long term approach presently seems uncertain. For South Warwickshire, the Housing Market Area including demand from West Midlands conurbations and the ‘duty to cooperate’ have promoted a need based on migration to South Warwickshire rather than organic growth from local communities. This is at odds with the overarching principles - most notably zero carbon (despite home working trends) and a 'commuter belt' characteristic has resulted. Turning to the target numbers themselves, the HEDNA notes that the Coventry population growth has been overestimated for some time and that asserts that the Government’s ‘trend based analysis’ can be justified. This would reduce the numbers in Coventry but increase in it surrounding districts. It seems in South Warwickshire, we have been granting permissions and building to meet to need of the combined housing market area including Coventry. In Stratford District the A46 corridor to Stratford and the area around Southam have seen very high percentages of building. Unsurprisingly, these houses are being occupied giving a trend of increasing population. To continue the trend which we now know to be flawed seems unwise. We believe that the figure of 868 homes a year has scant justification and is excessive. As well as the prospect of a review of the duty to cooperate, central government are apparently consulting toward allowing recent over provision to offset future dwelling numbers. Stratford has over provided by 42% since 2016. It may be noted that the new target of 868 represents a very similar target number to that of the last seven years in total, so the new target suggest a continuity of house growth targets. yr end built 'Old' target HEDNA target 16 1048 566 185.16% 868 120.70% 17 1114 894 124.61% 868 128.30% 18 1293 894 144.63% 868 149.00% 19 1386 894 155.03% 868 159.70% 20 1458 894 163.09% 868 168.00% 21 752 894 84.12% 868 86.60% 22 1568 730 214.79% 868 180.60% 8619 5766 149.48% 6076 141.90% Locations Determination of the location of new any settlement is likely to be problematical, not least because of the area of restraint of the Green Belt and AONB. This should not be a reason to confine all proposals to the remaining areas. There are upward of 16 potential settlement sites already indicated in the consultation. We emphasise that this response relates to principles rather that any of the 'sketched-in' locations, many of which can be evidenced to be unsuitable even at this early stage. Self build This is increasingly a developer led loophole in regulations which is being used to create unsuitable housing developments as an unintended consequence of the 2015 Custom and Self Building Act. The plan should address this. Affordable Homes There are concerns about how we can achieve the required level of affordable homes and avoid a developer driven approach. Looking a current practice, we have allowed developers to water down the 35% on viability grounds, and this process is insufficient to meet demand for this category of housing. It is be noted that the Government defined 'affordable housing' is for houses of up to 80% of market rents, can be up to nearly 40% more than social rents and may not be affordable at all to local people. So this problem is significant and should be a major factor in the plan. Although the debate throughout was largely influenced and driven by controversial housing numbers, commercial and business redevelopment does figure, but appears to be led by large developments (eg auto related) and tourism. Do we neglect the wider basis at our peril? Is it wise to ‘suck in’ more big facilities into relatively rural districts which expand housing demand in those rural areas?
Biodiversity There should be 20% Biodiversity Net Gain through new development, currently, only 10% is included in the plan. The Green Infrastructure study used is now 10 years old and needs to be reviewed early-on to inform growth options and to include joined-up wildlife corridors. We would like to see a more detailed assessment of local biodiversity and river habitats in the proposed growth and new settlement locations, especially in the areas adjacent to the river Avon and a number of key ‘Potential Local Wildlife Sites’.
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Energy efficiency, renewables, resources and Infrastructure Although national building regulations do not currently require new homes to be zero carbon, councils are permitted to set their own local planning requirements that do demand zero carbon [1]. Noting the overarching principles intended, this standard would be appropriate for inclusion in the plan. Provision of energy, water, sewage, roads and transport is challenging in this area. A mix of renewable energy types, particularly those that are community inspired schemes and community beneficial should be supported. However we additionally comment that lower wind speeds from the NOABL[2] wind speed database and other mapping sources mitigate against large scale wind turbines in central England. This does not preclude farm scale individual masts serving local demand. Wind turbines in towns have been shown to be ineffective[3] .
I have already submitted comments on behalf of the Liberal Democrat Group. I now wish to comment as Ward Member on local issues. I confine my comments to potential sites. Broad Potential Locations Substantial developments close the Chiltern Line and the spur to Kineton are unacceptable. This is a rural area generally far removed from other centres with little local or organic growth needs. It is most unlikely that rail authorities would support a rail station, even allowing for a degradation of service after HS2 comes into service. If a station such as unstaffed platforms were provided, it is unlikely the such an intermediate station would be adequately serviced as trains presently pass these points at speed and stopping trains between conurbations of Banbury and Leamington would be undesirable on energy and financially. Feeder custom from the wider area at such locations is unsustainable. Option 1, 2 and 3 The mapping shows a large development south of Southam. The Southam area has experienced excessive growth in recent years with the infrastructure overloaded (roads, health facilities, major shops). Even a well infrastructured new village would require frequent external travel to larger towns in opposition to the overarching principles. Option 4 The mapping shows a large development south of Southam, plus one to the east. In addition to comments above, the observations apply in this context as well. Option 5 Distributing development is unacceptable on environmental grounds and risk the destruction of the character of small villages and communities. Generally Constraining development to central areas of Stratford district and absolutely excluding the Green Belt and AONB has resulted in a concentration of development around Southam, Bidford, and Stratford. My own opinion is that a new settlement could preferentially be sited around Warwick Parkway Station with its existing station, and ready links to M40, M6, Warwick, Coventry, Stratford and Birmingham.
