Issue and Options 2023
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Q-C8: Please select the option which is most appropriate for South Warwickshire Option C.8b – Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events. Building regulations requirements are updated and enforced separately from planning policies and may change a number of times during the anticipated plan period, often with transitional arrangements where necessary. This ensures the development industry is able to take account and adapt to these requirements.
These are detailed matters for consideration under the Part 2 Plan, rather than strategic matters for consideration through Part 1. In relation to strategic allocations, these matters can be considered on a site by site basis through strategic allocation policies.
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The most appropriate option is considered to be D3a which includes a policy underlying the importance of density, but does not identify an appropriate minimum density or range of densities across South Warwickshire. It is important that densities are considered on a site by site basis, relative to their context. It may also be appropriate to consider different densities across a single site.
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Q-W2: Please select the option which is most appropriate for South Warwickshire Option W2a: Include a policy on Health Impact Assessments We agree that it would be beneficial to capture the cumulative health impacts on major developments, however, we would welcome the proportionate requirement for Health Impact Assessments, rather than a blanket requirement for submission of a Health Impact Assessment as part of all major planning applications.
Section 1.3 of the Issues and Options Consultation Document states: “Once Part 1 is fully adopted, it will replace the existing strategic policies of the Stratford -on-Avon District Council Core Strategy and Warwick District Councils Local Plan.” Paragraph 20 of the NPPF defines strategic policies as: “Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision13 for: a) housing (including affordable housing), employment, retail, leisure and other commercial development; b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat); c) community facilities (such as health, education and cultural in frastructure); and d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.” In respect of non-strategic policies, Paragraph 28 of the NPPF states that they can include “the provision of infrastructure and community facilities at a local level, establishing design principles, conserving and enhancing the natural and historic environment and sett ing out other development management policies.” A significant amount of the issues identified within the Issues and Options consultation are detailed Development Management matters such as design-led issues which are not, by definition, strategic issues. Given the purpose of the Local Plan Part 1 and the NPPF definitions detailed above, it is not considered appropriate for these matters to be considered through the Part 1 process. Rather, they should be reserved for the Local Plan Part 2.
As detailed above, it is considered that some of the policies proposed as part of the Issues and Options consultation document go beyond the scope of the Part 1 Plan. The policies proposed should be reviewed to ensure that detailed Development Management policies such as those referring to space standards (see Q-H3) and design (see Q-D1.2) are removed and included as part of the Part 2 Plan process.
