Issue and Options 2023
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New searchQ-I2: The County Council favours Option 12a. We believe that this gives greater clarity over requirements at the earliest stage. It will support potential developers to understand the implications of growth within a specific area and help avoid conflict with infrastructure providers. Q-I3: The ability to charge differing rates across the individual District Council areas is already dealt with in the two existing separate CIL strategies. WCC considers that a single CIL would bring considerable benefits and as such would support such an approach. However, WCC also recognises some of the challenges of this approach and will seek to work with both Districts whatever the outcome. Currently the District Council’s CIL approaches differ and as a minimum we would suggest that the application and monitoring processes should align. This would require a clearly agreed timetable and a shared set of paperwork. As a key Infrastructure provider and an organisation who actively bids for CIL funding the key issue is consistency of approach for determining funding allocation, monitoring spend etc. We also feel that there must be a mechanism whereby funds can be made available across the Local Plan area to help support the delivery of key infrastructure required because of cumulative impact. Q-I5: Under Infrastructure Delivery (Chapter 4, 4.1, Issues I2) a list of 3 ways for infrastructure to support new development is provided along with supporting/explanatory text. No. 3 states ‘off-site through the provision of financial developer contributions to pay for the provision of infrastructure to be provided elsewhere – e.g. education, health facilities, biodiversity restoration’. We have concerns that this suggests that this is the only way that off-site infrastructure can be delivered. We believe that this point and the explanatory text should be amended to also make reference to the delivery of transport and highway improvements via a section 278 highway agreement. For many large off-site transport improvements, the delivery generally relies on either s106 contributions or s278 highway agreements or a combination. This is often because the infrastructure costs are too large to be borne by a single development parcel and would have implications for the viability of development. This means that infrastructure delivery is reliant on developers submitting planning applications for the allocated sites in a timely and coordinated manner, all of the s106 contributions need to be received (often from different development sites or phased parcels within those sites), or s278 applications made, in order for the infrastructure to be designed, technically approved and constructed on-site to dovetail with the identified development occupancy trigger(s). If infrastructure is to be delivered at the right time, then the infrastructure delivery mechanisms/processes need to reflect the overall programme for the delivery of the infrastructure and require the design work, which is often complex, to be carried out sufficiently early so that the on-site construction period dovetails with the build out/occupancy rates of development. Recommend that for this strategic objective and particularly for large scale infrastructure delivery, there should be a mechanism to plan and monitor the overall programme for delivery, including design and construction stages, and to identify risks. The further assessment as part of the Housing and Economic Land Availability Assessment (HELAA), Infrastructure Delivery Strategy and viability assessments will be important to determine the deliverability of infrastructure. However, there are many elements for transport and highways schemes that are unknowns until the detailed design stage and these can make a scheme undeliverable, e.g. costs associated with diversion/protection works for statutory undertakers’ equipment, requirement for structures, ground conditions etc., by which time development and even occupation has started. Either more information should be provided by land promoters as part of the viability assessment work during the Local Plan review, or robust contingencies should be incorporated into the assessments.
Q-I4.1: If proposed growth can only come forward with the provision of key infrastructure which will require land, it would seem appropriate for this to be safeguarded within the Local Plan. We would expect areas required safeguarding to become apparent at the next stage of consultation when we will consider in more detail specific potential development locations and growth size. Q-I4.2: With reference to Emerging Site Allocations Plan and the A46 Safeguarding we ask if the Marraway junction should also be included or have National Highways confirmed that no improvement at this location would require land to be safeguarded? Although we recognise that the Plan is still at a relatively early stage of development, we would like to note that there may be a number of future transport schemes which would benefit from safeguarding within the Local Plan to ensure these opportunities are not lost as a result of growth. Examples include the potential for a new rail station/interchange/park and ride to serve the University of Warwick (also known as ‘Coventry South’), the preferred route of the A46 Link Road and the Stoneleigh Business Park Strategic Access Improvements. We understand that Midlands Connect will be making a similar submission regarding the future doubling of the Leamington Spa to Coventry rail line, which we also strongly support.
Q-S2: It would seem appropraite to consider intensification, but this will be limited to those areas where adequate mitigation can be provided. Option S2a seems the most appropriate approach. Q-S4.1: Growth of existing settlements should form part of the identification of sustainable and deliverable growth but a general policy on supporting growth of existing settlements could be problematic. It is recognised that growth in some areas could prove beneficial if it brings improvements to services. However growing existing settlements should only be considered where impact can be adequately mitigated. Growth in some smaller villages could help with the delivery of affordable homes encouraging younger families to move to the area. However, these small villages are often without education or health provision and public transport can be patchy. Large scale growth within one location can provide an opportunity to deliver new social infrastructure such as schools, health provision, green space etc. and active travel options can be planned in. Although this can be challenging, especially in those situations where the proposed growth area is made up of a variety of land parcels under separate ownership, we do believe there are examples of good practice within Warwickshire that could help inform the South Warwickshire Local Plan. Q-S5.2: We believe that the delivery of new settlements will provide an opportunity to develop sustainable neighbourhoods. The settlements to be of sufficient size that they will deliver social infrastructure such as education and health facilities as well as available green space and employment provision. Q-S8.1: Although on the face of it this could be a sensible way forward, this would need to be carefully considered and monitored to ensure this didn’t simply become a mechanism for generic dispersed growth and the difficulties this can cause. Thresholds would need to be agreed by the Local Community and reflected in the corresponding Neighbourhood Development Plans. Q-S8.2: The threshold size and how this will be delivered could be different for each community, but it should align with the corresponding neighbourhood plan. Q-S9: It would seem appropriate to reconsider this at the next stage of consultation.
