Issue and Options 2023

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Q-C2: Lockley Homes would select Option C2a referred to above, with some reservations. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as discussed below. The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. This is supported by the issues discussed below. Impacts of the global coronavirus (COVID-19) pandemic on Local Plan preparation within the UK According to central Government (London) estimates released by the Chancellor of the Exchequer (the now Prime Minister and former Chancellor of the Exchequer Rishi Sunak) during his Autumn Budget and Spending Review to Parliament, on Wednesday, 27th October 2021, the global coronavirus (COVID-19) pandemic has caused one of the worst economic recessions to affect the United Kingdom economy of a scale and severity not experienced across the UK for the last 300 years. Causing unprecedented record levels of Government borrowing due to the huge decline in economic activity during the years 2020 and 2021 ongoing COVID-19 pandemic, and the pro-longed 15 months of continuous lock-down restrictions, and the previous sustained long-term shutdown of the UK economy during the years 2020 and 2021. This severe and unprecedented long-term economic recession and the irresponsible handling of the public finances by central government (London) during the years 2022 to 2022 coronavirus pandemic, is highly likely to have long lasting implications in terms of a significant and long-term economic downturn. Causing one of the worst economic recessions in living memory across the South Warwickshire Region and the wider UK. Extending a long way into the shelf life of the Council’s new SWLP period once the new Local Plan has been formally adopted. This significant economic downturn driven by the various multiple adverse economic factors discussed above all coming together at the same time, is highly likely to harm the future financial viability and deliverability of many new housing development sites, resulting in some stalled housing sites, and some new housing sites not coming forward at all across the South Warwickshire Region. Due to the very challenging set of adverse economic circumstances discussed above. In addition, the house building industry is currently experiencing a severe spike in the financial costs of both building materials and labour costs, due to rising inflation and rapidly rising energy costs. Given the above factors, the housing market across the UK is currently very fragile. Consistent with our earlier substantial objections to the Council’s SWLP ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, Lockley Homes continues to maintain its view that the potentially massive implications of this severe UK economic recession (which will extend across the shelf life of the new Local Plan once it has been formally adopted) on both future housing delivery and future employment land delivery across the emerging Local Plan area, and how the recession will affect adversely affect future new housing and employment land delivery within the South Warwickshire Region and wider West Midlands Region area going forward, over the lifespan of the new Local Plan Review, once it has been formally adopted, has all been given an insufficient level of material planning policy weight and planning policy consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams when preparing both the emerging SWLP and SAP Local Plan Reviews. Or seemingly absolutely no planning policy weight at all – which is a highly alarming situation given the unprecedented severe adverse economic landscape now facing the local area for the reasons explained above. Local Plan preparation has refused and substantially failed to respond effectively to guidance within paragraph 82 (indent d) of the Revised NPPF (2021). Notably, the emerging Plan has substantially failed to respond effectively to the rapidly changing set of severe adverse economic circumstances now facing the Local Plan area. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation by the Council’s within the South Warwickshire Region. To make things worse, the Council’s are now proposing to produce two separate versions of the SWLP – a Stage 1 SWLP and Stage 2 SWLP, which will add a significant time delay to Local Plan preparation, and substantially delay new inward investment opportunities coming forward within the South Warwickshire Region. We are concerned about the level of economic harm and damage that the Council’s proposed Plan making approach is causing to the local economy. We continue to object to the “incapable” management and leadership approach being taken towards Local Plan-preparation within the South Warwickshire Region, within both the SWLP (2023) and Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2023). The presence of an unprecedented severe 300-year-economic-recession-event (driven largely by record levels of central government borrowing and weak economic growth during the years 2020 to 2022 coronavirus pandemic, and Russia’s Spring 2022 invasion of Ukraine) now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). The implications for all climate change policies coming forward within the SWLP (2023) Given the above issues, it is important to ensure that a less financially onerous planning policy regime is placed on the housing building development industry going forward within the SWLP (2023) to help support the future financial viability of new housing development sites during the very fragile post-COVID-19 economic recovery. The impact of the sharp increase in energy prices during Spring 2022 The impact of rising energy prices during Spring 2022 and the major increase in the energy price cap on the 1st April 2022, with an average United Kingdom (UK) household gas and electricity bill rising to £1,971 a year, and a further increase anticipated during October 2022, which could take the cost up to £3,300, means that the need for modern energy efficient housing with good quality insulation standards has never been more important. The Spring 2022 price increase is driven by more demand on energy as worldwide economies gradually recover from the effects of the global coronavirus (COVID-19) pandemic, with supply unable to keep up with demand. Russia’s Spring 2022 invasion of Ukraine has also exacerbated the issue, with some countries stopping or limiting their purchasing of Russia’s oil and gas. In conclusion therefore, these emerging new housing development proposals proposed for the Village of Broom settlement will play a key role in helping to deliver a much needed supply of modern, energy efficient housing for the local community, in a part of the rural area which is currently suffering from and dominated by poorly insulated, sub-standard historic mid-17th century housing (built from 1st January 1601 to the 31st December 1700) and 18th century housing (built from 1st January 1701 to 31st December 1800) located inside the Village of Broom Conservation Area. All these historic properties, which in some cases are now over 300-years-old, all lack cavity wall insulation and are all energy inefficient. These new modern energy efficient housing development proposals are therefore coming forward at an absolutely critical time for the local community when the local area is facing a rapid increase in energy prices. These new housing development proposals should therefore be strongly encouraged by the Local Planning Authority. Q-C3.3: Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021).

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Q-C4.1: Lockley Homes would select Question C4d. [none of these] Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). Q-C5: Lockley Homes would select Question C5c. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021).

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Q-C7: Lockley Homes would select Question C7c. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue, to help the emerging Plan to respond effictively to paragraphs 31 and 82 (indent d) of the Revised NPPF (2021). These issues already considered in our wider SWLP Representations Statement (March 2023). Lockley Homes is promoting a proposed new housing development site through the Council’s emerging SWLP Review which is coming forward within a sustainably-located infill site, within an area of under-utilised land, which forms very low quality fully restricted public access green space. The Sustainability credentials of this site are already discussed in detail within this wider SWLP Representations Statement (March 2023). The site in question is located within the Village of Broom settlement within the western part of the Stratford-on-Avon District, immediately bordering a vast, open prairie style, severely ecologically damaged and heavily eroded rural landscape. Which has suffered from many years of successive intensive farming practices, which has resulted in the widespread removal of hedgerow networks over a number of years on a huge ‘landscape-scale’ across considerable areas of South Warwickshire open lowland countryside. It has also resulted in the blanket removal of mature veteran and ancient deciduous trees across considerable expanses of countryside, due to the extensive hedgerow clearance works described above. The severe shortage of existing tree cover due to blanket tree removal within large expanses of the farmland landscape to the north of the Lockley Homes proposal site is supported by robust and defendable up-to-date photographic evidence in Photograph 2 (Appendix B of this Representations Statement). Lockley Homes is proposing to introduce new tree planting measures using suitable native tree species (see Appendix C of this Representations Statement) which would help to promote increased shade cover and promote natural cooling within the Village of Broom settlement. As well as provide habitats to support biodiversity. New tree planting is critical to help rural areas adapt to higher summer temperatures. Particularly those rural countryside locations which have suffered from the intensive farming practices described further above. Given the very limited existing tree cover present within adjoining open countryside for reasons explained above, there is a considerable opportunity for a new future high-quality residential scheme coming forward for this site to introduce significant new tree planting measures within rear residential garden spaces and within on-site landscaping screening buffer strips, using suitable native tree species to help support biodiversity. This would help introduce increased cooling measures through new tree planting (tree canopy shade cover, and natural cooling through evapotranspiration), as well as deliver net gains for biodiversity within a severely ecologically damaged rural landscape. The inclusion of this site as a new housing site allocation on the main Policies Map of the Council’s emerging SWLP Review would therefore be supported by Biodiversity Net Gain (BNG) focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). The proposals would also be supported by climate change focused guidance set out within paragraphs 153 and 154 of the Revised NPPF (2021). Paragraph 153 of the Revised NPPF (2021) is clear that: “… Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for … biodiversity and landscapes, and the risk of overheating from rising temperatures…” Given the above issues, the benefits of supporting new housing developments proposals coming forward within intensively farmed landscapes which are proposing to include new greening/ tree planting measures, should be given increased prominence within the SWLP proposed policy approach. These types of new housing development proposals should be strongly supported within the emerging SWLP Review (2023), given that they can play a crucial role in helping rural areas adapt to higher summer temperatures for the reasons explained above. Q-C9.2: Lockley Homes is a developer of very high-quality new luxury homes, and as a developer we take our environmental responsibility very seriously, and where opportunities exist, we are keen to support biodiversity where possible within our new-build residential development schemes. Lockley Homes considers that it is possible to provide compensatory measures to help provide new wildlife habitat features/ habitat enhancements to help deliver net gains for biodiversity, within high quality new build residential schemes. Consistent with guidance in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). Lockley Homes maintains its view that this is particularly possible and relevant when progressing new build housing development schemes coming forward on low-quality green space sites. Such as under-utilised, low-quality former horse grazing paddock land, and for site locations coming forward within areas of severely ecologically damaged open countryside. Which have suffered from considerable and constant ecological damage, as a direct result of years of uncontrolled mechanized industrial-scale intensive farming practices. Which has resulted in the widescale removal of features from the rural landscape, which would have previously provided important and highly beneficial wildlife habitats. For example, such as farmland wildlife ponds and other wetland habitat features, extensive hedgerow networks previously crossing large-expanses of farmland, removal of veteran and ancient trees within hedgerow networks due to widespread hedgerow destruction. Loss of wild flower hedgerow field margins, small woodland copses, wildflower meadows, etc. These issues are considered in further detail within Appendix C of this Representations Statement (2023). Ecologically damaged areas of sterile monoculture intensive farmland, within open countryside locations, such as ecologically damaged pasture fields and arable farmland, in particular, provide an excellent example, and significant opportunity where beneficial wildlife habitats can be delivered. To help re-introduce threatened wildlife habitat features, that have already been lost at an alarming rate from the British lowland countryside - due to years of damaging intensive farming practices as discussed above. In our view, this can help to deliver significant nature conservation enhancements and compensatory measures, to help support Biodiversity Net Gain (BNG). By providing habitats to support populations of severely declining and threatened wildlife species - consistent with approach expected by paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). In our view, the focus should be on replacing those threatened wildlife habitat features that have suffered particular high levels of extensive decline, and are considered to be particularly endangered, and vulnerable within the British lowland countryside - due to intensive farming practices. Most notably, this involves the replacement and re-introduction of Priority Wildlife Habitats within the countryside (priority habitats are classed as particularly vulnerable and scarce). A good example of a priority wildlife habitat type that has experienced significant rapid decline within South Warwickshire and the wider British lowland countryside, is farmland wildlife ponds. Therefore, the introduction of small wildlife garden ponds within new housing development site layouts, provides an excellent, robust and defendable example of a type of ecologically important, and significantly declining priority wildlife habitat feature, that can be easily replicated and incorporated into new residential site layouts. Within rear residential garden spaces and as part of small Sustainable Urban Drainage (SUDS) wetland ponds delivered in on-site natural green space landscaping buffer strips. Including these features has a particularly strong level of planning policy support when assessed against guidance in paragraph 179 (indent b) of the Revised NPPF (2021). Which confirms that plans should “…promote the conservation, restoration and enhancement of priority habitats…” Farmland wildlife ponds are now a priority habitat type given their increasing rarity and widespread decline within the British lowland countryside. Lockley Homes are promoting a sustainably located potential new housing development site through the emerging SWLP (2023). The site in question is located within the northern edge of the Village of Broom settlement boundary, immediately north of Mill Lane. The site is located within the civil parish of Bidford-on-Avon, within the western part of the Stratford-on-Avon District. The site in question is located on very low-quality green space (former paddock land), which has suffered from years of horse over-grazing, which has resulted in very poor and damaging grassland habitat management. The site subsequently has no nature conservation interest. On its northern site boundary, the proposal site immediately borders an area of ‘severely depleted and heavily ecologically damaged’ open countryside, which has suffered from years of uncontrolled intensive farming practices. Which has resulted in the extensive loss of a wide range of wildlife habitat features from the adjacent rural farmland landscape. Including the removal of miles of hedgerow networks due to the expansion of arable farmland and pasture fields, loss of mature veteran trees from hedgerow networks due to widespread hedgerow destruction on a vast scale, loss of hedgerow field margins. The draining of farmland wildlife ponds and other wetland habitat features. Blanket tree removal across large expanses of countryside, etc. The above issues are supported by robust, up-to-date and defendable photographic evidence in Photograph 2 within Appendix B of this Representations Statement document (2023). Particularly evident is the blanket removal of mature trees and hedgerow networks. Given the above issues, and for the reasons explained above and in more detail within Appendix B of this Representations Statement, Lockley Homes considers that Issue C9: (Mitigating Biodiversity loss) should increasingly recognise the important role that high quality new residential development proposals can play in helping to support the policy objectives of Issue C9. Lockley Homes maintains its view that it has a sustainably located site suitable for new housing development located within an existing village settlement boundary. Given the very strong, clear and compelling sustainability credentials of the site as already evidenced in our Representations, we consider that this site (within the Village of Broom settlement boundary) should be prioritised for future development and included without delay as a new housing site allocation on the main Policies Map of the Council’s emerging South Warwickshire Local Plan (SWLP). Allocating this site for new housing development would help to meet the policy objectives of Issue C9: ‘Mitigating Biodiversity Loss’ for the reasons explained above and within Appendix B of this Representations Statement (2023).

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Q-D2: Lockley Homes would select Option D2d referred to above. There are some concerns given the challenges being faced by Local Planning Authorities who, in many cases, simply do not have the staff resources, and staff with the specialist technical skills needed to prepare Design Guides or codes for their areas. At a time when Local Planning Authorities across the United Kingdom are struggling and significantly under-resourced, where some Council’s Development Management and Planning Policy Teams are failing and over-stretched, due to 15 years of continual ongoing financial austerity measures being imposed by Central Government (London), since the year 2008. And at a time when Local Planning Authorities (LPA’s) are facing significantly high workload pressures, with very limited staff resource levels, and notable significant and severe town planning skills shortages within Local Planning Authority both Development Management and Planning Policy Teams, we would advise that a pre-cautionary approach is taken in relation to this specific planning policy topic matter. It is clear that LPA’s across the South Warwickshire Region, the wider West Midlands Region, and wider UK are currently under significant pressures for the various reasons highlighted above. Council’s are also grappling with the problems of managing significant budget shortfalls, which is affecting resourcing levels within LPA Planning Departments. Combined with the shortages of competent skilled town planners, urban designers, and the shortages of in-house qualified architects. These resourcing constraints realistically will affect the ability of LPA’s to successfully deliver Design Guides or codes for their areas. Good quality housing developers bringing forward high quality residential schemes, such as Lockley Homes (as evidenced in the photographs at the back of this Representation Statement which show our recent development schemes) will always adopt high quality design standards from the early concept stage of development proposals. So the principles of good design are already established, so Design Guides and codes may not always be necessary, as these matters can be satisfactorily addressed through dialogue with LPA’s at the pre-application advice stage. We also make use of other evidence where available to influence our development schemes, such as adopted Conservation Area Character Appraisals (CACA) reports. Finally, another key point is how LPA Planning Policy Teams within South Warwickshire will deliver effective methods of engagement with local residents in the preparation of Design Guides and codes. In practice, this may prove difficult for LPA’s to achieve. Q-D5: Lockley Homes would select ‘No’ to Question-D5 referred to above. On page 47 of the SWLP consultation report (January 2023), within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment”, we have concerns that the Village of Broom settlement has been recognised as having high historic environment sensitivity. We have concerns about the findings and historic environment planning policy assumptions being made within this emerging background evidence base document, and would question whether it is sufficiently robust and fit for purpose to inform future ongoing Local Plan preparation work going forward within both the emerging SWLP (2023) and SAP (2023) Local Plan Reviews. It is important that any heritage designations and any heritage assessments being used by Local Planning Authorities to inform future Local Plan preparation work are supported by a sufficiently robust and defendable platform of up-to-date evidence - consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 192 of the Revised NPPF (2021). Paragraph 192 (indent a) of the Revised NPPF (2021) is perfectly clear that: “…Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to: (indent a) assess the significance of heritage assets and the contribution they make to their environment…” Paragraph 31 of the Revised NPPF (2021) confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” In addition, heritage designations should not be viewed as a site constraint to prevent new development, given that high-quality new residential development schemes incorporating good quality architectural design features, and use of appropriate types and colours of building materials in external facing building facades (which remain sympathetic to preserving a proposal sites historic surroundings), can all help to improve the historic setting, appearance and character of both Statutory Listed Buildings (such as Grade II Listed buildings), and nearby Conservation Areas. Historic environment focused guidance in the Revised NPPF (2021) positively encourages new development proposals which seek to enhance the character and setting of the historic environment. This is confirmed in paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021), which both strongly encourage new development proposals which seek to “…make a positive contribution to local character and distinctiveness…” As a key local stakeholder with a strong commitment and proven track record of bringing forward and delivering very high-quality new build residential schemes within the South Warwickshire countryside, and across the wider Midlands Region (see photographic evidence of the high-quality character of our new build residential schemes at the end of this Representations Statement). We maintain our view that the presence of heritage designations should therefore not be viewed as a site constraint within any future Local Plan policy approach to prevent future new housing development sites from coming forward within the emerging Local Plan area. Our views on this issue are supported by the above NPPF guidance. It is critically important that any future planning policy approach taken on this issue within the emerging Local Plan Review, has a positive and pro-active development approach towards supporting the needs of the private sector house building development industry. To ensure that a sufficiently robust Local Plan-making approach it taken by the LPA, reflecting the requirements of paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021). Q-D6: On page 47 of the SWLP consultation report (January 2023), within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment”, we have concerns that the Village of Broom settlement has been recognised as having high historic environment sensitivity. We have concerns about the findings and historic environment planning policy assumptions being made within this emerging background evidence base document, and would question whether it is sufficiently robust and fit for purpose to inform future ongoing Local Plan preparation work going forward within both the emerging SWLP (2023) and SAP (2023) Local Plan Reviews. It is important that any heritage designations and any heritage assessments being used by Local Planning Authorities to inform future Local Plan preparation work are supported by a sufficiently robust and defendable platform of up-to-date evidence - consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 192 of the Revised NPPF (2021). Paragraph 192 (indent a) of the Revised NPPF (2021) is perfectly clear that: “…Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to: (indent a) assess the significance of heritage assets and the contribution they make to their environment…” Paragraph 31 of the Revised NPPF (2021) confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” In addition, heritage designations should not be viewed as a site constraint to prevent new development, given that high-quality new residential development schemes incorporating good quality architectural design features, and use of appropriate types and colours of building materials in external facing building facades (which remain sympathetic to preserving a proposal sites historic surroundings), can all help to improve the historic setting, appearance and character of both Statutory Listed Buildings (such as Grade II Listed buildings), and nearby Conservation Areas. Historic environment focused guidance in the Revised NPPF (2021) positively encourages new development proposals which seek to enhance the character and setting of the historic environment. This is confirmed in paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021), which both strongly encourage new development proposals which seek to “…make a positive contribution to local character and distinctiveness…” As a key local stakeholder with a strong commitment and proven track record of bringing forward and delivering very high-quality new build residential schemes within the South Warwickshire countryside, and across the wider Midlands Region (see photographic evidence of the high-quality character of our new build residential schemes at the end of this Representations Statement). We maintain our view that the presence of heritage designations should therefore not be viewed as a site constraint within any future Local Plan policy approach to prevent future new housing development sites from coming forward within the emerging Local Plan area. Our views on this issue are supported by the above NPPF guidance. It is critically important that any future planning policy approach taken on this issue within the emerging Local Plan Review, has a positive and pro-active development approach towards supporting the needs of the private sector house building development industry. To ensure that a sufficiently robust Local Plan-making approach it taken by the LPA, reflecting the requirements of paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021).

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We have some concerns in terms of how easy it would be in practice to deliver and apply this policy concept within more remote rural parts of the South Warwickshire Districts countryside. Where existing small rural village settlements are surrounded by large expanses of open countryside. And also at a time when many small shops and other services within existing villages and larger centres are closing due to the challenging retail climate caused by the worsening cost-of-living-crisis, combined with rising inflation and rising energy prices. These issues are considered below. What is a 20-minute in rural areas: At its simplest, a 20-minute neighbourhood would allow residents to meet the vast majority of their day-to-day needs, including shopping, leisure activities, schools, healthcare and access to green space within a 20-minute walk or cycle from their home. (Source: Savills, 2023) Given the geography and scale of the South Warwickshire Region, with dispersed small rural village settlements, surrounded by large expanses of open countryside, it is unrealistic to expect rural areas to deliver all services to all people. It is far easier to apply the principle of a 20-minute neighbourhood within large cities (for example, the concept has already been applied successfully within other parts of the world such as Melbourne City Centre, Australia). Where there are a large range of services and facilities available within a short geographic distance to meet day-to-day community needs of city dwellers. It is abundantly clear and fairly obvious that the South Warwickshire Region is completely different from these large urban city centres where the 20-minute neighbourhood concept has been previously successfully tested and delivered. However, within heavily rural districts (with small rural village settlements, with little or no services available) characteristic of South Warwickshire, it is likely to prove difficult to apply this policy area. Particularly in more isolated parts of the South Warwickshire Region, where small rural village settlements are surrounded by large expanses of open countryside. It is also important that 20-minute neighbourhood policy approach concept is not used as a Development Management policy tool to harm and obstruct the future delivery of new housing development proposals coming forward across the SWLP area. Given the severe housing shortage and severe housing crisis present across all parts of the South Warwickshire Region, and the urgent need to boost the supply of new housing in accordance with paragraph 60 of the Revised NPPF (2021). Finally, it is also important that the Council’s preparing the emerging SWLP have confidence that they are taking forward a policy approach that is capable of being delivered within South Warwickshire Region, in accordance with guidance in paragraph 16 (indent b) of the Revised NPPF (2021).

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