Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
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.
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 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.
Question V3.1 & 3.2 … Vision and Strategic Objectives National Planning Policy Framework states “ the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent Urban Sprawl by keeping land permanently open.” In its present form the SWLP chooses to set this fundamental aim aside with an unjustified bias towards development in the Green Belt to the North of Leamington Spa. I believe it is most important to prevent creeping sprawl towards Coventry. In my view the Vision and Strategic Objectives should state that avoiding development on Green Belt land will be prioritised at all stages of the Plan development. The protection of the Green Belt should be given higher priority than at present.
Who could possibly object to these. We question whether these are strategic objectives: they are aims and it is important to recognise that there are conflicts between them.
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.
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.
No – We welcome the including of tourism potential under a “well-designed and beautiful South Warwickshire.” However, we consider that “protection and growth of visitor attractions, recreation and leisure facilities and visitor accommodations” should be a strategic growth objective under “Meeting South Warwickshire ‘s Sustainable Development Needs.”
No - The local environment and habitat needs to be considered. Currently it seems that only AONB are considered which are more than 14 km away. We have important farm land surrounding kenilworth which if built on will be gone forever. Being able to provide diffident food for the local population is extremely important. We are all striving for zero food miles. We also need to develop farming practices to provide more effective and efficient farming practices, this could be a key contributor to economic growth. In addition, the landscape around kenilworth provides a habitat for wildlife including deer, badgers, foxes, squirrels, rabbits, voles, moles, a wide variety of birds. This must not be overlooked. We have a responsibility to maintain these ecosystems. We are also blessed with the beautiful, historic kenilworth castles which is located on the north side of Kenilworth town surrounded by beautiful country side. This must be preserved for future generations to enjoy. In my view this area should be defined as an area of outstanding natural beauty.
3.2 Rainier are supportive of the overall vision of the Plan, which ultimately seeks to meet South Warwickshire’s sustainable development needs to 2050. 3.3 Rainier are however concerned that the Vision does not wholly acknowledge the importance of meeting the employment needs of South Warwickshire and it does not recognise the significant role that employment growth will play in meeting development needs up to 2050. 3.4 The plan’s focus should be equally between housing and employment needs, as both support each other and are integral to the growth of the area. 3.5 Rainier is supportive of the five overarching principles that have been established to underpin the Vision for the Plan; and their land south of M40 J15 will be able to meet these as follows: • A climate resilient and net zero carbon South Warwickshire – Rainier will ensure that any development proposed on the Site will be climate responsive, addressing both operational outputs and embodied carbon so that it does not create more emissions that are offset or stored up. • A well-designed and beautiful South Warwickshire – The design evolution for the Site has been informed by landscape and visual considerations, which has identified key points to be implemented, to ensure that any future development of the Site will be well-screened and there will be no detrimental impact on the surrounding area. • A healthy, safe, and inclusive South Warwickshire – The Site is highly accessible, with good access to existing bus services. Also, the delivery of employment use on the Site will enable several Key Deliverables across the region, for example enhancing the existing cycle route 41, and providing new pedestrian connections, as shown within the Vision Document. • A well-connected South Warwickshire – The Site is very well-connected, in close proximity to the M40 Motorway, which presents an opportunity to support the Midlands Engine (a demonstration of the government’s commitment to making the Midlands a powerful engine for economic growth). • A biodiverse and environmentally resilient South Warwickshire – The Site largely comprises two fields which are considered to be of little ecological value. Issue V2: Vision for Places 3.6 Figure 6 of the Plan sets out the ‘Suggested location for Visions for Places within the Development Plan’; however Rainier have concerns that there is no specific definition for what comprises ‘strategic’ or ‘non-strategic’, i.e., a definition for which policies and site allocations would fall under SWLP Part 1 and SWLP Part 2 respectively. 3.7 It is therefore recommended that the SWLP Part 1 Plan is amended to include a definition for ‘strategic growth’, for example regarding strategic employment sites, these should be defined as sites of 5 hectare or over, and/or 20,000 sqm of office floorspace to be considered in the SWLP Part 1 Plan, and all smaller sites to be considered in the Part 2 Plan. Issue V3: Strategic Objectives 3.8 The proposed Strategic Objectives set out further detail for how the Local Plan Vision will be delivered in South Warwickshire. We support these objectives and have therefore set out how the delivery of employment development on the Site can meet them (where relevant), whilst focussing on high quality design: • Providing infrastructure in the right place at the right time – Future development will present an opportunity to promote active and sustainable travel, enhancing connectivity and infrastructure for business. Opportunities will also arise for multi-purpose green and blue infrastructure including buffer screen planting, ponds, SuDS, and enhanced biodiversity. • Developing opportunities for jobs – One of the key deliverables for the Site is to create jobs that are accessible locally, building on South Warwickshire’s strong and diverse economy. • Contributing towards Net Zero Carbon targets – Rainier are committed to ensuring that the new development will not cause a net increase in carbon emissions and it will be resilient to a changing climate. This includes the provision of an EV charging hub on site. • Creating attractive places – As illustrated on the Preliminary Site Layout Plan (in the Vision Document), the scale and diversity of potential development on the Site seeks to deliver a commercial masterplan which recognises the importance of the buffer zones to protect adjacent conservation and ecological zones. Consequently, the development will be built to a high quality, catering for employment needs and which respect the setting of the surrounding settlements. • Protecting and enhancing our heritage and cultural assets – The Site does not contain any designated heritage assets; however, beyond the Site there are several designated heritage assets, and Sherbourne Conservation Area is located to the west of the Site. The Vision Document therefore appraises how this context provides distinctive place-shaping opportunities for future development and identifies the specific elements that will be considered in the evolution of the proposals for the Site. • Improving the health, safety, and quality of life of our communities – Development of the Site has the potential to deliver wider benefits to the community, including an improved cycle way along the A429, a new pedestrian path linking Sherbourne and Bamford Village, potential to reduce traffic noise, and a significant country park (as shown in Appendix A of the Vision Document) which provides a buffer from Sherbourne Conservation Area. • Connecting people to places – The Site is ideally located for access to the wider SRN and connections to the whole of the UK, including the A429 (a major road connecting Warwick to Cirencester), M40 Motorway (London to Birmingham Motorway), and the A46 (providing access to Cheltenham, Broadway, Stratford-on- Avon, Coventry, Leicester, Newark and Lincoln). • Protecting and enhancing our environmental assets – It is Rainier’s intention to maximise opportunities for enhancements across the Site and specifically, the proposed employment development can mitigate impacts on issues such as drainage, heritage, landscape, and biodiversity and deliver real benefits for the community.
Issue V1: Vision for the Local Plan Historic England is pleased to see that the proposed Vision now encompasses heritage within a new overarching principle on design and beauty. Issue V3: Strategic Objectives Historic England welcomes the addition of a specific objective relating to protecting and enhancing the heritage and cultural assets of the area. However, we suggest that the word ‘protecting’ is amended to ‘conserving’, to better reflect the wording of the NPPF.
Crest Nicholson welcomes the focus in the Vision on the delivery of homes and jobs and that this will include, where appropriate, unmet need from neighbouring authorities. The inclusion of reference to a ‘Net Zero Carbon South Warwickshire’ is noted and, as set out in the accompanying Vision document for the ‘Land South of Westwood Heath Road’ site, Crest Nicholson is the first UK housebuilder to have its net-zero target validated by the Science Based Targets initiative (SBTi), reflecting its commitment to reducing greenhouse gas (GHG) emissions across its value chain and reaching net-zero GHG emissions by 2045. Crest Nicholson will engage with the Local Plan process as it progresses, in order to assist with ensuring that the policies relating to zero / low carbon development are deliverable.
2.1 No. 2.2 It is noted that under the heading ‘Meeting South Warwickshire’s Sustainable Development Needs’ there is an objective relating to ‘delivering homes that meet the needs of all our communities’. However, this objective only relates to addressing local housing need but does not include any reference to addressing development needs from neighbouring areas. This is despite the accepted position that South Warwickshire straddles two market areas; Greater Birmingham and the Black Country, and Coventry & Warwickshire. Both of these market areas have a history of unmet need which, in Birmingham’s case, has never been fully addressed and which is now worse (c. 78,000 dwellings) compared to the shortfall in the adopted Birmingham Development Plan (37,500). This is in addition to the unmet need arising from the Black Country, which currently stands at 28,239 dwellings up to 20391. 2.3 On this basis, RPS recommends that the objectives of the SWLP should be updated to reflect the emerging position regarding future (unmet) need across the wider market areas within which South Warwickshire is located and which make a clear commitment to assisting in addressing those needs. 2.4 In addition, the SWLP draft vision runs up to 2050. However, the base year date is not defined in the IO document. Paragraph 22 of the NPPF makes clear that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years) to take into account the likely timescale for delivery. In this case, the SWLP includes options for new settlements and significant extensions to existing urban areas, which fall into the paragraph 22 development categories. Assuming adoption of the SWLP is likely during 2025 at the earliest, 30 years from adoption would extend the plan period to 2055. Accordingly, RPS recommend that in line with the NPPF, the SWLP should look ahead to 2055 at the earliest). 1 Draft Black Country Plan 2020-2039, July 2021, Table 2
We largely agree with the Vision and Strategic Objectives as set out, but would welcome the specific inclusions of homes also be delivered in all locations to cater to the needs of all potential occupiers.
The Vision and Objectives are currently meaningless because they are not followed through appropriately in the rest of the proposed plan. Consider for example the linked factors of 'Creating attractive places' (which includes 'great spaces') and 'Protecting and enhancing our environment' (which includes 'protecting what already exists'). The Green Belt is an essential part of an attractive place and vital to protecting our environment. Yet as the proposed plan develops through the chapter on Meeting Sustainable Development Needs, first it ignores the fact (defined in the NPPF) that the key characteristic of the Green Belt is its permanence; it then it goes on to define "the approach taken has been 'blind' to whether a particular location or corridor is in the Green Belt." This approach is unacceptable and invalidates the analysis of growth options. The consultation is flawed because you have given consultees no opportunity to respond to 'Issue S6: A review of Green Belt boundaries' by offering any questions Q-S6. This is a particularly serious omission in light of the responses to the Scoping consultation.
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 thatthe 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.
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 consultation version of the SWLP does not state when the plan period will commence, it just states that the plan will cover the period up to 2050. The Urban Capacity Study states that the plan period is between 2025-2050 (paragraph 1.1). Consideration should be given to the length of the plan period if the Councils choose to allocate any new settlements or large urban extensions. Paragraph 22 of the National Planning Policy Framework (‘NPPF’) states that “where larger-scale development such as new settlements form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery” (Savills emphasis). In light of this, the Council’s may wish to extend the plan period beyond 2050.
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.
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.
Vision 2.2 In overall terms the suggested Vision is unobjectionable. However, some minor redrafting would strengthen it as a statement of intent: The vision is to meet South Warwickshire’s development needs to 2050 in a sustainable manner and responding to climate change. The local plan will ensure that sufficient homes are built for current and future residents and land is provided for new jobs to boost and diversify the local economy, in suitable locations, at the right time. New infrastructure will be provided to support new growth. 2.3 The five overarching principles are equally unobjectionable when seen in the context of the Vision as a whole and the supporting strategic objectives. Strategic Objectives 2.4 The Strategic Objectives are important in providing a greater level of understanding as to how the Vision will be delivered. In other words, what is the practical effect of having this Vision. 2.5 We agree with the breadth of the Strategic Objectives and in particular those associated with “Meeting South Warwickshire’s Sustainable Development Needs”. 2.6 This will require planning policies and proposals that ensure a sufficient number and range of homes are provided to meet the needs of present and future generations. In this context Sustainability Objective 9 concerning Housing is important. Where policies and proposals are shown to contribute a positive beneficial effect, these should be cornerstones of the Local Plan. 2.7 This is particularly germane to considerations as to the overall amount of new housing to be provided and where in the plan area which we discuss in later sections of our response.