Issue and Options 2023

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Q-T1: In an ideal world all those people who want to, should be able to access a range of local services and facilities – a shop, a pub, a school, a bus or train and employment opportunities – within 10 minutes. In reality very few people in the South Warwickshire Area can do this, and there is little which can be done to improve the situation. At present some 45% of the population in Stratford upon Avon District live in the rural south and east (Inspectors Interim Report, March 2015). Almost all of these live more than 10 minutes from local facilities. A large number of those living in the Main Rural Centres also live more than 10 minutes walk from key services because settlements have not grown out evenly from an obvious ‘centre’, and no longer benefit from local shops in residential areas. In Warwick District the same is true, although it is less pronounced as more people live in the urban areas. In other responses to this Paper Stansgate clients have supported a dispersed approach to the distribution of development, with market and affordable housing directed towards a wide range of settlements to support both the housing needs arising from those settlements and also to support the settlements themselves. Just because the 20 minute neighbourhood cannot be achieved does not mean these areas are not suitable for development. It is unrealistic to seek development in accordance with the 20 minute neighbourhoods in rural south Warwickshire and as such Stansgate clients would support Option T1a: Include no policy on the principles of the 20-minute neighbourhood for new development.

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Q-E4.2: Stansgate prefers Option E4.2a: Include a policy supporting small-scale employment opportunities in rural areas for the reasons given in the consultation paper. It will encourage the growth of small scale businesses in rural areas, support local communities, and reduce the need for many to travel. Q-E7.1: Stansgate prefers Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. The creation of a Core Opportunity Area may have a negative effect, taking potential businesses away from the District. Potential employers may see the policy as preventing economic development elsewhere, and it may unnecessarily raise land value in the Core Opportunity Area making it less affordable to smaller occupiers. Current employment policies are generally seen as successful but there needs to be more support for employment opportunities in rural areas which could cut commuting distances. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.

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The affordability gap in both Stratford and Warwick Districts is acknowledged to be substantial, with a particular need in the more rural areas. The issue of people being offered homes away from their communities is also a substantial problem, in communities where money to travel is limited. The only obvious way to boost the supply of affordable housing is to boost the supply of market housing and require affordable housing as part of proposals. There should be strong support for a dispersed pattern of development to ensure affordable housing is provided in all parts of the South Warwickshire area, including in the Green Belt. Moreover affordable housing tends to be the first element of a development to be dropped where sites are complex or have substantial infrastructure costs. This is often the case with new settlements and as such the focus of development should be at existing settlements where infrastructure costs are generally lower. Brownfield sites can have additional site clearance and contamination costs, which can reduce their ability to provide the full requirement of affordable housing and thus there is a key role for greenfield sites in meeting affordable housing needs.

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Q-H5: The provision of land to provide custom and self build housing plots is an important part of housing policy which is not addressed in either the Stratford upon Avon District Core Strategy or the Warwick District Local Plan. Policies that meet the legislative duty to provide enough serviced plots to meet identified demand need to be included within the emerging South Warwickshire Local Plan to provide certainty and to support the growth of this housing type to meet aspirational and affordable needs. Evidence from the Councils’ self-build/custom house build registers indicates that purchasers do not want to be on large development sites. They are looking for smaller sites on which they can create bespoke homes. Alternatively they want individual plots to meet specific needs. In the light of this Stansgate clients would support Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. In addition support would be given to a policy whereby unidentified sites, which will be assessed against a range of criteria to determine their need and suitability, can be brought forwards. Given the lack of demand for homes on large development sites, Stansgates clients would not support Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site.

Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.

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