Issue and Options 2023

1. Introduction 1.1 About Copperfield 1.1.1 Copperfield Land and Planning Land Limited are a specialist Town Planning Consultancy based in Bristol. The business focuses on providing planning advice to a wide range of clients in the South West and Midlands including assessments relating to sustainability, master planning and spatial planning policy matters. 1.1.2 Copperfield have previously submitted representations on behalf of St. Modwen during 2021 and 2022 relating to previous stages of the South Warwickshire Local Plan and Call for Sites. 1.2 About St. Modwen 1.2.1 St. Modwen are a highly successful land promoter and housebuilder who specialise in the delivery of large scale sustainable development solutions and mixed use regeneration projects. They are currently the lead master developer of high quality sustainable new community at the Meon Vale development in Stratford upon Avon. 1.2.2 St. Modwen have an interest in land to the East of Southam and are engaged in the long term promotion of the site. It is intended to promote the land through the newly formed South Warwickshire Local Plan by working with the combined authority planning team and other local community stakeholders to deliver a successful large scale sustainable housing led development for the town. 1.3 Scope of this Representation 1.3.1 This representation seeks to promote the Town of Southam and particularly land to the east as a sustainable location for new growth within the new South Warwickshire Local Plan area. Within the context of growth for the town the appended Vision Document also seeks to identify the development potential and opportunity value for land to the East of the town. 1.3.2 Section 2 of this report sets out some high level principles and the sustainable development focus for the land within control of St. Modwen. It incorporates a range of potential land uses to form a sustainable new suburb supporting the long term vitality of the existing town centre and providing development of sufficient quantum to provide key social and physical infrastructure. This report also sets out a delivery timetable for the development providing clarity on the potential of the site within the plan period. 1.3.3 Section 3 of the report sets out Southam’s role within the current Local Plan for Stratford upon Avon and its emerging role within the new South Warwickshire Local Plan. This section establishes the importance of the town to the District, its residents and the surrounding rural areas who rely upon Southam as a service centre. 1.3.4 Section 4 takes a more detailed look at Southam as a sustainable settlement and its ability to accommodate growth. The section sets out why the land to the East of the town should be considered favourably for new development when considering the emerging policy objectives and evidence base of the new Local Plan. Section 5 of the report responds to the SWLP Consultation document Issues as they relate to Southam as a settlement and land to the east of Southam as a preferred Broad Location. St. Modwen’s representation are highlighted and 17 sections of the SWLP Issues and Options document assessed. 1.3.6 Section 6 sets out broad conclusions from our assessment of the Issues and Options consultation document. 2. About Land East of Southam 2.1 Location 2.1.1 The 98.7Ha site is located to the east of the rural market town of Southam and is shown outlined in red in the plan below. 2.1.2 It comprises principally agricultural fields used for arable crops. Fields are generally bounded by hedgerows. The Site is bounded to the north and to the south east by the A425 Daventry Road and Welsh Road East respectively. The River Stowe bounds part of the Site to the east. Beyond these linear boundaries is open countryside. To the west the Site is bounded by modern residential development at Flying Fields and the town of Southam. 2.2 Master Planning Principles 2.2.1 A team of technical specialists have been developing a Masterplan Vision Document and a short version has been submitted alongside this representation to set out the ambitions for the project. The vision document is appended to this representation document. 2.2.2 The site initial concepts offer the following key features: A mix of high quality housing, including affordable housing and potential for later years provision, responding to local need; • A new Country Park accessible by foot and cycle providing access to green spaces, formal and informal sports and play and enhanced biodiversity Infrastructure; • S.106 and CIL funding for education provision including a primary school and land for a potential secondary school (or other uses); • Social infrastructure including potential convenience, retail, remote working facility, and space for GP or dental provision within a neighbourhood centre; • Employment opportunities through construction phase and through the provision of mixed use communities including employment opportunities on the development; • An extension to the existing community well integrated through sustainable access routes; • Economic benefits including council tax income and additional spend on local businesses generated by the new residents; • Enhanced connectivity opportunities via the existing gateways into the east of the town with public transport access and dedicated pedestrian and cycle networks. The site has the potential to deliver a balanced communities solution for Southam supporting the town centre and other local services, delivering up to 2000 new market and affordable homes with sustainability and carbon reduction as a key feature of the new community. 2.3 Delivery in the Plan Period 2.3.1 The 2018 Letwin Review was a Government commissioned Independent Review of Build Out on major large scale housing schemes. Letwin’s report was presented to parliament in October 2018 to establish whether land banking within the industry was occurring. 2.3.2 His analysis focused on the issue of the build out rate of fully permitted new homes on the largest sites in areas of high housing demand. Approximately 92 sites of over 1,500 dwellings were reviewed with an average site size of 3,327 new homes. Data found that the average length of the build out was 15.5 years equating to an average large site size delivery of 214 homes per annum. Letwin excluded periods of enabling works and planning promotion or application periods in this assessment. 2.3.3 Further research on the enabling of large site delivery was captured in Lichfields ‘Start to Finish’ 2020 Report documenting the challenges of consenting, enabling and delivering large scale housing schemes. The report highlighted that from the date at which an outline application is validated, the average figures can be 5.0-8.4 years for the first home to be delivered; 2.3.4 St. Modwen as master developer with a demonstrable track record of delivery of major mixed use development schemes within Stratford Upon Avon District (Meon Vale Development) are ideally placed to deliver higher levels of development on schemes of this nature. The table below shows how the master developer approach could deliver significant benefits through the plan period using a 3 housebuilder build out model. A LDO process could be used if supported by the Local Authority as this could speed up delivery. 3. Southam in the Issues and Option Consultation 3.1 Southam’s current role in Stratford on Avon Local Plan 3.1.1 Southam is a market town located in the north-east of Stratford-on-Avon District, about six miles to the east of Leamington Spa. It has a population of 6,567 (Census 2011 data). 3.1.2 The A423 runs through Southam, connecting the market town to Coventry in the north and Banbury in the South. Access to the M40 at Gaydon is located only 5 miles to the south and the town is strategically well located for commuting to the major Conurbations in the West Midlands. The town expanded considerably between 1961 and 1971 and more recently between 1980 to 2008. The latest allocated sites are also being delivered with a further 1000 dwellings being constructed in the current plan period. Development locations have been influenced by the introduction of the A423 Southam Bypass constructed in 1992. Most development is located to the west of the A423 and it is only in the last plan period that large scale residential development of any size has moved out to the east. 3.1.3 The town has a conservation area at its core including the town centre retail space. Out of town convenience in the form of a Tesco superstore has been built on the SW of the town on the A425 Leamington Road. The town is also well provisioned with a good employment base centred around the larger Industrial buildings which are located in the south of the town. 3.1.4 The Core Strategy 2011-31 vision for Southam states that it will continue to prosper as a centre and focal point for shops, services and jobs for a sizeable rural catchment. Development will have taken place to the north, east and south of the town to provide significant numbers of new homes, a range of new sports facilities and other community infrastructure, and about 3 hectares of additional employment land. In 2011 Southam had a population of 6,567 people and with growth in the last 10 years this is now grown to 8,114 people. 3.1.5 The Stratford-on-Avon Core Strategy classes Southam as a Main Rural Centre that functions as a service centre for large parts of the eastern section of the district. It is noted that it provides essential facilities for the surrounding rural area. 3.1.6 Within the 2015 Core Strategy the Local Authority noted the following potential future growth issues and opportunities for Southam:  Southam’s character as a rural market town needs to be protected;  Development to the east of the bypass would tend to exacerbate the issues of severance and integration that has been experienced with large housing estates built in the 1990s;  If any development is to be acceptable to the east this area, high quality crossings of the bypass for pedestrians and cyclists will be essential in order to provide attractive links to the town centre, schools and various facilities; Landscape Sensitivity Study identifies much of this area to the east as being of only medium value in terms of impact from housing development;  Land on the southern edge of the town is of medium landscape value;  The sloping and elevated land relating to the Stowe Valley on the west side of the town is particularly sensitive in landscape terms and would impinge on what remains of the open aspect of this part of the town’s setting;  The Stowe Valley area is designated as an Area of Restraint. The Landscape Sensitivity Study identifies the entire western flank of the town as high/medium value;  None of the land on the periphery of Southam is of high quality agricultural value;  There are a number of specific ecological and archaeological features that need to be taken into account, including some of the best surviving ridge and furrow in the area;  There is also an extensive Conservation Area covering the central part of the town and the open space to the west of the town centre;  There is a mineral safeguarding area to the north east of the town, beyond the bypass;  The cutting sides of the bypass at its northern end, and the quarry associated with Southam Cement Works, are designated as Regionally Important Geological Sites;  Further large-scale development proposals in the town will be dependant on additional capacity being provided at the Itchen Bank Wastewater Treatment Works. This will require the involvement of Severn Trent Water;  The River Stowe valley through Southam to its confluence with River Itchen lies within Flood Zone 3a;  The route of the proposed High Speed Two railway runs close to the southern edge of the town;  The employment land study resisted major employment growth unless major housing is proposed but noted the provision of small business floorspace on existing sites should be encouraged;  The town centre needs to be improved through a wide range of measures to improve its economic viability and physical appearance;  The Policy AS7 records the need to improve formal sports pitch provision and improved pedestrian links to the town centre. 4 The Local Plan also sets out aspirational objectives for the built environment and setting of Southam which its states will have been enhanced, including by restraining development in the Stowe Valley to the west of the town. The Local Plan allocation map is below: 3.1.5 The Core Strategy identified Southam as a sustainable location for significant growth. It looked to deliver about 1,100 homes in the market town over the plan period. Three sites were allocated for development in the Core Strategy: o Land West of Banbury Road, Southam (SOU.1): 200 homes o Land West of Coventry Road, Southam (SOU.2): 165 homes o Land South of Daventry Road, Southam (SOU.3): 530 homes 3.1.6 The HS2 line is now in construction to the south of the settlement and all three of the above allocations are being delivered. 3.2 Southam’s future role in the New South Warwickshire Local Plan 3.2.1 The emerging South Warwickshire Local Plan will replace the existing Stratford-on-Avon Core Strategy and the existing Warwick Local plan to provide a combined strategy for both districts. From 10 May to 21 June 2021, a Scoping and Call for Sites consultation was run. The consultation’s focus was to determine where future growth should be located. Seven growth options were proposed, of which four identified Southam as a potential location for future growth. There were:  Growth Option B - seeks to accommodate growth along existing bus corridors  Growth Option C - along main road corridors;  Growth Option E - in areas with the greatest need for new homes and jobs due to higher unemployment rates, lower qualifications and high need for affordable housing based on the housing waiting list.  Growth Option G - proposes to locate growth in settlements that have been identified as suitable locations for development in the existing Local Plans. 3.2.2 The feedback to this consultation has resulted in further growth options being included in the 2023 Issues and Option Consultation. Southam again plays its part in a number of these options. 3.2.3 Southam is listed under the following Growth Options in the January 2023 Issues and Options Consultation:  Growth Option 3 – Economy  Growth Option 4 – Economy and Sustainable Transport  Growth Option 5 - Dispersed 3.2.4 Southam is excluded from Option 1 – Rail Corridors as it is not currently serviced by a railway station with the nearest services being Leamington Spa and Warwick Parkway. Southam is also excluded from Option 2 – Sustainable Travel by virtue of the lack of a dedicated railway station. 3.2.5 The South Warwickshire Issues and Option Consultation identified Southam as one of nine towns within the Local Plan area worth assessing as Broad Locations for future growth. Four Broad Locations were analysed around Southam. Settlement Analysis was undertaken to better understand growth potential in the 9 towns and 21 smaller settlements considered as potential growth locations. 3.2.6 Southam area is also recognised as part of the emerging Local Plan. “Unique Economic Assets” in the named Silicon Spa, part of the gaming industry. This extends from Leamington out to the surrounding areas of Southam and Warwick employing over 2,000 highly skilled people. 4. Southam as a Sustainable Location for Growth 4.1 Planning Policy Designations for Southam 4.1.1 The current Stratford Upon Avon Core Strategy was adopted on 11 July 2016 and includes a proposals map (see section 2.2). There are currently no environmental designations covering any of the land around Southam. 4.1.2 In other areas around the Borough there are environmental constraints including the Cotswold AONB to the south and Green Belt to the north. It is noted that the current Consultation adopts a “policy off” approach to assessing Green Belt and AONB in the context of Growth Options. 4.1.3 It should be recognised that the most significant Local Plan constraint policy for the Borough does relate to Green Belt. The current Core Strategy states that once established, Green Belt boundaries should be altered only in exceptional circumstances. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch, Bromsgrove, Solihull and Warwick. Much of the land within Option 1 and 2 Growth Options would involve the loss of significant areas of Green Belt. 4.1.4 The current extent of the approved Green Belt has been established since 1975 and the Core Strategy states that it still complies with the purposes of including land within it, as now set out in the NPPF. In the last Local Plan the Council states that there are no reasons for extending the area covered by the Green Belt within Stratford-on-Avon District. Likewise, there is no justification for making a significant reduction to the current extent of the approved Green Belt. 4.1.5 Matters relating to Green Belt are referenced in Issue S6 of the current consultation document. St. Modwen would support a Green Belt review to establish capacity within these areas as part of any future review. The review must incorporate development capacity assessments in green belt locations if it is to be successful in balancing the protection of current green belt boundaries with the sustainable development opportunities of non-green belt locations. 4.1.6 For Southam, there are very few acknowledged policy constraints to consider. Only the area to the west of the town ‘Area of Development Restraint’ and ‘HS2 Safeguarded Route” policy constraints apply. 4.2 Landscape and Environmental Designations 4.2.1 Nationally designated areas, including Areas of Outstanding Natural Beauty (AONB), have been confirmed by the Government as having the highest status of protection in relation to landscape and scenic beauty. Development will generally be restricted in these areas. 4.2.2 Southam is also located away from any Special Landscape Area Designations located at Arden, Cotswold Fringe, Feldon Parkland and Ironstone Hills Fringe.4.2.3 To the West of Southam is the Stowe Valley area, designated as an Area of Restraint. These areas make an important contribution to the character of the settlement. Development must not harm or threaten the open nature of such areas, taking into account any possible cumulative effects. Planning permission for a large-scale form of development in an Area of Restraint will only be granted where a scheme would have demonstrable community benefits and contribute significantly to meeting an objective of the Core Strategy. 4.2.4 There were 9 European recognised SAC, SPA and Ramsar sites located within 20 km of Stratford. None of these designated assets identified in the Habitat Impact Assessment were situated to the east of Stratford near to Southam. 4.2.5 The Landscape Sensitivity Analysis was undertaken in July 2011 and the extract is set out below capturing the relative sensitivities to the landscapes around Southam. Based on the above review there are relatively few environmental constraints, sensitive designations or environmental constraint restrictions on future development around Southam beyond the Stowe Valley area to the west of the Town Centre. The landscape evidence suggest less sensitive areas are located to the south and east of Southam.Heritage 4.3.1 There are no designated scheduled ancient monuments, registered battlefields or registered parks and gardens present in Southam. Archaeological studies recognise MWA 4789 as a postmedieval Turnpike Road from Ryton Bridge to Banbury via Southam. 4.3.2 There are 40 listed buildings within Southam. These are detailed in the graphic below. 4.3.3 There are generally no significant heritage assets that would preclude the sensitive and appropriate development of land around Southam. 4.4 Evidence Base – Settlement Analysis 4.4.1 The current consultation documents are supported by Settlement Analysis dated January 23. The document assesses settlement structure, constraints mapping, connectivity and local services mapping. 4.4.2 It is important to note no associated levels of growth or capacity assessment has been conducted. Large scale development provides opportunity to address existing and future impacts and provide adequate mitigation so the study work needs to be assessed within the context of small scale development only, or assessment work amended once overall levels of growth are identified. 4.4.3 Southam is assessed as a second tier settlement and scores well against its peers with the exception of rail accessibility. 4.4.4 The Connections Analysis documents includes reference to 9 assessed areas. The following observations are made: Area 9 fails to assess the edge incorporating the school playing fields which extend significantly into the countryside. For the purposes of edge analysis this should be addressed in any future study;  Areas 7 and 8 are covered by current ‘Area of Development Restraint’ policy. This policy aligns with the evidence base landform analysis which annotated both areas as steeply sloped. Connectivity analysis should take account of topography where this analysis is looking at potential future connections;  Area 6 is now completely bisected by HS2 rail routes which limits potential for larger scale growth and development options. Updated mapping should be used to identify if land parcels in this area are available;  Within the Key of the Connections Analysis diagram it notes Public Rights of Way but not all are shown on the diagram. The Connections Analysis document also looks at access to facilities within 800m. Intelligent referencing should be made to larger scale development options which bring new or enhanced local facilities and connectivity of other facilities such as school, employment related uses and open spaces. 6. The Future for Southam – Conclusions of the Representation 6.1 Southam is a highly sustainable and generally unconstrained location for future housing growth and the significant benefits delivered by new housing growth would be of economic and social benefit to the existing residents of the town and the rural communities that Southam serves. Having reviewed the SWLP evidence base and assessed the Growth Options set out in the current consultation St. Modwen strongly believes that Southam is the right location for significant new development in the new SWLP. 6.2 The evidence base also reviews Broad Locations around Southam. Our review of this evidence and the scoring matrix contained within the Sustainability Appraisal suggest that errors have been made in the Council’s assessment. When these errors (see sections 4.4.4 and 5.5 of this representation) are corrected St. Modwen strongly believe that land to the East of Southam has the highest potential to deliver sustainable and low carbon new communities which meet the future needs of the town. Development of the scale proposed by St. Modwen will also maximise the delivery potential aligned to 20 minute neighbourhood principles. 6.3 The appended vision document also highlights how the proposed development on Land East of Southam aligns with the Strategic Objectives of the SWLP. Specifically, these are:  Addressing Climate Change – Our vision for land East of Southam supports sustainable and net zero carbon ambitions to address climate change effects including through the provision of green and blue infrastructure;  Promoting wellbeing – Our vision for land East of Southam will deliver on site provision of health and education facilities, along with affordable housing which St. Modwen agree is critical to the success of achieving sustainable communities. Our proposals promote healthy, inclusive and safe places and include the provision of pedestrian and cycle connections within and between neighbourhoods, high quality public space, safe and accessible green infrastructure, sport and recreation facilities, local shops, meeting places, access to healthier food and allotments.  Improving connectivity – Our vision for land East of Southam will provide for appropriate transport infrastructure and consider the opportunities from existing or proposed transport infrastructure particularly those in relation to walking, cycling and public transport.  Increasing biodiversity – Our vision for land East of Southam includes green and blue Infrastructure providing multiple benefits to existing and new residents of the town. These spaces will create and enhance habitats and biodiversity rich places securing measurable net gains for the development.  Creating well-designed and beautiful places – Our vision for land East of Southam will be focused on design quality relating to individual buildings and the spaces and places between them including the potential for public art. St. Modwen acknowledge that a ‘policy off’ position has been taken to assessing Broad Location and New Settlements and this includes only limited Green Belt considerations. St. Modwen believes that when an assessment of the appropriateness of large scale new development in the Green Belt is undertaken, that policy unconstrained locations such as Southam should be given higher weighting as a suitable location for major growth. A Green Belt review should be prioritised ahead of any further growth strategy work to ensure that future assessment work considers all significant issues. 6.5 St. Modwen strongly agrees that any preferred Growth Strategy needs to factor in the impact of new development on the Green Belt. 6.6 On Issue H4 we believe there is further consideration of sub regional and regional housing growth. St. Modwen support the need to define the level of additional housing to allow the SWLP to proceed. 6.7 On Issue H1, St. Modwen supports the use of evidence on affordability and housing need to ensure that SWLP delivers mixed tenure development that reduces the affordability crisis, giving access to suitable housing accommodation for all existing and future residents. 6.8 A St. Modwen would highlight the following key SWLP consultation responses as they relate to directing growth to Southam.  On Issue V1 – Vision for the Local Plan St. Modwen fully support the ambitions set out in the SWLP Vision Statement.  On Issue V3 – Strategic Objectives St. Modwen supports the Strategic Objectives.  On Issue S4 - Growth of existing settlements St. Modwen strongly support the need for sustainable urban extensions to meet the future growth needs of the SWLP as part of a balanced overall growth strategy. St. Modwen would highlight the following SWLP consultation response as they relate to Land East of Southam:  On Issue I1 – Sustainability Appraisal St. Modwen questions to the conclusions of the Sustainability Appraisal for Southam. Errors have been made in the evidence base that need correcting as the SE Broad Location is the most sustainable location as supported by Table 4.1 of the Councils Sustainability Assessment.  On Issue I5 – Viability and Deliverability St. Modwen strongly feel that viability and deliverability are key to achieving a successful SWLP and that land East of Southam will deliver if allocated in the Local Plan.  On Issue T1 - 20-minute neighbourhoods St. Modwen supports the principle of the 20-minute neighbourhoods as a design principle. This can be delivered through comprehensive growth strategies that provide service and facilities as part of new development.

Yes

Issue V1 – Vision for the Local Plan St. Modwen fully support the ambitions set out in the SWLP Vision Statement. 5.2.2 The plan period to 2050 is considered to be ambitious and acknowledges that a number of Local Plan reviews will be required in accordance with NPPF para 33 which states “policies in local plans and spatial development strategies should be reviewed to assess whether they need updating at least once every five years, and should then be updated as necessary”. Notwithstanding these periodic reviews the need for co-ordinated and long term thinking related to spatial planning matters is very positive. 5.2.3 St. Modwen also support the 5 overarching principles and believes the promotion of land East of Southam development provides an ideal opportunity to deliver in line with the proposed principles and vision for the SWLP. Issue V2 – Vision for Places 5.3.1 St. Modwen notes that Vision for Places is to be moved to other Development Plan Documents. St. Modwen broadly supports the Vision For Places subject to other strategic policies setting clear ambitions for the distribution of new growth aligned with appropriate policy parameters including Green Belt setting out how any distribution links to the overall vision of the SWLP and that the scope of distribution and levels of growth is grounded in good evidence based information. 5.3.2 St. Modwen also supports the preparation of SWLP documents with a view to speeding up the overall allocating and consenting process. Consideration needs to be given to the LDS and publication dates for part 1 and part 2 of the local plan. For applications consideration should be given to inviting early applications and the potential use of Local Development Orders where these are considered appropriate. Issue V3 – Strategic Objectives 5.4.1 St. Modwen supports the Strategic Objectives. Further clarity could be provided through linking new development to enhancing the economy and supporting established local retail centres. Refence to the impact of Covid should be assessed in the context of a 30 year plan period with adoption in 2025 at the earliest. It is not clear that Covid has had any direct specific impacts that would be classified as strategic in nature. St. Modwen agree that the role of Local Centres needs to be assessed and combined with local ambitions linked to the transformation potential of supporting large scale growth. Our ambitions for a 2000 new dwelling urban extension on land east of Southam provides unrivalled opportunity to enhance and support the town centre and ensure that accessibility and town centre sustainability are at the heart of Southam’s role in the SWLP. 5.4.3 St. Modwen fully support that the infrastructure needed to support the growth in new homes and jobs is secured through new development. Our vision for Land East of Southam sees significant green space infrastructure, local primary school provision and sustainable transport links as early infrastructure improvement opportunities serving new residents and existing communities in the town. 5.4.4 St. Modwen strongly supports that every opportunity is taken to reduce existing carbon emissions and mitigate against climate harms. St. Modwen’s vision for land East of Southam could accommodate net zero cardon ambitions and embraces a holistic and integrated approach to climate change that meets the need of future residents. 5.4.5 St. Modwen fully support the strategic objective to create attractive places, protect and enhance our heritage and cultural assets, improve access to sustainable and active travel options and protect and enhance environmental assets. Having assessed land East of Southam against these criteria we are confident that this location represents a good location for growth and would align with the proposed strategic objectives.

St. Modwen acknowledge and support the Sustainability Appraisal of the identified Broad Locations. We acknowledge that Southam is included in the 9 Broad Location settlement and that these have been identified to be capable of delivering up to 2,000 homes and significant areas of greenspace to facilitate effective green infrastructure planning. We support Southam as a highly sustainable location for future housing growth. 5.5.2 Overall Southam scores very well in the Sustainability Appraisal as a preferred town or location for growth and when compared to the 9 Key Towns should be seen as a preferential location for significant new housing. When considering the Broad Locations we believe that in line with St. Modwen’s Vision Document (appended) that the South East direction of growth for Southam should be considered the preferred location for new housing in Southam. 5.5.3 It is also important to ensure that appraisal relating to accessibility in the sustainability appraisal take account of new facilities such as the proposed new Aldi food store when assessing proximity to services. The new store sits adjacent to the Southeast Broad Location of development assessed by the SA. Committed development should be factored into the evidence base to ensure a fair assessment is undertaken. St. Modwen raises inaccuracies in the conclusions of the Sustainability Appraisal for Southam which appear to conclude (ref page 79 section 4.13) that Southam SouthWest is the most sustainable location for growth. 5.5.5 The following key factors appear to have been assessed and a recording error made. Para 4.11.9 (see below) clearly states that SW are within high/medium and high sensitivity land parcels that will be challenging to mitigate. We agree with this assessment but the conclusion in 4.13 records in error that the SW performs best in this category. The correct 4.13 annotation should have read “BEST PERFORMING BL: SOUTHAM SOUTHEAST”. If the above landscape scoring is corrected on the page 79 summary (table 4.13.1) and a sensible approach taken to onsite infrastructure set out in our vision document including enhanced public transport facilitating the 20 minute Neighbourhood principles, local facilities enhancement, employment land and the provision of a new primary school, the findings of any balance appraisal would clearly support development on land to the South East of Southam as the preferred Broad Location. 5.5.7 St. Modwen would also highlight within the SA report (Figure 4.3) shows that of all Southam options ‘Southam Southeast’ is the least impacted location across the SWLP area relating to the impact on priority habitats. 5.5.8 St. Modwen would also flag the Agricultural Land Classification data collected for Broad Location which shows Southam Southeast has no Grade 2 land and that Southam generally is Grade 3 land when compared to other Broad Locations. The above extract taken from the Table 4.1 of the Sustainability Appraisal shows that of all Southam option ‘Southam Southeast” scores the best from a Sustainability perspective. St. Modwen fully agree with this finding.

Issue I2 – Infrastructure Delivery 5.6.1 St. Modwen acknowledge that the most common concerns relating to infrastructure in South Warwickshire relate to transport, utilities, education, green infrastructure and health facilities. 5.6.2 St. Modwen are confident that the proposals set out in our Vision Document for Southeast Southam align with the 5 Strategic Objectives of the SWLP. These are:  Addressing Climate Change – Our vision for land East of Southam supports sustainable and net zero carbon ambitions to address climate change effects including through the provision of green and blue infrastructure and through delivery of the 20 minute neighbourhood;  Promoting wellbeing – Our vision for land East of Southam is capable of delivering on site provision of health and education facilities, along with affordable housing which St. Modwen agree is critical to the success of achieving sustainable communities. Our proposals promote healthy, inclusive and safe places and include the provision of pedestrian and cycle connections within and between neighbourhoods, high quality public space, safe and accessible green infrastructure, sport and recreation facilities, local shops, meeting places, access to healthier food and allotments.  Improving connectivity – Our vision for land East of Southam will provide for appropriate transport infrastructure and consider the opportunities from existing or proposed transport infrastructure particularly those in relation to walking, cycling and public transport. The development would adhere to the principles of the 20 minute neighbourhood.  Increasing biodiversity – Our vision for land East of Southam includes green and blue infrastructure providing multiple benefits to existing and new residents of the town. These spaces will create and enhance habitats and biodiversity rich places securing measurable net gains for the development.  Creating well-designed and beautiful places – Our vision for land East of Southam will be focused on design quality relating to individual buildings and the spaces and places between them including the potential for public art. 5.6.3 St. Modwen strongly believe that development on Land to the East of Southam maximises the chance of ensuring infrastructure delivers services the new residents and the existing residents of the town need. 5.6.4 It is also important to plan properly for infrastructure requirements across the SWLP area. Identifying impacts and mitigation linked to growth scenarios is critical if development is going to be delivered viably and in accordance with the principles of the Local Plan. Infrastructure evidence will form a key part of the Councils evidence base and should be assessed ahead of and not after key Growth Options analysis is completed. CIL requirements can then be assessed based on an appropriate growth scenario. Issue I5 – Viability and Deliverability 5.7.1 St. Modwen strongly feel that viability and deliverability are key to achieving a successful SWLP. The land being promoted as part of the appended Vision Document is within one land owners control being promoted with one master developer, St. Modwen, promoting and delivering the site. The land to the Southeast of Southam is therefore available in accordance with Para 68 NPPF terms which notes that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. 5.7.2 We would also highlight that land to the Southeast of Southam should be considered fully deliverable under NPPF definitions as meaningful development would occur within 5 years of the sites allocation in the SWLP. St. Modwen would be fully prepared to submit a Statement of Common Ground in support of collaborative working to ensure applications are submitted that support the Council’s vision for development in Southam. St. Modwen want to work with the SWLP team to ensure that Land East of Southam can be delivered quickly and in accordance with the emerging policies in the Local Plan. This would include viability assessment based work showing that Land East of Southam is a highly deliverable development solution for the SWLP.

Issue S1 – Green and Blue Corridors 5.8.1 St. Modwen fully support the integration of green and blue infrastructure within large scale growth options. Our vision for Land East of Southam provides a new country park and extensive spaces for blue and green infrastructure that will significantly enhance ecology, biodiversity and access to semi natural spaces for future and existing residents of Southam. The development will feature the planting of street trees, creating parks, providing private gardens, allotments, sustainable urban drainage systems, wildlife areas, woodlands, natural flood management schemes and hedgerows. 5.8.2 We would also raise the evidence base requirements for New Strategic Nature Corridors and the need to understand the requirements of these objectives before significant decisions are taken on future Growth Options. A detailed plan for nature corridors would ensure all factors relating to growth decision were known. Issue S4 - Growth of existing settlements 5.9.1 St. Modwen strongly support the need for sustainable urban extensions to meet the future growth needs of the SWLP. Towns like Southam provide varying levels of services and facilities to meet the needs of the people who live or work in and around them. Planning growth of a strategic scale allows key facilities and services to be provided to enhance the life of existing and new residents. It also allows ambitions such as the 20 minute neighbourhood to be embedded in new design and master planning ambitions. 5.9.2 Southam’s baseline assessment fully supports future growth for the town without significant environmental, greenbelt policy or landscape impacts. Southam remains a highly sustainable location for future housing growth. 5.9.3 St. Modwen notes the connectivity, accessibility and density analysis undertaken by the Council and would support further robust and detailed analysis of growth options. For Southam, an assessment to date of Broad Locations for up to 2000 new homes, mix of uses and associated infrastructure suggests that the South East arc offers the most beneficial direction for growth. St. Modwen believe a more detailed and robust assessment of options including our proposed vision for land East of Southam would highlight key opportunities to maximise the potential delivery in line with the Strategic Objectives of the SWLP. Issue S6: A review of Green Belt boundaries 5.10.1 St. Modwen strongly agrees that any preferred Growth Strategy needs to factor in the impact of new development on the Green Belt. To date the ‘policy off’ approach and consultation on the potential for a future Green Belt review have deferred key decisions on the overall spatial strategy for the SWLP. It is clear that Option 1 Rail Corridors and Option 2 Sustainable Transport both favour significant loss of Green Belt land. 5.10.2 We note that an initial very high-level initial assessment of Green Belt was undertaken for the New Settlement identification. St. Modwen support an early comprehensive review of the Green Belt to establish the impact of proposed New Towns and smaller settlement extensions on the NPPF Para 139 ‘5 purposes of Green Belt’. The findings of this technical analysis then need to be assessed against the relative impacts on all Growth Options with a suitable weighting applied to land that has negative impacts when measured against the national and local Green Belt policy.

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Issue H4 – Accommodating Housing Needs Arising Outside of South Warwickshire 5.14.1 St. Modwen support the need to define the level of additional housing to allow the SWLP to proceed. Whilst the HEDNA looks at the Coventry and Warwickshire HMA area there is a significant under supply of 78,415 homes in the Birmingham City Council area that needs to be accommodated across the HMA. There is also additional under delivery in the Black Country area as well. 5.14.2 The only effective solution is for the SWLP Team to agree an acceptable contribution to this under delivery in the wider HMA areas. Failure to agree a position on accommodating additional housing risks significant future delays in any plan making process.

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Issue H1: Providing the right number of new homes 5.12.1 St. Modwen supports the use of evidence on affordability and housing need to ensure that SWLP delivers mixed tenure development that reduces the affordability crisis, giving access to suitable housing accommodation for all existing and future residents. 5.12.2 The use of base date projections data is necessary when assessing the future quantum of housing across a plan period, especially a plan period extended out to cover an extended period to 2050. St. Modwen would support an affordability based assessment approach where policies relating to housing need are reviewed regularly and where the aim is to maintain or improve affordability within the area. 5.12.3 The SWLP housing figure should also factor in any need from Greater Birmingham & the Black Country and from Coventry. The only way this can be done is if all authorities within the Greater West Midlands area collaborate to ensure fair and appropriate re-distribution occurs. It is our experience that this level of integrated collaborative working across authorities has not, and is not, likely to result in a consensus view of how to accommodate City overspill. 5.12.4 Given the challenges in meeting sub regional and regional overspill we would support the Council proceeding with the current levels of housing and economic growth in the SWLP as informed by the HEDNA as a minimum with additional focus being placed on maintaining or improving affordability and how to address neighbouring unmet need. Issue H3 - Providing the right size of homes 5.13.1 St. Modwen objects to the use of Table 12 page 107 HEDNA based housing mix for larger Broad Locations or New Settlement Developments. Careful consideration is needed to the approach taken on housing mix when considering different types of development. For instance, urban infill site in established towns should be viewed differently to the proposed housing mix for New Settlements. The proposed delivery of only 10% of 4+ bedroom homes on the viability and deliverability of New Towns or 2000 dwelling Broad Locations needs to be tested alongside the social policy objectives linked to balanced communities and the provision of housing for older segments of the population. Flexibility in mix is advocated in the HEDNA and we would agree with including flexibility in the SWLP on mix for large sites. 5.13.2 Consideration also needs to be given to providing smaller mix sized properties that may appeal to downsizers. Under occupancy in the HEDNA study area has been identified as a significant with over 200,000 properties currently with 1 or 2 spare bedrooms.

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Issue D1 – Strategic Design Principles 5.15.1 St. Modwen support the introduction of a policy relating to strategic design principles. Our vision for land to the East of Southam is founded upon design principles linked to a comprehensive development approach, creating a pleasant environment to live and work that related and integrates with its surroundings. We also agree that development should be distinctive and build upon the unique characteristics of its surroundings creating a positive sense of place. 5.15.2 St. Modwen’s vision for land to the east of Southam focuses on connectiveness to existing town services and facilities whilst providing on site facilities to the benefit of existing and new residents. The development is also proposed to be landscape led with environmental sustainability and net zero carbon ambitions at the heart of the vision. Issue D2 – Design Codes and design guides 5.16.1 St. Modwen support the use of design guides and/or design codes where the spatial strategy identifies significant change. Careful consideration needs to be given to the time taken in Local Plan making and application processing to ensure that the process of agreeing design guides does not materially impact on the speed of housing delivery. Policy provision should require the need to provide design guides or codes as part of applications and the Council policy position should support the timely review and approval of such codes. Issue D4 – Safe and attractive streets and public spaces 5.16.1 St. Modwen support the use of appropriate range of topics for a policy on the design of safe and attractive streets. Clarity is required as to the acceptable adoptable standards for new highways where the developer and authority seek to agree the use of street trees. The specific adoptions process will need to be agreed and Warwickshire County Highways team agree to the provision of street trees as part of a SWLP policy as without their endorsement then the implementation of this policy will be problematic.