Issue and Options 2023

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Issue D2: Design Codes and design guides Q-D2: please select all options which are appropriate for South Warwickshire The Church Commissioners considers Option D2c most appropriate and notes that these are likely to be the larger and more strategic sites, such as any new settlements. It is not appropriate to have a Design Guide across South Warwickshire as the area is too vast, and has a range of characteristics, therefore would not be representative or achieve suitable design across a variety of landscapes. Therefore, each Site should be assessed on its’ own merits. Issue D3: Designing adaptable, diverse and flexible places Q-D3: Please select all options which are appropriate for South Warwickshire The Church Commissioners supports Option D3b where policy should specify a minimum density requirement across South Warwickshire. However, the Policy needs to be fully tested and evidenced to decipher the minimum housing density whilst also containing flexibility to enable different densities to be achieved in situations such as where housing need requires a greater number of one-bedroom flats, or 4 bedroom houses which would impact upon density. Furthermore, potential site constraints may also impact upon density, consequently, policy needs to be worded identifying the minimum density to be achieved, unless an alternative can otherwise be demonstrated as suitable. 6.5 Clarification is required in relation to the density suggestions, as Option D3b states that an example could be set at a similar level to that of the existing policy at Warwick, being 30dph, whereas the Sustainability Appraisal, produced as part of the evidence base, is based upon the assumption of 35dph, thus an inconsistency between the two approaches.

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Yes

Q-D4.1: The Church Commisioners agrees that this is an appropriate range of topics, however it is important that the topics achieve the overarching objective of promoting social interaction, as per paragraph 92 of the NPPF. However, the minimisation of conflict between users, as per Paragraph 112 of the NPPF, should also be included within the range of topics. It should also be included and noted that the design of streets should be reflective of current national guidance, including the National Design Guide and National Model Design Code.

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Issue W1: Pollution Q-W1: Should the Part 1 plan include a policy on pollution? 7.1 The Church Commissioners supports the introduction of a policy which would cover all pollution and would ensure that any development that would result in a significant impact on the health and wellbeing of people in an area will not be permitted unless effective mitigation can be achieved. However, the Policy needs to be suitably worded to allow for offsetting and mitigation measures. The Policy should also be clear in defining what is classed as effective mitigation. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q-W3: Please select the option which is most appropriate for South Warwickshire One of the overarching principles to achieve the vision of the SWLP is ‘a healthy, safe and inclusive South Warwickshire – enabling everyone to enjoy safe and healthy lifestyles with a good quality of life.’ Consequently, an overall policy should be included with Part 1 to help achieve the overall vision, however cannot be detailed until Part 2. As a result, the Policy would need to be brief but re-affirm that development should achieve healthy, safe and inclusive communities. The Policy needs to be worded in accordance with the NPPF, specifically paragraph 8, contributing towards the overall achievement of sustainable development, whereby the social objective is achieved by supporting a strong, vibrant and healthy community. Furthermore, Paragraph 92 of the NPPF states that planning policies should aim to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible and enable and support healthy lifestyles.

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Issue T1: 20-minute neighbourhoods Q-T1: Please select all options which are appropriate for South Warwickshire The Church Commissioners suggests that Option T1a is pursued on the basis that it is not appropriate to introduce this Policy within the strategic element of the Part 1 Plan, and should therefore be considered at a later date, within the Part 2 Plans. Furthermore, the principle of 20-minute neighbourhoods predominantly relates to the location of development, which will be enacted through allocations. The inclusion of a subsequent policy would therefore be redundant. 8.2 However, if the Councils wish to include consideration to twenty minute neighbourhoods within Part 1, it should be in reference to principles, as Option T1b sets out. However, all principles need to be tested, evidenced and justified and as this Option is not specific enough in identifying the principles, cannot be fully commented upon. Issue T2: Sustainable transport accessibility across South Warwickshire Q-T2: Please select the option which is most appropriate for South Warwickshire Option T2a should be incorporated into the SWLP, where a Policy is introduced to allow for a hierarchical approach. The Church Commissioners agrees car parking standards should be amended in areas where public transport accessibility is strong, to encourage reliance away from the private car. 8.4 However, sufficient evidence is required to determine what transport infrastructure is required as a result of developments and how the hierarchy varies based upon different geographical locations. As a result, the hierarchy needs to be considered to ensure flexibility, as different geographical areas would have different hierarchies, and therefore Policy needs to ensure flexibility. 8.5 Development also presents an opportunity to deliver additional transport infrastructure, including enhancing off-road pedestrian and cycle connectivity.

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Issue B5: Environmental Net Gain. Q-B5: Please select the option which is most appropriate for South Warwickshire The Church Commissioners states that Option B5c is appropriate in relation to Environmental Net Gain. The Church Commissioners appreciates and acknowledges the requirement of the Environmental Act, for 10% biodiversity net gain, however cannot support either Option B5a or B5b as it is unclear how either option would work in practice. Clarity is required to understand how Air Quality, Water Quality and Carbon Capture can feed into the environmental net gain concept, and further evidence is required to show how this would work in practice, but also from a viability perspective. As a result, The Church Commisioners reserves the right to comment on any future policy later in the plan making process. Issue B6: Wildbelt designations Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? The South Warwickshire Local Plan should not introduce Wildbelt designations, to enable the goal of 30% of land to be managed for nature by 2030. As Issue B6 sets out, ‘the idea of Wildbelt is that it protects the space that nature needs for the future,’ however The Church Commissioners questions how the Council are aware of what areas require protecting at this stage, due to the lack of evidence produced at this point. The Councils need to undertake further work, including that to understand their housing and employment land requirements prior to introducing further designations. Any proposed Policy in relation to Wildbelt designations, including the identification of land needs to be fully consulted and engaged upon if the Council proceed on this basis.