Issue and Options 2023

Introduction 1.1. These representations are made by Pegasus Group, on behalf of Corbally Group (Harbury) Ltd., (hereafter Corbally Group), in response to the Issue and Options consultation for the South Warwickshire Local Plan. 1.2. These representations relate to land covering some 10ha at Harbury Depot (hereafter ‘the Site’), lying to the north of Bishops Itchington and adjoining the recently developed Barratt David Wilson (BDW) residential developments known as ‘Bishops Hill and the ‘Willows’’. The Site is identified on the Location Plan at Appendix 1 and is being promoted as being available, achievable and deliverable, with the capacity to deliver some 210 homes. The Site was promoted through the 2021 Scoping and Call for Sites consultation and is identified on the Council’s interactive maps [redacted text] with Site ref: 144, noted as being a Housing/Residential proposal. The detail of the Call for Sites submission is not repeated within these representations, but specific comments are made where appropriate to respond to the questions identified in the Issues and Options consultation. A copy of the Vision Document submitted alongside the Call for Sites is further attached here as Appendix 2. These representations have had regard to the published consultation document and questions set out therein, accompanying documentation forming the current evidence base, and the national planning context. 1.6. The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework 2021 (NPPF), paragraph 35: • Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; Effective – deliverable over the Plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 1.7. These tests of soundness, along with other legal and procedural requirements associated with the plan-making process provide a contextual framework for these representations. It is noted that the consultation changes to the NPPF published in December 2022 propose to remove the requirement for Development Plans to be ‘Justified’ in order to be found sound. However, at the time of writing and submission of these representations that change has not been enacted, is the subject of significant representations not least from the RTPI who note in their response on the NPPF consultation that; ‘Any suggestion that plans need not meet this high bar must be resisted.’ These representations therefore still take the test of ‘justification’ into account. 1.8. These representations refer directly to the specific questions set out in the Issue and Options consultation document and also respond to the following evidence base documents where appropriate: • South Warwickshire Local Plan Part 1 Stage 2: Issues and Options Consultation, January 2023 • Sustainability Appraisal (SA) November 2022 • Housing and Economic Development Needs Assessment (HEDNA) November 2022 • Urban Capacity Study, October 2022 • South Warwickshire Settlement Analysis, January 2023 • Evolving the Spatial Growth Options – The Story so Far – Topic Paper, August 2022 Land at Harbury Depot, Harbury 9.1. Corbally Group has an interest in land at the Harbury Depot site, Bishops Itchington. It has been identified as Reserve Site by SoADC in their October 2020 Site Allocations Plan (SAP) Reg 18 Consultation and the July 2022 SAP consultation. The site is now identified as Site 144 in the South Warwickshire Local Plan Scoping and Call for Sites interactive mapping tool. 9.2. The site relates well to the recent BDW development of ‘Bishops Hill/Willows’ located to the south, and development would provide the opportunity through critical mass, to provide some small-scale community facilities to support both developments. There are no statutory designations nor constraints covering the site that would preclude its development. 9.3. Corbally control land at Harbury Depot and have successfully promoted the core of the old cement works site for residential development, outline planning permission for up to 200 homes was granted in September 2014, with an outline approval for a further 80 dwellings granted in September 2016. 9.4. Both of these outline approvals progressed rapidly to Reserved Matters approvals, and the site is now nearing completion. This provides evidence of both market demand in this location and Corbally’s local track record on rapid delivery. This site could be delivered within 5 years. 9.5. The site is identified as a Reserve Site through the SoADC SAP under reference LRS.B (previously LSL.04B) as having the potential to deliver some 210 dwellings. 9.6. Detailed work has been undertaken to establish baseline matters such as soils, drainage, ecology etc, and there are no constraints to the early release and development of the site, which is capable of delivering new market and affordable homes within the next 5 years. 9.7. To support the delivery of the site, and its promotion through the South Warwickshire Local Plan process, a detailed Vision Document has been produced to demonstrate the site's capacity, and technical deliverability (Appendix 2). The Vision Document is submitted alongside these representations and should be read in conjunction with them, it confirms inter alia, that from a landscape and visual analysis, the site is well placed to accommodate development without any significant impacts into what is an ‘unremarkable local landscape character’. The Vision draws on evidential work which has been undertaken in respect of the Phase 1 and 2 elements of the consented scheme (built out by BDW), with regard to understanding matters such as drainage, ecology, transport and noise, and has been updated with additional evidence to support specific landscape and design considerations. The Vision supports the emerging SoADC SAP identification of the site as a sustainable location for new development, capable of accommodating circa 210 dwellings. The site is within 0.6 miles of the nearest shops and services in Bishops Itchington including a post office, convenience store, Co-Op food retail and doctor's surgery, all of which are accessible by footpath through the nature reserve to the south that leads directly into Bishops Itchington village centre. 9.9. The Vision Document recognises the potential to also introduce a small local centre element to the scheme, which alongside the existing consented Phases 1 and 2, will be an element of viable supporting local infra-structure, to complement existing facilities in Bishops Itchington, but which Phases 1 and 2 alone were not able to economically support. 9.10. The new infrastructure and access introduced off Station Road to serve Phases 1 and 2 has both improved the immediate road network and has sufficient capacity to accommodate the development of this Site. The use of that infrastructure to access this Site is not constrained by third party landholdings or the requirement for upgraded site access infrastructure. 9.11. The Vision Document analyses the site context, its setting within the landscape, its proximity to existing facilities, public transport, and the major employment area of Gaydon/Lighthorne Heat - JLR (less than 4 miles distant) and through a process of establishing both constraints and opportunities, draws together an illustrative masterplan for how the site could be delivered. The Council are invited to review the Vision Document, and recognise the benefit that early delivery of the site could bring, both in terms of; 1) meeting any housing requirement within the next 5 years, in a manner consistent with an overarching spatial strategy which continues to acknowledge the role that development around some of the smaller settlements will bring, and, 2) enhancing the sustainability of the existing Phase 1 and 2 BDW developments. Conclusion 10.1. This representation has been prepared by Pegasus Group on behalf of Corbally Group (Harbury) Ltd. 10.2. Corbally are promoting land at Harbury Depot for residential development. The land is sustainably located adjacent to the newly developed Bishops Hill and Willows developments, and is well related and connected through that to Bishops Itchington, and its social and physical infrastructure. This land is suitable, available and deliverable and should be identified as a location for future residential development as part of the South Warwickshire Local Plan. 10.3. This representation demonstrates that there are no significant constraints that would preclude the development of the site for residential development. The Vision Document shows how circa 210 homes can be accommodated on the site, along with on-site open space, landscaping, BNG and sustainable drainage. 10.4. Corbally Group welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site in order to fully assist in the assessment of this site, this can be provided upon request.

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Q-V3.1+ Q-V3.2 As set out in response to the Scoping and Call for Sites consultation, Corbally supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Corbally supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed, and thus how the Vision will be delivered, do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes on to talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out several objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported, and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle, and it is acknowledged that national policy is pursuing ‘beauty’ in planning, however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice in South Warwickshire.

The Issues and Options document is supported by a Sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA: The principle and broad approach of the SA is supported, and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements and excludes some settlements altogether that should be considered as sustainable locations for growth, such as Bishops Itchington and Harbury. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives. Further comments are made below and in following sections regarding the SA with specific reference to Bishops Itchington/Harbury and the Site.

Q-I2: It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Recognising that S106 will still play a part in site related infrastructure delivery, it is important that there is robust testing of the appropriate level of CIL having regard to site viability. Q-I5: The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detailed viability work must support the Local Plan process. Such viability work should either; a) be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58, or b) if based on general ‘site character types’ be sufficiently flexible to allow viability to be considered through S106 to address any unforeseen exceptional site delivery costs. 3.12. The Infrastructure Delivery Plan will be an important part of the evidence base, and Corbally Group would welcome the opportunity to comment on it.

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Q-S3.2: It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.14. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S8.2 The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.27. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.28. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold, perhaps in a range to reflect the existing settlement scale, would allow for an appropriate higher level of development and support greater on-site affordable housing provision. Q-S9: There will be a need to maintain established settlement boundaries identified within the currently adopted local plans as a minimum to accommodate development that is of an appropriate and sustainable scale in relation to these settlements, where appropriate within the plan period. 3.30. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. 3.31. Beyond this, to be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable locations to meet the development needs of the Plan. It is considered that a review of settlement boundaries would be an appropriate approach for the Joint Local Plan.

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Q-S4.1: Growth at existing settlements across the Joint Plan area should form a part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. This is so, even when large scale new settlements are proposed to address significant parts of the housing requirement. 3.16. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.17. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing local infrastructure requirements and provide an appropriate mix of housing for the area. 3.18. Bishops Itchington and Harbury are identified within Option 5 however they each benefit from a range of local services and facilities and would contribute towards achieving the Council’s aspiration for 20 minute neighbourhoods. The SA should assess Bishops Itchington and Harbury and proposed development options for the settlements, including this Site. The site, sits directly north of recent residential development by BDW, on a part of the former Harbury Depot site, and would form an extension to it, with the ability to further enhance its sustainability through provision of a convenient small local retail facility and community space, commensurate with the development’s size. 3.19. This Site (Call for Sites ref: 144) is located in a sustainable location, well related to existing development, and the newly created infrastructure from the BDW scheme, it should be positively considered as a location for growth, related to a recognition of the roles that Bishops Itchington and nearby Harbury play as sustainable settlements. Q-S4.2: Bishops Itchington is not included in the settlement analysis. It should be included in this assessment as the evidence base evolves to support the Plan, and in recognition of its size, supporting physical and social infrastructure, and sustainable location, close to the major employment centre (and proposed employment expansion) at Gaydon/Lighthorne Heath.

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Q-H1-1 Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of ‘significantly boosting’ the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (paragraph 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix 3) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear.” 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.