Issue and Options 2023

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Form ID: 84262

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire

South Warwickshire Local Plan (Part 1) Issues and Options Consultation (Regulation 18) On behalf of our client, Federated Hermes Property Unit Trust (“Hermes”), we are pleased to submit representations to the South Warwickshire Local Plan (“SWLP”) Part 1 Issues and Options Consultation (Regulation 18). These representations have been submitted alongside our response to the Call for Sites in relation to the Maybird Shopping Park, Birmingham Road, Stratford-upon-Avon. Hermes owns Maybird Shopping Park in Stratford-upon-Avon, which is an ‘out of centre’ shopping destination, approximately 800 m from the primary shopping area of the town centre. Existing operators within the shopping park include B&Q, Boots, Next, Matalan and M&S. As set out in the Call for Sites, Hermes is considering the potential future redevelopment of the shopping park for mixed use, residential led development, however these representations are also relevant to continued retail use at the site. Hermes’ response to the Issues and Options Consultation is provided in this letter and focusses on the following issues: • Issue E2: A Low Carbon Economy; • Issue E9: Supporting our changing town centres; • Issue H1: Providing the right number of new homes; • Issue H2: Providing the right tenure and type of homes; • Issue H3: Providing the right size of homes; • Issue C4: New Buildings; • Issue C5: Existing Buildings; Issue C8: Adapting to flood and drought events; • Issue C10 – Climate Change Risk Assessments; • Issue W2: Health Impact Assessments for major development. Summary We trust that the comments on the Issues and Options Consultation Document will be taken into account and used in the further development of the Part 1 SWLP. Hermes would also like to reserve the right to comment on the proposed wording of any draft planning policies when they are published as part of the Preferred Options (Regulation 18) consultation stage.Please do not hesitate to contact myself or my colleague Ian Anderson if you have any queries regarding the comments provided in this letter.

Form ID: 84263

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option E2a: Include a policy which encourages businesses to be low carbon

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Option E2b: Do not include a policy encouraging businesses to be low carbon

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Option E2c: Include a policy which looks to identify sites or development zones which are targeted at businesses wishing to be innovative towards a low carbon economy.

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Form ID: 84264

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option E9a: Identify retail areas on the policies map as well as Town Centre boundaries, within the Part 1 plan

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Option E9b: Save existing town centre and retail area boundaries in the Part 1 plan, and address this in Part 2

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Form ID: 84265

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Q-E11: Please add any comments you wish to make about delivering South Warwickshire's economic needs

Issue E2 – A Low Carbon Economy Hermes’ view is that Option E2a: ‘Include a policy which encourages businesses to be low carbon’ is the most appropriate proposed option which recognises the need to address climate change, and this should apply across the whole of the South Warwickshire Local Plan area. Future policies will need to ensure that there is flexibility in the approach to low carbon initiatives, to ensure that this would not result in developments becoming unviable. Issue E9: Supporting our changing town centres Hermes supports Option E9a: ‘Identify retail areas on the policies map as well as Town Centre boundaries, within the Part 1 plan’. Hermes agree that it is useful to identify retail areas within the Town Centres as well as Town Centre boundaries, in order to effectively apply retail policies. However, important existing out of centre retail facilities such as the Maybird Shopping Park should also be identified as retail locations where further retail/mixed use development would be appropriate. The Maybird Shopping Park is already recognised as an important existing retail location that provides an important and complementary function to Stratford-upon-Avon town centre, with good accessibility. In the short term, this will continue, however this is a relatively low density use and there could be an opportunity in the short/medium/long term for redevelopment of either part of the site, or the whole shopping park, for mixed-use, residential led development.

Form ID: 84266

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire?

Nothing chosen

Q-H1-2: If your answer to H1-1 is No, what would be a more appropriate approach to calculating future housing needs for this Local Plan?

Issue H1: Providing the right number of new homes Notwithstanding the comments above regarding the important retail role the Maybird Shopping Park currently plays, there could be an opportunity in the future for mixed-use, residential led development on part or across all of the retail park, which would increase the density of development in this sustainable location. As noted above, Hermes has responded to the Call for Sites, to propose the Maybird Shopping Park as a potential housing development site. Once the Council has reviewed the further sites submitted as part of the Call for Sites exercise in terms of their availability, suitability and deliverability, there should be a better understanding of future capacity.

Form ID: 84267

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire?

Issue H2: Providing the right tenure and type of homes Hermes’ view is that a single affordable housing requirement across the whole South Warwickshire area is the most appropriate approach to take (Option H2-2a) as this would provide most certainty for developers, rather than applying local variations to reflect value/affordable housing demand.

Option H2-2a: A single South Warwickshire wide affordable housing requirement

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Option H2-2b: Separate affordable housing requirements for Stratford-on-Avon and Warwick Districts

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Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire

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Q-H2-3: How should South Warwickshire best address the specialist needs for older people?

No answer given

Form ID: 84268

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option H3a: Do not seek to include minimum space standards in a policy in the SWLP.

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Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence.

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Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards.

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Option H3d: None of these

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Form ID: 84269

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option H6a: Identify a range of specific sites in sustainable locations of up to 15 pitches/plots in size to be developed only for Gypsy and Traveller and Travelling Showpeople homes.

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Option H6b: Require large developments of over 500 homes to provide a proportion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site.

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Option H6c: Rely on a case-by-case approach whereby planning applications for Gypsy and Traveller and Travelling Showpeople homes will be assessed against a range of criteria to determine their suitability.

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Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire

Issue H3: Providing the right size of homes Hermes’ preference is for option H3a, which does not seek to include minimum space standards in a policy in the SWLP, as this is not a strategic policy, and if necessary minimum space standards could be considered in a Part 2 plan.

Form ID: 84270

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time.

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Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments.

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Option C4.1c: Have a phased approach to net zero carbon, setting a future date by which all new development will need to achieve net zero standards. In the intervening period new development will need to meet building regulation standards.

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Option C4.2a: All new development

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Option C4.2b: Development over a certain size

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Form ID: 84271

Respondent: Federated Hermes Property Unit Trust (“Hermes”)

Agent: Lichfields (London)

Option C5a: Include a policy that requires net zero carbon requirements for all building proposals that require planning permission – including conversions, changes of use, and householder residential applications

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Option C5b: Include a policy that encourages the retrofit of climate change measures, such as solar panels and heat pumps, including those on traditional buildings or within historic areas

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Option C5c: None of these

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