Issue and Options 2023

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Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? It is important to have in mind that South Warwickshire is to grow and evolve in the plan period to 2050. Change is inevitable, and the planning process functions to support sustainable growth and should not be applied to stymie or otherwise place unnecessary obstacles in the way of new development. Thus, tackling the climate emergency cannot be at the expense of delivering new housing, employment and retail and other space. We consider that the Vision has been modified to better reflect this important principle, and one of the six Strategic Objectives now relates to meeting sustainable development needs. This is welcomed and reflects our earlier submissions. However, we consider that this should be further amended to make clear that development needs must be met in any event, and that it is for the plan to set out how this is achieved sustainably.

The SA prepared to support the Issues and Options explores reasonable options in relation to: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. • 116 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. Each option has been assessed/scored against each of the 13 SA objectives in relation to 1. climate change; 2. flood risk; 3. biodiversity and geodiversity; 4. landscape; 5. cultural heritage; 6. pollution; 7. natural resources; 8. waste; 9. housing; 10. health; 11. transport; 12. education and 13. economy. The comments below relate first of all to the housing numbers and then to the growth options and broad locations around main settlements. Housing numbers Two reasonable alternatives to establishing housing number calculations have been undertaken. Option 1 – the HEDNA trend- based projections which point to a need for 868 dwellings per annum in Stratfordon-Avon and 811 dwellings per annum in Warwick – total of 1,679 dwellings per annum. Option 2 – uses the Standard Method and identifies the need of 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum in Warwick – total of 1,239 dwellings per annum. It is reported within the SA that using the HEDNA figure would more accurately represent local housing need and would better meet the needs of the various members of the community (including affordable homes, student accommodation, older people’s accommodation, specialist housing and custom and self-build plus gypsy and traveller and travelling show people communities). Both options have a similar negative impact on climate change, biodiversity, pollution, natural resources and potentially waste. Option 1 would likely have a greater adverse impact on landscape and townscape character due to higher housing numbers. Both options have a similar minor positive impact on 11 – transport, by the location of new housing in closer proximity to workplaces. The consideration of housing numbers does not provide any locational information and so the impacts in relation to climate change, cultural heritage, health, education is uncertain.Whilst overall, at this stage option 2 appears to perform better overall, we would support the use of the higher HEDNA figure which will allow flexibility within the overall development strategy. This will enable the plan to accommodate a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry. Growth options As set out in the SA, scores each option against the SA objective, which indicates that each option is likely to perform better than others. All perform positively in relation to employment and housing and so, at this stage, no stage should be ruled out in our view. The broad locations for proposed new development have also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratford-upon-Avon and Warwick. These locations were further analysed to test distances from GP surgeries, schools, public transport etc, to remove land within flood zones 2 or 3, AONB, Grade 1 agricultural land, scheduled monuments, SSSI, Registered Parks and Gardens and Ancient Woodland. These broad locations all perform similarly against the SA objectives and at this stage, we would consider it too early to discount any broad locations without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. The same principle is considered appropriate in terms of reasonable alternatives put forward in relation to small settlement locations. Early indications within the SA consideration in relation to New Settlements suggest that this growth option would perform poorly against climate change overall and waste, use of natural resources and landscape; some performing poorly against flood risk, pollution, health, education and biodiversity and local wildlife sites. Whilst this option would achieve up to 6,000 dwellings, thereby resulting in a significant contribution towards meeting the housing need, and seen as being a major positive impact on housing provision, these large-scale developments invariably take years to come to fruition, requiring major investment in all types of infrastructure before housing can come forward. Numerous local plans relying on this type of option have failed. This option, in our opinion therefore is the least favoured and potentially should be ruled out at this stage.

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Q-I4.1 Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes, in part. We consider that it is appropriate for a policy to safeguard specific infrastructure schemes within the SWLP, where those infrastructure schemes have been evidenced through the plan making process. Where infrastructure schemes have not been evidenced, it would be inappropriate for the plan to specify and safeguard such schemes, since these would not be justified having regard to the tests of soundness embedded in the NPPF. Where specific infrastructure schemes are safeguarded, the policy must be sufficiently flexible to be adaptable to changing circumstances. For example, one such infrastructure scheme which may be safeguarded is the improvement of the A46 at Bishopton and Wildmoor junctions. We are aware that scheme proposals for junction improvements are evolving, and the land take required may change over time. Where a plan showing the extent of safeguarding is embedded in the SWLP it should be made clear that the precise extent of safeguarding may change (either extending or shrinking) due to changing circumstances.

Issue I2 Infrastructure Requirements and Delivery Q12a: This option, to set out infrastructure for all scales, types and location of development within Part 1 of the Local Plan is considered is preferred. This would allow the requirements to be applied equally across the District and provide developers with more certainty when coming to consider implications for proposed development/proposed sites across both Stratford and Warwick. Issue I3 CIL Q-13a: This option for CIL is preferred, which would set a single levy for the whole of South Warwickshire. This would give developers greater certainty regarding likely development costs.

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Issue I5 Green and Blue Corridors Q-S1 – Option S1a We consider that the SWLP should identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. However, this should be based upon proportionate evidence, which must be up to date. The SWLP refers to the Warwickshire Coventry and Solihull Sub regional green infrastructure study being used to inform policies, however this study dates back to 2013, and is therefore some 10 years old. This should be updated if it is to be used for the purposes of policy making, and included in the forthcoming suite of additional evidence base documents which can be commented upon as part of the plan making process in Stratford and Warwick. Issue S2: Intensification Please select all options appropriate Option S2c – Do not have a policy which encourages intensification. Each site should be considered on its own merits to take account of site-specific constraints and opportunities. A blanket approach to a policy with an ‘in principle ‘support for intensification or even the identification of sites which are considered to be particularly suitable could be counterproductive. Whilst it is acknowledged that the current Framework promotes the effective use of land in meeting the needs for homes, this should not be at the expense of healthy living spaces, or, as advised in footnote 47, “except where this would conflict with other policies in the Framework.” Any proposed intensification, per se could run contrary to the achievement of “well-designed or beautiful places” advocated by the Framework, which places great emphasis on “the creation of high quality, beautiful and sustainable buildings and places”. Furthermore, we are concerned that higher anticipated yields from such sites resulting from an intensification policy approach could result in the allocation of fewer sustainable green field sites – which could ultimately result in failure of the plan to deliver its requirement over the plan period because of the reliance on the yield from the intensification of the site, which may, in due course not be supported due to adverse impact on living conditions for future occupiers or character/appearance reasons and so on. Issue S3 Using Brownfield Land for development Q-S3.1-Option S3.2c We do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars to sustainably and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function. Q-S5.3 Do you think new settlements should be part of the overall strategy? No. We are of the view that new settlements should not be part of the overall strategy for the following reasons; • Due to the level of infrastructure required, new settlements can take years to come forward before housing can be delivered. This can seriously jeopordise the ability of the local plan to deliver both open market and affordable homes across the District for which there is a critical need. A study by Lichfields entitled “Start to Finish” (2016) highlights the problems associated with large scale development and compares them against delivery times for smaller developments. It highlights several examples of new settlements (2,000-3000 dwellings at Cambridge University). On average it took 10 years for the final schemes to be approved following allocation in the Local Plan (following outline and various reserved matters applications). The report did not go on to consider discharge of conditions applications/variations which actually may also delay the ability deliver the approved dwellings. This compares to smaller scale schemes which on average took 8 years. • The report states that large sites, which are not likely to deliver quickly are also unlikely to be contributing to five year housing land supply calculations. The strategy should include small and medium sites which the Framework acknowledges can make an important contribution to meeting the housing requirement. • The reliance of new settlements within the strategy will also result in an inherently inflexible plan – which relies on the delivery of fewer but larger sites with multiple land owners. Coming to agreement over land value and sequencing of delivery are likely to be other factors which can delay the scheme which ultimately may result in developers having to contribute more to the infrastructure (drainage/highways etc) which will impact on viability, potentially at the expense of affordable housing provision. • It for these reasons that several plans relying on large new settlements have failed – Uttlesford DC withdrew their plan due to the Inspector not being persuaded that evidence demonstrate the Garden Communities and overall spatial strategy had been justified. North Essex had similar problems with their proposed Garden Communities, which had to be removed from the Joint Local Plan before the Inspector found the Plan sound. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold development approach is appropriate, to allow more small-scale developments to come forward? Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap. Issue S9: Settlement Boundaries and infill development Q-S9 – It is our preference for Part 1 of the Plan to review and define all settlement boundaries across the combined district. This would achieve a consistent approach and allow smaller settlements to take more proportionate growth to enhance the vitality of rural communities.