Issue and Options 2023

Q-W2: Lockley Homes would select Option W2b referred to above. Lockley Homes maintains its view that Health Impact Assessments (HIA’s) should be required for major new housing development proposals. We would suggest a threshold of residential schemes over 2,000 residential units. Health Impact Assessments (HIA’s)should only be required for large major strategic housing site allocations. We also have concerns that many Council’s do not have the required in-house technical skills and sufficient expertise to assess HIA’s when they are submitted at the Development Management Planning Application submission stage. They are also likely to place a further layer of additional bureaucracy burden on already stretched Development Management Planning Officers, who are in many cases at many Local Planning Authorities across the UK, already struggling with individual officer planning application caseloads over 150 planning application per officer. At a time when Local Planning Authorities across the United Kingdom are struggling and significantly under-resourced, where some Council’s Development Management/ 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 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 the proposed use of Health Impact Assessments at the Development Management planning application stage within South Warwickshire. It is also important to ensure that if Health Impact Assessments are used by the South Warwickshire District Council’s, that they (the HIA’s) provide measurable and meaningful outcomes/ measurable performance targets to establish periodically whether they are in fact working effectively to help deliver high quality development proposals across the SWLP area. To ensure that they do not just merely add a further layer of additional and unnecessary bureaucracy on the private sector development industry. It is also important to ensure that Health Impact Assessments do not place an additional, onerous and unnecessary financial burden (in terms of additional background technical evidence reports required to support planning applications) on the private sector house building development industry. At a time when the house building sector is vulnerable and fragile due to the adverse economic climate facing the UK, for the reasons already explained within this wider Representations Statement (2023). The number of background specialist technical evidence base reports now required to enable the Registration of Planning Applications, even planning applications involving relatively modest small-scale development proposals, has significantly increased within the last 10 years across all LPA Development Management Teams. The above issues are therefore relevant as they cause a time delay in registration and additional financial costs for developers.

selected

selected

selected

No

Q-B1: Lockley Homes would select Option B1b referred to above. It is critically important that the LPA’s preparing the emerging SWLP promote the most sustainable patterns of new housing development in order to ensure that the emerging Local Plan Review satisfies the ‘Sustainability’ test of Soundness for Local Plan preparation, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). It is noted that the LPA’s preparing the emerging SWLP have a severe shortage or urban brownfield land (previously developed land sites) to meet their required housing development needs during the shelf life of the new SWLP, extending up until the year 2050. Given that the Plan area is dominated by large expanses of heavily rural open countryside. The Council’s will therefore have to rely on existing sustainably-located green space areas and areas of farmland located within the vicinity of existing village settlements, in order to meet their future development needs (NPPF para 79) – to help deal with the worsening chronic housing shortage present across all parts of the SWLP area. In accordance with guidance in paragraphs 79, 141 (indent a) and 142 of the Revised NPPF (2021), the Council should be supportive of bringing forward areas of low quality, under-utilised green space land for new housing development. Particularly those green space/ under-utilised greenfield sites located outside of the designated Green Belt. This approach has strong support within the above NPPF guidance. On this basis, a one-size-fits-all planning policy green space protection approach is not justified, is not acceptable, and is not a sufficiently robust policy approach to take within the emerging Local Plan Review. It is important that when drafting this open space focused policy area, that highly experienced, specialist and competent green space town planners are used, to help deliver a sufficiently robust, balanced and flexible policy approach, which effectively responds to the requirements of the NPPF. In order to ensure that the development needs of the local area can be met within sustainable site locations, and in order to ensure that villages are allowed to grow and thrive, consistent with guidance in paragraph 79 of the Revised NPPF (2021). Those most sustainable site locations such as the Lockley Homes site should be strongly supported for new housing development by the LPA within the emerging Local Plan Review. It is important that a highly obstructive planning policy approach towards green space protection is not taken, particularly for those low quality and under-utilised green space areas characteristic of the Lockley Homes site. This is critically important given the severe shortage or urban brownfield land sites present across the South Warwickshire Plan area. We have concerns that the Council’s preparing the emerging SWLP consider that it is appropriate to promote new housing development sites within the open Green Belt countryside, and ignore completely sustainable site locations such as the Lockley Homes sites. The scale of potential errors being accommodated into evidence base documents by completely overlooking and missing out sustainable development locations is quite alarming. For the scale of potential errors being incorporated into Local Plan preparation please refer to the large infill site located outside the Green Belt which has been overlooked by the LPA’s in their Plan-preparation work. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the emerging SWLP Review. Both Lockley Homes and their planning consultant Goldfinch Town Planning Services, continue to object to the “incapable” management and leadership approach being taken towards Local Plan-preparation within the emerging SWLP Review (2023). It is important that the ongoing failure to promote the most sustainable patterns of new housing development across the South Warwickshire districts is urgently addressed by the LPA’s Planning Policy Teams within the emerging SWLP Review. 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 SWLP. We consider that allocating this site for new housing development in the Council’s emerging SWLP as suggested would result in a more effective, positively prepared and justified plan, in accordance with tests of Soundness set out in paragraph 35 of the Revised NPPF (2021). Q-B5: Lockley Homes would select Option B5c referred to above. Including carbon capture policies and integrating these with Biodiversity Net Gain will place an unreasonable financial burden on the house building development industry at a time when the local economy is suffering from a severe economic recession. Placing an onerous set of policy restrictions on housing developers will have an adverse impact on the future financial viability of development sites coming forward across South Warwickshire. These issues are considered in more detail within this wider Representations Statement (2023). The proposed planning policy approach of combining Biodiversity Net Gain (BNG) with a Carbon Capture Policy, will significantly dilute and weaken the delivery of robust and significant BNG features within new development proposals, therefore conflicting with the BNG focused policy objectives set out within paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). Making the BNG component part of the policy undeliverable, therefore conflicting with ‘deliverability policy tests’ set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). 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 SWLP (2023). We are proposing to include a number of on-site biodiversity enhancement features within the site layout if this site came forward through the Council’s emerging SWLP Review. These issues are considered in Appendix C of this Representations Statement (2023). Allocating this site for new housing development would therefore help to meet the policy objectives of Issue B5: ‘Environmental Net Gain.’ This site should therefore be strongly supported by the LPA within the emerging Local Plan Review as a potential new housing site allocation. Q-B6: Lockley Homes would select ‘No’ to Question B6 referred to above. We maintain our view that areas of low-quality green space and areas of intensive farmland should not be designated as Wildbelt designations, if there is no robust, credible and up-to-date ecological survey evidence in place to support such designations. Otherwise the designations could be challenged by the private sector at future Planning Appeals as well as during the Local Plan forthcoming Examination in Public (EIP) Stage. Only those green space locations with sufficiently robust and demonstrable ecological value should be designated and form part of any Wildbelt designations. This approach is supported by guidance reinforced in paragraph 31 of the Revised NPPF (2021) which states that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” It is also noted that huge areas of rural lowland countryside within the Stratford-on-Avon District have already been significantly damaged by years of successive intensive farming practices. Stratford-on-Avon District Council’s Planning Policy Team “appears to have been fully asleep at the steering wheel” while these damaging landscape changes have been taking place across the countryside, where little, or no action has been taken by the Council’s Planning Policy Team, despite the removal of huge sections of hedgerow networks within the rural countryside, the removal of veteran and ancient trees from hedgerow networks, draining of farmland wildlife ponds, etc. The severe impacts of damage caused by intensive farming practices on farmland wildlife habitats is particularly evident within the open farmland landscape located immediately north of the Lockley Homes proposals site, on the northern edge of the Village of Broom settlement. This aspect is supported by robust and defendable photographic evidence in Appendix B of this SWLP Representations Statement (2023). To help deliver net gains for biodiversity and respond positively to guidance within paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021), the Council’s preparing the emerging SWLP Review should be far more pro-active in supporting new housing development proposals coming forward within areas of intensively farmed countryside, particularly where new housing development proposals are delivering Biodiversity Net Gain (BNG) solutions to help support declining wildlife species. Lockley Homes position on this issue is also strongly supported by guidance within the Warwickshire, Coventry and Solihull Local Biodiversity Action Plan (BAP), which is strongly supportive of new housing development proposals which include measures which actively seek to support the recovery of vulnerable populations of Priority Wildlife Species and the recovery of priority wildlife habitats across the South Warwickshire countryside. These issues are explored in considerable detail within Appendix C of this SWLP Representations Statement (2023). Q-B8: Lockley Homes would select ‘No’ to Question B8-1 referred to above. There may be areas of the best and most versatile agricultural land present on the edges of existing rural village settlements within the South Warwickshire countryside. However, greenfield sites within these areas should not necessarily be safeguarded within the SWLP (2023) given that they represent highly sustainable site locations for new housing development. This is particularly the case for areas of ‘greenfield’ land located outside of the designated Green Belt. In accordance with guidance within paragraphs 79, 141 (indent a) and 142 of the Revised NPPF (2021), these types of locations on the edges of existing rural village settlements should be prioritised for new housing development. Areas of low quality and under-utilised green space land such as the Lockley Homes site (which is located outside of the designated Green Belt) within the existing Village of Broom settlement boundary should be particularly prioritised for new housing development, without delay on an urgent basis. Given the very strong, clear and compelling sustainability credentials of the site in question as already evidenced in our Representations (March 2023), we consider that this site should be prioritised for future development and included without delay as new housing site allocation on the main Policies Map of the Council’s emerging South Warwickshire Local Plan (SWLP). These types of medium scale-sized land parcels should not be left for a Stage 2 SWLP to consider in future years, but should be considered as an urgent priority now, and brought forward for new housing within the emerging SWLP (2023). Our position on this issue has a strong level of planning policy support within the above NPPF guidance. In particular, within paragraph 79 of the Revised NPPF (2021) which is perfectly clear that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Further support is provided in paragraph 69 of the Revised NPPF (2021) which attaches considerable planning policy weight to the importance of small and medium sized site land parcels. It states that: “…Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly…” Q-B9: Question B9 - Lockley Homes would select ‘No’ to Question B9 referred to above. It is important that there is a sufficiently robust and defendable platform of ecological evidence to support and justify any site-based nature conservation designations. Use of non-designated sites would not provide a sufficiently robust approach and could potentially be vulnerable to challenge at future Planning Appeals and challenge at the future SWLP Review Examination in Public (EIP) stage. Q-B10: Lockley Homes maintains its view that new housing development sites coming forward within well-integrated infill site locations immediately alongside existing rural village settlements, within areas of intensive farmland should be supported for new housing development within the emerging SWLP for reasons already set out within this Representations Statement (2023). The emerging Local Plan Review should have a much more supportive and pro-active planning policy approach towards supporting new housing development proposals coming forward near to areas of intensive farmland in circumstances where meaningful Biodiversity Net Gain (BNG) features are being delivered within the new housing development site layouts. These aspects are covered in further detail within Appendix C of this Representations Statement (2023).

selected

selected

selected

No

No

Paragraph 79 of the Revised NPPF (2021) states that: “…To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby…” Responding to question B8.2, in accordance with the above NPPF guidance, Lockley Homes would suggest that the Council’s emerging SWLP (2023) should prioritise the future housing-led growth and sustainable expansion needs of existing rural village settlements located across the South Warwickshire countryside. This matter should be one of the key spatial planning policy priority areas for the emerging SWLP Review to consider, in order to help deliver a ‘More Positively Prepared Local Plan,’ and to allow the Plan to promote the most sustainable patterns of development - consistent with the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). Proposed housing sites such as the Lockley Homes site located within the Village of Broom settlement should be brought forward for new housing development in the SWLP (2023) as a matter of urgency, not left for consideration within a future Stage 2/ version 2 of the SWLP in many years from now. We have concerns that the SWLP and its accompanying Sustainability Appraisal (SA) are both not currently promoting the most sustainable patterns of new housing development, and the approach to Plan-making is therefore failing the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).

No

Lockley Homes would select ‘No’ to Question P1.1 referred to above. Producing two separate Local Plans – Parts 1 and 2 will add significant confusion and a major time delay to the Local Plan making process. This will cause significant uncertainty for housing developers, rural landowners, local businesses, local communities and other key stakeholders. Our concerns about the Council’s proposed Plan-making approach are set out below. Page 174 (Chapter 12) of the SWLP (January 2023) states that: “…The South Warwickshire Local Plan will be divided into two parts. Part 1 would be a single document, while Part 2 could consist of multiple documents. Neighbourhood Development Plans would form part of the wider Development Plan for South Warwickshire, but would not fall within either Part 1 or Part 2….” Lockley Homes strongly objects to the Council’s proposed Local Plan-making approach of producing a Stage 1 and Stage 2 (Parts 1 and 2) of the SWLP. This will just add a significant confusion to the Plan-making process, and will result in a significant time delay to Local Plan delivery across the South Warwickshire Region. At a time when the local economy is facing such considerable economic uncertainty. This does not bode well for the delivery of a certain and clear planning policy framework going forward across the South Warwickshire area. Page 174 of the SWLP (January 2023) states that ‘smaller and non-strategic housing site allocations’ will be brought forward under Part 2 of the Local Plan. In response, Lockley Homes considers that placing small-scale and medium scale housing sites within a Stage 2 SWLP is completely unacceptable situation. This proposed planning policy approach is in direct conflict with paragraphs 60 and 69 of the Revised NPPF (2021). Paragraph 69 of the Revised NPPF places considerable importance on small and medium-sized housing sites and their important contribution towards meeting the housing requirement of an area, and the fact that these sites are often built-out relatively quickly to help meet the urgent housing needs. These important small and medium-sized housing sites should be brought forward as a matter of urgency within the emerging SWLP at the very front of the Local Plan period, in order to help boost the supply of new homes, consistent with paragraph 60 of the Revised NPPF (2021). These types of small housing sites have a key role to play in helping to deliver a much-needed supply of new homes to help tackle long-standing housing shortfalls present across the South Warwickshire Region. Relying on large Strategic Housing Sites to support the front of the Local Plan period (Stage 1/ Part 1) also has considerable risks, given that the local area is currently facing significant economic pressures/ the local area is facing a 300-year-economic-recession-event, and severe volatility in the residential mortgages market due to rising inflation. This approach to Plan making may not therefore be deliverable and would fail deliverability tests set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). This would affect the ‘Soundness’ of the overall proposed Plan-making approach, given that the Local Plan could be challenged against the above NPPF guidance. We suspect that the Councils preparing the emerging SWLP are already aware that they are taking forward an unsound Plan-making approach that tails tests of Soundness in paragraph 35 (indent d) of the Revised NPPF (2021) – given the Plans continual ongoing failure and continued refusal to promote the most sustainable patterns of new housing development within the South Warwickshire Region. This is supported by evidence given the highly obstructive planning policy approach being taken against the Lockley Homes site within the Village of Broom settlement. Which represents a highly sustainable site location for new housing. Moving smaller and medium sized sites to some time in the distant future to be considered within a SWLP Stage 2/ Part 2 Plan version, is therefore helping the Council’s avoid the issue of why the Council’s are still refusing to promote the most sustainable patterns of new housing development coming forward within the South Warwickshire Districts. We find this highly obstructive approach being taken towards Local Plan preparation very concerning. The Council’s Planning Policy Teams stance on these issues is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making.

No

Questions P1.3 and Q-P1 4: - Lockley Homes would select ‘No’ to Question P1.1 referred to above. Producing two separate Local Plans – Parts 1 and 2 will add significant confusion and a major time delay to the Local Plan making process. This will cause significant uncertainty for housing developers, rural landowners, local businesses, local communities and other key stakeholders. Our concerns about the Council’s proposed Plan-making approach are set out below. Page 174 (Chapter 12) of the SWLP (January 2023) states that: “…The South Warwickshire Local Plan will be divided into two parts. Part 1 would be a single document, while Part 2 could consist of multiple documents. Neighbourhood Development Plans would form part of the wider Development Plan for South Warwickshire, but would not fall within either Part 1 or Part 2….” Lockley Homes strongly objects to the Council’s proposed Local Plan-making approach of producing a Stage 1 and Stage 2 (Parts 1 and 2) of the SWLP. This will just add a significant confusion to the Plan-making process, and will result in a significant time delay to Local Plan delivery across the South Warwickshire Region. At a time when the local economy is facing such considerable economic uncertainty. This does not bode well for the delivery of a certain and clear planning policy framework going forward across the South Warwickshire area. Page 174 of the SWLP (January 2023) states that ‘smaller and non-strategic housing site allocations’ will be brought forward under Part 2 of the Local Plan. In response, Lockley Homes considers that placing small-scale and medium scale housing sites within a Stage 2 SWLP is completely unacceptable situation. This proposed planning policy approach is in direct conflict with paragraphs 60 and 69 of the Revised NPPF (2021). Paragraph 69 of the Revised NPPF places considerable importance on small and medium-sized housing sites and their important contribution towards meeting the housing requirement of an area, and the fact that these sites are often built-out relatively quickly to help meet the urgent housing needs. These important small and medium-sized housing sites should be brought forward as a matter of urgency within the emerging SWLP at the very front of the Local Plan period, in order to help boost the supply of new homes, consistent with paragraph 60 of the Revised NPPF (2021). These types of small housing sites have a key role to play in helping to deliver a much-needed supply of new homes to help tackle long-standing housing shortfalls present across the South Warwickshire Region. Relying on large Strategic Housing Sites to support the front of the Local Plan period (Stage 1/ Part 1) also has considerable risks, given that the local area is currently facing significant economic pressures/ the local area is facing a 300-year-economic-recession-event, and severe volatility in the residential mortgages market due to rising inflation. This approach to Plan making may not therefore be deliverable and would fail deliverability tests set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). This would affect the ‘Soundness’ of the overall proposed Plan-making approach, given that the Local Plan could be challenged against the above NPPF guidance. We suspect that the Councils preparing the emerging SWLP are already aware that they are taking forward an unsound Plan-making approach that tails tests of Soundness in paragraph 35 (indent d) of the Revised NPPF (2021) – given the Plans continual ongoing failure and continued refusal to promote the most sustainable patterns of new housing development within the South Warwickshire Region. This is supported by evidence given the highly obstructive planning policy approach being taken against the Lockley Homes site within the Village of Broom settlement. Which represents a highly sustainable site location for new housing. Moving smaller and medium sized sites to sometime in the distant future to be considered within a SWLP Stage 2/ Part 2 Plan version, is therefore helping the Council’s avoid the issue of why the Council’s are still refusing to promote the most sustainable patterns of new housing development coming forward within the South Warwickshire Districts. We find this highly obstructive approach being taken towards Local Plan preparation very concerning. The Council’s Planning Policy Teams stance on these issues is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making.

Page 181 (Policy CS.19 – Housing Mix and Type) states that: “…Affordable Housing requirements and thresholds dependent on location. Requirement for 35% requirements relating to on-site provision, affordability and tenure, on-site integration and delivery…” Lockley Homes response: Lockley Homes maintains its view that there has been a huge, substantial, unprecedented and significant recent material change, and a huge and rapid shift in highly damaging adverse economic circumstances now facing the South Warwickshire Region and the wider United Kingdom, due to the presence of the ongoing global coronavirus pandemic (COVID-19), economic uncertainty caused by Russia’s Spring 2022 invasion of Ukraine, and the subsequent severe and unprecedented economic downturn. Which is anticipated to cause one of the worst economic recessions in the UK in living memory since records began. The severity of the forthcoming recession is now acknowledged by central Government (London), who accept that the COVID-19 pandemic has caused one of the worst economic recessions within the UK not seen for the last 300 years. This is highly significant, and should now result in an urgent re-shaping of affordable housing, Community Infrastructure Levy (CIL), planning obligations, and infrastructure policies within the Council’s emerging Local Plan Review. The Council’s preparing the emerging SWLP and its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) now need to begin to finally accept that their highly onerous planning policy position on these policy issues now needs to change to help support the highly fragile local economic recovery, and help support the house building development industry at a time when they are bringing forward sites under an incredibly challenging economic climate, which will affect the financial viability of many housing schemes. A highly onerous affordable housing and CIL/ planning obligations/ infrastructure demands approach therefore needs to be avoided within the emerging Local Plan Reviews referred to above. The worst global health pandemic event to affect the UK for the last 100 years, combined with the presence of one of the most severe economic recessions for the last 300 years, should now result in a more supportive Development Management and Planning Policy approach being taken (to support the interests of the private sector development industry and rural landowners) by the LPA within the emerging SAP and SWLP in relation to unreasonable and highly onerous affordable housing planning policy requirements, Community Infrastructure Levy (CIL) planning policy requirements, and other infrastructure demands/ planning policy requirements being placed on the house building development industry, the local business community and rural landowners looking to bring forward sustainably-located new housing development sites. In order to help support the future financial viability of new housing development schemes coming forward across the district at an incredibly challenging time, and to help support the fragile local economic recovery across the district. This approach would be consistent with Government guidance reinforced in paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The rapid change in economic circumstances as described above now facing the South Warwickshire Region Local Plan area (which has had a huge and devastating impact on the local economy) should now therefore be carefully shaped into the Plan-making approach being taken by the District Council’s going forwards within both the emerging SAP and SWLP Local Plan Reviews, and their policy formulation. To ensure that the plan-making approach taken within the emerging Local Plan Reviews is based on a platform of sufficiently robust and up-to-date evidence, is deliverable, and responds effectively to the rapid change in severe adverse economic circumstances now facing the local area, consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 82 (indent d) of the Revised NPPF (2021). The severe and unprecedented global coronavirus (COVID-19) pandemic, and the continued 15 months of pro-longed lockdown restrictions across the UK during the years 2020 and 2021, has highlighted and placed into very sharp focus the continued relevance and importance of the need for LPA’s to build-in sufficient planning policy flexibility when they are drafting policies within emerging Local Plan Reviews, for the reasons clearly set out above. These ‘pandemic-related factors’ are of critical importance and should now therefore be carefully shaped into and form part of the planning balance when preparing the Council’s emerging SAP and SWLP Local Plan Reviews as the Plans move forward to their next stage of Local Plan preparation. The evidence is perfectly clear, all of the above ‘pandemic-related’ factors appear to have been given no planning policy consideration and material planning weight whatsoever by the LPA’s when preparing the Council’s emerging Site Allocations Plan (SAP) and emerging South Warwickshire Local Plan (SWLP). We have concerns about this ongoing failure being taken towards Local Plan preparation by the Council’s Planning Policy Teams, who after all, are supposed to be experts in Local Plan preparation. In particular, we consider that any new policies contained within the new emerging SWLP covering policy areas such as affordable housing policy, will need to substantially revised and current planning policy affordable housing threshold levels substantially reduced, to help ensure that the future financial viability of new residential development schemes coming forward across the South Warwickshire Region is not adversely affected and site viability severely harmed. The affordable housing planning policy origins and foundations are sitting on top of a huge mountain of unstainable and insufficiently robust evidence, given that the affordable housing policy is being directly carried over from the existing Stratford-on-Avon District Council’s existing adopted Core Strategy (adopted July 2016), which is forged, set and fixed on highly questionable, insufficiently robust, heavily out-of-date pre-COVID-19 economic data. This Core Strategy (adopted July 2016) no longer has any planning policy credibility to dictate the 35% affordable housing policy trigger threshold, and to carry this over and force-it-through into the emerging SWLP (2023). The Council’s planning policy on these issues is no longer defendable and fails clear tests in paragraph 31 of the Revised NPPF (2021) which reinforces that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” The evidence would seemingly suggest that the Council’s evidence base on these issues is unsound, and no longer fit for purpose to inform future Plan preparation work going forward within the emerging SAP and SWLP Local Plan Reviews. The Council’s preparing the emerging SAP and SWLP Local Plan Reviews now need to face the reality of the new economic situation, and start to begin to finally accept that times have now significantly changed and moved on since the year 2016 Stratford-on-Avon District Core Strategy was adopted. We would suggest that a 5% affordable housing planning policy threshold going forward within the emerging SWLP Local Plan Review (2023) would be more appropriate given the massive long-term shift in the adverse economic conditions now facing the Local Plan area as described in detail above. Similar to affordable housing, the same issues equally apply to LPA Community Infrastructure Levy (CIL) excessive, onerous and highly damaging planning policy requirements and unreasonable planning policy demands. The existing planning policy evidence base that underpins and provides the current planning policy platform and policy foundations to support the current CIL planning policy regime across the South Warwickshire Local Plan Review area, now lacks any kind of planning policy credibility given that its policy assumptions are now based on a heavily out-of-date and unsound set of economic circumstances. The existing planning policy approach therefore places an unreasonable, highly damaging, excessive and onerous financial burden on the house building development industry, due to wholly unreasonable and heavily out-of-date CIL planning policy requirements. The existing planning policy approach and unreasonable policy regime therefore needs to be urgently revisited and heavily revised within the emerging SWLP Local Plan Review, and more appropriately shaped towards reflecting the heavily adjusted set of long-term adverse economic circumstances now facing the Local Plan area as described above. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider UK economy should now play a prominent role in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews, in particular, those policies covering affordable housing, CIL, planning obligations, infrastructure planning policy requirements, etc. In order to ensure that the Council’s planning policy Plan-making approach on these matters is sufficiently robust and responds effectively to NPPF guidance referred to within this response. The approach described above, would correspond well to guidance in paragraph 31 of the Revised NPPF (2021) which is perfectly clear that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” As well as by guidance in paragraph 82 (indent d) of the Revised NPPF (2021) referred to further above These critically important ‘pandemic-related factors’ described above therefore require critical consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams as part of their ongoing Plan-preparation work going forwards. To ensure that the Council’s planning policy approach is sufficiently robust, based on a platform of credible and fit-for-purpose evidence, and responds effectively to guidance in paragraphs 31, 35 (indents b and c) and 82 (indent d) of the Revised NPPF (2021).

selected

selected

selected

No answer given