Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? 2.2 Subsequent to the 2021 Scoping Options consultation, St Philips supports the changes to the overarching vision in regard to making clearer the role of housing and jobs within South Warwickshire. St Philips also welcomes the acknowledgement of the need to accommodate the unmet needs of surrounding authorities as stated within the vision. This is considered to be legally compliant in accordance with National Planning Policy Framework [NPPF]paragraph 24 which states: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” 2.3 As discussed in detail below, there is a large quantum of development required throughout South Warwickshire in order to meet both the social and economic needs of the administrative area as well as the neighbouring authorities, such as Coventry and Birmingham. Therefore, St Philips recommends that a suitable quantity of land should be assessed to ensure that the development needs can be met in the most sustainable locations. This would accord with NPPF paragraph 8b in terms of achieving the social objective of sustainable development, which states the following: “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. 2.4 Additionally, in terms of the presumption in favour of sustainable development, NPPF paragraph 11b states that: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” 2.5 In consideration, St Philips also supports the strategic objective that seeks to deliver the right quantity of homes in order to “meet the needs of all of our communities” (IO, page 23). With regard to the Duty to Cooperate and the unmet needs identified within Birmingham and Coventry, St Philips considers that reference should also be made within this strategic objective to meeting the unmet needs of neighbouring authorities. Although, it has been acknowledged and welcomed that the overarching vision makes reference to meeting the unmet needs within surrounding authorities.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
There appears to be heavy and completely unnecessary priority to build in the greenbelt. This land should be protected as a high priority, it is vital that the urban sprawl towards Coventry is prevented and that the land remains open and as a greenbelt.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
Main objectives and priority actions (page 21 & 22) Supportive of the main objectives and priority actions. Make the additional comments: OB 1 Address the skills imbalance – strongly supported B2 increase provision of affordable housing – strongly supported 3.7 Don’t believe that this addresses the looming water crisis although action to capture /retain water would reduce flooding. (see below) 4.2 A lot more can and should be done. In addition we should not ignore the significant potential contribution of the domestic ‘estate’ in both demand reduction and self-generation. Also: Water Inadequate water resources is increasingly likely to be an issue confronting us all. I am surprised that in is not mentioned. Health & Social care Businesses rely on people to be successful. There are gaps in the health and social care that result in `fit days lost` that undermines productivity. A systems approach to a comprehensive economic strategy should at minimum identify these issues and aim to join forces with those that have the tools to resolve. The same could be said for child care.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
General Observations 2.2. Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stratford-on-Avon District Council and Warwick District Council up to 2050. Paragraph 22 of the National Planning Policy Framework (NPPF) requires that all strategic policies should have a minimum timeframe of 15 years from point of adoption. While the SWLP is compliant with Paragraph 22 there is concern that a plan period to 2050 may be too ambitious in so far as it may be difficult for the plan to adapt to change. A further concern is that in establishing a 25-year plan period, the SWLP will make decisions that are so long term that it could compromise meeting the development needs of the area. By way of example, the SWLP could allocate a site which would genuinely take 20 years to deliver as a key part of its development strategy and given the magnitude of such sites could lead to smaller sites, in deliverable locations, not coming forward to meet housing needs in the intervening period. 2.3. Section 1.4 of the Consultation Document confirms that it remains the Council’s intention to prepare a two-part plan. The Respondent’s main concern regarding a two-tier system is the inevitable delay in plan-making that will occur as a result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans, there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect updated evidence needs. This is a particular concern given the projected end date of the plan being some 25 years hence. 2.4. The suggested timetable for the SWLP’s preparation is also considered to be highly ambitious. Given that most Local Plans take more than a year to be Examined by the Secretary of State it is considered very unlikely that Part 1 will be adopted before 2027 and potentially beyond if there is slippage between the public consultation stages indicated in Figure 2 (Page 16) of the Consultation Document. Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2: If no, please indicate why: 2.6. The Respondent is in general agreement with the vision and strategic objectives set out in the Consultation Document but considers that the delivery of market and affordable housing to meet housing needs, including unmet need arising from neighbouring authorities, should be given greater emphasis in the Council’s Vision for the Local Plan (V1). 2.7. The respondent would also suggest the following amendment: “The vision is to meet South Warwickshire’s sustainable development needs to 2050, including new market and affordable homes, while responding to the climate emergency. Where appropriate and agreed, this should include unmet need from neighbouring authorities. The plan will provide homes and jobs, to boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time. Five overarching principles will determine how this development is delivered:” 2.8. With regards to V3: Strategic Objectives, the role that all current settlements can play in meeting housing needs should be recognised. 2.9. Furthermore, in recognition that it may not be possible to fully off-set carbon emissions in all cases (see comments made later in this Statement), the Council should consider updating the strategic objective of “Contributing towards Net Zero Carbon targets” to refer to “Minimising net carbon emissions arising from new development as far as practicable” (or similar).
Q-V3.1 & 3.2 – Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. My reasoning for this is that the greenbelt in this local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority. I am very concerned that the previous consultation exercise, which has a tiny number of respondents is being used as justification for a greenbelt review, that consultation was so small that it should be disregarded. I am strongly opposed to any review of greenbelt boundaries, with the single exception of when brownfield sites are identified within the greenbelt.
Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation, with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority. Not only does greenbelt protect and preserve open land spaces, but these areas also have many more benefits such as tackling issues such as air pollution, slowing and reducing the impacts of climate change and providing essential habitats for wildlife.
3.2 The University supports, as consistent with its own vision, the strategic objectives set out in the plan of climate resilient and Net Zero Carbon; well-designed and beautiful; healthy, safe and inclusive; well-connected; and biodiverse and environmentally resilient.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: The use of the greenbelt area for the scale of development proposed would be detrimental to the local residents of Weston Under Wetherley, Hunningham and Cubbington due to the creep towards urban sprawl resulting in the connection of these spaces. This will not only deprive local residents and tourists of the ability to walk across the variety of footpaths through beautiful countryside, some of which is so pretty it is noted in national walking guides but will deprive the well established villages and areas of their unique identity and underlying local cultures. Further to this the loss of habitat and therefore biodiversity would have a vast impact and one that cannot be truly mitigated against or offset in any meaningful way. Continued housing developments that do not utlise existing space such as that suggested by many academics as needed in central urban areas to overcome the urban decay and empty shops from the post covid work at home environment and subsequent loss of urban footfall are unimaginative and ultimately unsustainable. Considering the lack of eco-credentials and loose energy standards that new developments are currently subject to in the UK compared to many other first world nations makes the use of climate emergency as a reason null and void, if any development does not utilize existing space and resources and result in passive energy use.
General Points. Firstly, may I congratulate Warwick and Stratford Councils for continuing to work together on the combined Local Plan, despite the decision of the two Councils not to merge their two authorities after all. There is no doubt that ‘South Warwickshire’ is a more logical strategic geographical area on which to plan ahead for a Local Plan. A combined plan will also save time for everyone in engaging in what might have been two plans and also saving on Duty to Cooperate liaison between the two, Secondly, it is impressive that both Councils have continued to press on with the joint review despite the uncertainty at national level on planning reform and especially in the light of the chaotic and confusing Planning Reform consultation paper which was circulated by DLUHC just before Christmas, Thirdly, and on the other hand, this does raise questions about the future of Stratford DC’s own ‘Site Allocation Plan’ which has already undergone 3 different iterations and, as yet, has not been formally submitted. This is worrying for those landowners and developers (such as two of my clients) who have 2 self-build sites ‘marooned’ within the latest Preferred Options SAP which apparently still has little weight within the planning system and yet they are promoted those sites at risk. Vision. Issue V1. Vision for the plan: My clients positively welcome the vision as set out in the document broadly ‘to meet South Warwickshire’s sustainable needs to 2050 and where appropriate to reflect unmet needs from neighbouring authorities’. We also welcome the desire to respond to the climate emergency – but are slightly unclear about what this will mean in the context of the overall vision. This ought to be made more clear in the accompanying text. Issue V2. Vison for Places: I acknowledge the point that a ‘standard’ vision for places is probably inappropriate. Each ‘place’ will no doubt have its own ‘Vision’. However, not all places have Neighbourhood Plans and I worry that some places, given the choice, will choose to resist change as a means of protecting their own comfy lifestyles rather than thinking about the future of the settlement or indeed the needs of subsequent generations. Category F settlements in Stratford for example, have a policy which resists any development unless it is ‘community led’. This effectively acts as a nimby’s charter to enable ‘locals’ to resist outsiders. It has been applied very effectively in Priors Hardwick recently to stop a sustainable proposal for a single cottage which had previously legitimately gained consent on appeal. Issue V3. Strategic Objectives: I would broadly accept the strategic objectives, however the objective that ‘new development does not cause an increase in carbon emissions’ seems wholly unrealistic. This seems a very high bar to achieve for every application to surmount.
The opening statement of the Vision is ‘to meet South Warwickshire’s sustainable development needs, while responding to the climate emergency’. We are pleased to see reference being made to ‘sustainable development’ at the start of the Vision, as this ties in well with the purpose of the planning system, which is ‘to contribute to the achievement of sustainable development’2. However, the phrase ‘to meet South Warwickshire’s sustainable development needs’ inappropriately skews the emphasis towards ‘development needs’ rather than ‘sustainable development’. This impression is reinforced by the Strategic Objectives, where the objective of ‘meeting South Warwickshire’s sustainable development needs’ only focusses on delivering vibrant town centres, infrastructure, jobs and homes. It is further reinforced by the emphasis given to infrastructure, jobs and homes in the third paragraph of the Vision. Development is only sustainable if it meets economic, social and environmental objectives in mutually supportive ways.3 It is not appropriate to emphasise one or two of these objectives over another. We acknowledge that the opening statement of the Vision states ‘… while responding to the climate emergency’. Responding to the climate emergency is obviously a key consideration. However, this should not be the only environmental objective that is addressed at the start of the vision. Also, the use of the word ‘while’ creates the impression that responding to the climate emergency is a secondary and separate objective, albeit that will be addressed concurrently with meeting sustainable development needs. The vision should make it much clearer that development needs should be met in a way that actively addresses the climate emergency. Alongside the ‘climate emergency’, explicit reference should also be made to the ‘ecological emergency’ (i.e., the drastic decline in biodiversity at an international, national and local level). With regards to the ecological emergency, we recommend that the principle of having ‘a biodiverse and environmentally resilient South Warwickshire’ should explicitly seek to achieve a significant increase in biodiversity. We also have concerns about the emphasis given, in the Vision, to accommodating unmet needs from neighbouring authorities. Whilst this is an important consideration for identifying the amount of housing and development that should be planned for (and the spatial strategy for delivering this), it does not seem appropriate to put this issue ‘front-and-centre’ in the over-arching Vision for the area. We suggest that this sentence should be deleted. Strategic Objectives All of the strategic objectives should contribute to sustainable development. This should be made clear in the opening / supporting text for the strategic objectives. In this context, and having regard to our comments on the Vision, the first strategic objective should be ‘Meeting South Warwickshire’s Development Needs’ rather than ‘Meeting South Warwickshire’s Sustainable Development Needs’. The section of the strategic objective ‘A resilient and Net Zero Carbon South Warwickshire’ should address the resilience of the whole South Warwickshire area to climate change, not just the resilience of new development. We consider that the strategic objective of ‘A well-designed and beautiful South Warwickshire’ should make explicit reference to the Cotswolds National Landscape (CNL). Although the CNL only covers a small part of South Warwickshire, its setting covers a wide and development further afield has the potential to increase traffic movements through the CNL. The CNL is also an area whose distinctive character and natural beauty are so outstanding that it is in the nation’s interest to safeguard it. This national importance should be reflected in the strategic objectives. Recommendations (in relation to Q-V3.1 and Qv3.2) Vision Suggested wording: The vision is to achieve sustainable development in South Warwickshire by meeting the area’s development needs in a way that actively addresses the climate and ecological emergencies and significantly enhances our natural and built environment. The plan will provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time. Five overarching principles will determine how this development is delivered: • A climate resilient and Net Zero Carbon South Warwickshire – adapting to the effects of climate change and mitigating against its causes, while avoiding any further damage that might arise from development • A well-designed and beautiful South Warwickshire – creating spaces where people want to be, which respect and reflect the existing beauty and heritage of the area • A healthy, safe and inclusive South Warwickshire – enabling everyone to enjoy safe and healthy lifestyles with a good quality of life • A well-connected South Warwickshire – ensuring that development is physically and digitally connected, provided in accessible locations, and promotes active travel • A biodiverse and environmentally enhanced South Warwickshire – strengthening green and blue infrastructure and achieving a significant net increase in biodiversity across South Warwickshire Strategic Objectives – Meeting South Warwickshire’s Sustainable Development Needs The title of this strategic objective should be changed to ‘Meeting South Warwickshire’s Development Needs’, with the supporting – or introductory – text clarifying that all of the strategic objectives should contribute to achieving sustainable development. Strategic Objectives - A resilient and Net Zero Carbon South Warwickshire The wording of the bullet point should be changed to: • Ensuring that South Warwickshire is resilient to climate change, that new development does not cause a net increase in carbon emissions and that every opportunity is taken to reduce existing carbon emissions and mitigate against – and adapt to - climate harms. Strategic Objectives – A well-designed and beautiful South Warwickshire This strategic objective should include an additional bullet point: • Conserving and enhancing the natural beauty of South Warwickshire’s valued landscapes, particularly the Cotswolds National Landscape. Alternatively, to ensure consistency with other bullet points, the phrase ‘protecting and enhancing’ could be used. 2 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework. Paragraph 7. 3 NPPF. Paragraph 8
Q-V3.1 & 3.2 - Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local areas is of vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt, and especially farmland, should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. My reasoning for this is that the greenbelt in this local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority. I am very concerned that the previous consultation exercise, which has a tiny number of respondents is being used as justification for a greenbelt review, that consultation was so small that it should be disregarded. I am strongly opposed to any review of greenbelt boundaries, with the single exception of when brownfield sites are identified within the greenbelt.
We agree that the Vision is essential to set out the main aims which the Plan hopes to deliver. We acknowledge that from the high-level goals identified, the guiding principles provide more clarity on how the goals will be achieved. It will be important, as the vision states, to ensure that proper placemaking to deliver more local visions takes place. The SWLP suggests that this is brought forward by Neighbourhood Development Plans. We note that NDPs are important to reflect the needs and wishes of the local community but believe it is important that some overarching principles for areas are established ahead of these. This is because in some cases, Neighbourhood Plans can face delay or not come forward at all. We support the five overarching principles for development including adapting for climate resilience; well-designed spaces; creating a healthy, safe and inclusive district; being wellconnected; and being environmentally resilient. The ability to deliver ‘homes for all’ will be important in ensuring diversity and to enable a thriving population and it is positive to see that the Local Plan will intend to engage positively with neighbouring authorities. It recognises this by confirming that where appropriate and agreed, unmet need from neighbouring authorities will form part of the consideration for sustainable development.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: We believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
The Vision and Strategic Objectives should specifically state that avoiding development on Green Belt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy bias towards development in the greenbelt which it unexplained and unjustified. The Green Belt to the North of Leamington has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of Green Belt should be given higher priority. This must be included as part of the accepted Vision and Strategic Objectives. Every Option you have put forward has development in the Green Belt consequently this will have severely disrupted the ability to obtain resident responses as it implies a decision has already been made. The Green Belt around the North of Leamington fulfils all of the five stated purposes of Green Belt land. The Government has recently made it clear in a letter from the Secretary of State for Levelling Up, Housing and Communities, that local planning authorities such as Warwick District Council are not expected to review the Green Belt to deliver housing. Changes to the National Planning Policy Framework mean that the estimated figure for Local Housing Need is, to quote the letter from Michael Gove MP “no more than” a starting point and “importantly, that areas will not be expected to meet this need where they are subject to genuine constraints”. The Green Belt around North Leamington is recognised as a genuine constraint to development. One of the most important reasons for a Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land and the Secretary of State’s letter in December also made a “brownfield first” pledge which should be the basis of the way that a District Council such as Warwick responds to unmet housing need in other neighbouring authorities. So, the “brownfield first” pledge should be reflected in any duty to cooperate with other local authorities, ensuring that larger conurbations do look hard at creative brownfield solutions close to where people work. Developers may well prefer to use greenfield sites as these are easier to develop, but that goes against the latest Government advice and is contrary to accepted Sustainable Communities and fighting climate change. The Green Belt around the North of Leamington is a highly valued open space. Local residents feel it is very valuable to us for both our physical and mental health. It is visually of a very high quality and has a number of easily accessible public footpaths across the fields. These footpaths were heavily used during lockdown with enormous benefit to public health and wellbeing. Maintaining the Green Belt boundary, as currently defined, is vital in maintaining this popular differential between town and country. Development within the Green Belt to the north of Leamington Spa would substantially reduce the land that separates Kenilworth from Leamington Spa. This is even more the case since the current Local Plan which in reviewing the Green Belt removed land to the south of Kenilworth and north of the A46 from the Green Belt. The joint Green Belt study in 2015 highlighted the contribution to preventing the merger of Leamington Spa, Kenilworth and Coventry that this part of the Green Belt makes by stopping urban sprawl, protecting the countryside and preserving the special character of these differing but very special historic towns. The Green Belt land to the north of Leamington is high-quality. It is to be noted that recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The Government is clear that it seeks to protect such land from non-agricultural development, and indeed the National Planning Policy Framework states, “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality”.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
The vision and strategic objectives are idealistic. There is no detail on how these are to be achieved. For instance, “ensuring new development does not cause a net increase in carbon emissions” is highly unrealistic even if there is significant change in new housing policy. How would this be achieved through the whole supply chain? Steel and concrete are carbon intense materials, trucks will be needed to deliver building materials, trees and green land will be destroyed to make way for housing. Even attempts to make the houses sustainable such as the production of heat pumps, creates carbon in the supply chain as well as the fall-out from mining for the components. Creating new developments causes significant carbon emissions whether we like it or not. Of course there are ways to minimise this but to suggest development will be carbon neutral is green washing even with proposed use of off-setting schemes which are often not effective. Comments such as “providing infrastructure in the right place at the right time” and “design of developments to…cater for the needs of all users and which respect the setting of many settlements” sounds good but is not followed through in the rest of the plans. To respect current settlements there would be no talk of relaxing current green belt rules or overriding current neighbourhood plans, and there would be emphasis on ensuring the infrastructure is present or developed to support the planned growth in communities. At present there is no obvious plan/funding to provide infrastructure and this seems left to private developers who have a poor track record in providing such facilities and may not have the correct information regarding what is actually needed. “A healthy, safe…Warwickshire – enabling everyone to enjoy safe and healthy lifestyles and a good quality of life” will not be possible if there are not enough school places/GP surgeries, increased congestion and pollution on our roads and no substantial green spaces left. The plan to achieve a net increase in biodiversity across South Warwichshire is at odds with the extensive plans for development and current strategy to relax green belt rules. We are extremely concerned that the Plan doesn’t include the 20% biodiversity net gain that the Warwickshire Wildlife Trust advocated for, that the Green Infrastructure study is now 10 years old, that your growth and new settlement locations don’t consider local biodiversity and river habitats and you don’t go far enough in tackling the climate emergency. So whilst superficially the vision and objectives look good we find them to be unrealistic and disingenuous, without proper backing in the rest of the plans.
The vision and strategic objectives are idealistic. There is no detail on how these are to be achieved. For instance, “ensuring new development does not cause a net increase in carbon emissions” is highly unrealistic even if there is significant change in new housing policy. How would this be achieved through the whole supply chain? Steel and concrete are carbon intense materials, trucks will be needed to deliver building materials, trees and green land will be destroyed to make way for housing. Even attempts to make the houses sustainable such as the production of heat pumps, creates carbon in the supply chain as well as the fall-out from mining for the components. Creating new developments causes significant carbon emissions whether we like it or not. Of course there are ways to minimise this but to suggest development will be carbon neutral is green washing even with proposed use of off-setting schemes which are often not effective. Comments such as “providing infrastructure in the right place at the right time” and “design of developments to…cater for the needs of all users and which respect the setting of many settlements” sounds good but is not followed through in the rest of the plans. To respect current settlements there would be no talk of relaxing current green belt rules or overriding current neighbourhood plans, and there would be emphasis on ensuring the infrastructure is present or developed to support the planned growth in communities. At present there is no obvious plan/funding to provide infrastructure and this seems left to private developers who have a poor track record in providing such facilities and may not have the correct information regarding what is actually needed. “A healthy, safe…Warwickshire – enabling everyone to enjoy safe and healthy lifestyles and a good quality of life” will not be possible if there are not enough school places/GP surgeries, increased congestion and pollution on our roads and no substantial green spaces left. The plan to achieve a net increase in biodiversity across South Warwichshire is at odds with the extensive plans for development and current strategy to relax green belt rules. We are extremely concerned that the Plan doesn’t include the 20% biodiversity net gain that the Warwickshire Wildlife Trust advocated for, that the Green Infrastructure study is now 10 years old, that your growth and new settlement locations don’t consider local biodiversity and river habitats and you don’t go far enough in tackling the climate emergency. So whilst superficially the vision and objectives look good we find them to be unrealistic and disingenuous, without proper backing in the rest of the plans.
This Section of our representations comments on the proposed Vision and proposed Strategic Objectives. We support both the Vision, the Strategic Objectives. We note that the Vision and Strategic Principles for Long Marston were originally set out in the adopted SPD dated February 2018 and that some degree of updating will be required to bring this in line with the emerging Vision within the South Warwickshire Local Plan; specifically in terms of climate resilience and sustainable modes of travel. This will not however undermine the key design principles or jeopardise options for further growth at Long Marston Garden Village. The Strategic Objectives are important in providing a greater level of detail We agree with the Strategic Objectives and draw particular reference to “Meeting South Warwickshire’s Sustainable Development Needs”. This will require a strategy to ensure the delivery of objectively assessed housing needs through a range of homes, on a portfolio of sites.
Issue V1: Vision for the Local Plan; Issue V3: Strategic Objectives: We broadly support this plans vision and strategic objectives. In addition, Natural England advises that the Plan’s vision should address impacts upon, and opportunities for, the natural environment as a high priority. ‘An economy is built upon the environment’ - Economic growth and the environment - GOV.UK (www.gov.uk) https://www.gov.uk/government/publications/economic-growth-and-the-environment. It needs to clearly set out the environmental ambition and linked opportunities for the plan area. The plan should take a strategic approach to the protection and enhancement of the natural environment, including providing a net gain for biodiversity, considering opportunities to enhance and improve the quality of connectivity. Where relevant there should be linkages with the Biodiversity Action Plan, Local Nature Partnership, National Park/Area of Outstanding Natural Beauty Management Plans, Rights of Way Improvement Plans and Green Infrastructure Strategies, Nature Recovery Network (amend as appropriate to the local area). We note that you make mention of the Climate emergency, however there is also a biodiversity emergency which must be held with equal status alongside climate change as it has the potential to contribute to addressing climate change. Biodiversity - our strongest natural defence against climate change | United Nations. The inclusion, interaction and nature connectedness of people must also be considered as a priority in especially in terms of their wellbeing and developing love for the natural world. There should be an overarching strategy in the plan for the natural environment covering: • natural capital assets and ecosystem services • nature recovery • landscape, including designated landscapes • designated sites and local sites • ecological networks • irreplaceable habitats, priority habitats and species • protected species • impacts on invertebrates • geodiversity • soils and best and most versatile land • green infrastructure • biodiversity and wider environmental net gains • environmental enhancement • climate change adaptation Issue V2: Vision for Places: We support the inclusion of visions for places being captured within neighbourhood plans in that the local context and community will have a more intimate connection/understanding of what makes their place special. In following this practice we urge you to ensure you identify and find innovative ways of reaching those voices within the community that are likely to be overlooked. Alongside this approach we welcome the recent NPPF reform of the term ‘Beauty’ in ensuring that designs of Green and Blue infrastructure reflect a ‘Natural Beauty’ as part of the built environment. Recently launched NE GI Framework guidance will help here as will NE landscape sensitivity assessment guidance. The Plan should set design standards for high quality placemaking. The plan should incorporate a policy on design (including landscape character and green infrastructure) and set out what further guidance is available. The NPPF encourages all local authorities to prepare local design codes or guides. National design guidance is set out in the National Model Design Code (https://www.gov.uk/government/publications/national-model-design-code) and the National design guide (https://www.gov.uk/government/publications/national-design-guide).
As set out in response to the Scoping and Call for Sites consultation, L&Q Estates supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a more rural population than Warwick and those difference must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. L&Q Estates supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives The Plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented as it accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of homes and jobs does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation document goes onto talk about the delivery of growth an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.