Issue and Options 2023
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New search2.1 Response: It is noted that the SA in the conclusion for the Sustainability Appraisal states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ [emphasis added] 2.2 As the Issue and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and not mitigation has not been considered.
2.3 Response: It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.’ [emphasis added] 2.4 Therefore, albeit referring to capacity for housing land, the Council(s) evidence base clearly demonstrates the need for the release of greenfield land.
2.5 Response: The Strategy should provide a wide range of employment opportunities in accessible locations. Moreover, the Strategy needs to respond to the needs of businesses. 2.6 The National Planning Policy Framework 2021 (paragraph 8) states that the economic objective for achieving sustainable development requires the planning system to ensure that ‘sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity.’ 2.7 The Local Plan should indeed support the growth of new industries/sectors as part of a portfolio approach to supporting economic growth within the Districts. In so far as there is some level of balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. As such, the Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment sites are either not suitable or not available to meet employment requirements. 2.8 Sustainable locations should be considered for employment, for example adjacent to existing employment locations and adjacent to main towns including Stratford-upon-Avon Council. In so far as the majority of employment opportunities are located within and adjoining the main towns of both Districts, these settlements should be the focus for new employment locations that are needed.
2.10 Response: The Bird Group does not object to the consideration of new settlements as part of the Council’s Growth Option. 2.11 A range of sites varying in scale and size should be explored in order to secure the delivery of new developments. The expansion of existing settlements and new settlements allocated in the Local Plan should also be explored further to see whether there is capacity to be extend these further.
All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-upon-Avon and Warwick Districts.
2.30 Response: In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.31 It is evident that some allocations in the current development plan have failed to deliver new employment development. The availability of such sites to contribute to the supply of employment land opportunities should be reviewed. No purpose is served in allocating land for employment development where the land is not then brought forward into development. The effective supply of industrial land is then over-estimated, which frustrates new investment and jobs. it would be inappropriate to envisage that existing employment sites are capable of producing new sources of land for investment. The joint Plan must allocate new land for employment development on the urban edge of the main settlements. The land must be suitable and attractive for new inward investment. 2.32 In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.33 A criteria based policy would be appropriate to establish the need and suitability of additional land to meet employment needs.
