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.
The WMHAPC welcomes the South Warwickshire (“SW”) councils’ recognition of the need to deliver “homes that meet the needs of all our communities…Allowing for the growth in new homes that meet the diverse needs of all our residents, including affordable, student, specialist and self and custom build housing, along with the accommodation needs of our gypsy and traveller and travelling show people communities.” Housing associations are well placed to help the SW councils deliver this strategic objective.
2.1. As set out in response to the Scoping and Call for Sites consultation, Persimmon 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. 2.2. 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 much more rural population than Warwick and those differences 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 2.3. 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. Persimmon 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 to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. 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, which 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.” 2.5. 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 documents 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. 2.6. 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. 2.7. 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.
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.
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.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? 2.1 Ellis Machinery supports the vision in principle, which seeks to create a prosperous, strong and sustainable South Warwickshire. The vision provides a positive framework for the Strategic Objectives and is generally reflects the three overarching sustainability objectives set out in NPPF Paragraph 8. Strategic Objectives 2.2 Ellis Machinery is supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Stratford on Avon Core Strategy was adopted in 2016. We consider that the Site, which has the potential to deliver 80 new homes in Gaydon would assist the South Warwickshire Authorities in achieving these objectives. 2.3 In seeking to achieve the strategic objective there will be competing needs, which will have to be carefully assessed in the planning process, in both allocating strategic development sites and in the decision making and determination of planning applications. This should be acknowledged in the wider planning context.
The Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be a priority at all stages of the plan development. The proposals are totally at odds with this as they seem to contain a high level of development in the greenbelt which in consideration of a sustainable “Vision and Strategic Objectives” philosophy is fundamentally flawed.
2.1. As set out in response to the Scoping and Call for Sites consultation, Persimmon 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. 2.2. 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 much more rural population than Warwick and those differences 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 2.3. 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. Persimmon 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 to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. 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, which 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.” 2.5. 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 documents 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. 2.6. 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. 2.7. 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.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: I strongly feel that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages. The greenbelt in our local area is crucial in preventing urban sprawl, protecting wildlife and keeping land permanently open. The protection of greenbelt should be given higher priority.
We agree that the Vision and Strategic Objectives are appropriate; our response will be limited to the following objectives: Providing infrastructure in the right place at the right time. Developing opportunities for jobs. Contributing towards Net Zero Carbon targets. Enriching the tourism potential. Connecting people to places.
Thank you for providing the opportunity to respond to this early stage of the process of preparing the South Warwickshire Local Plan (SWLP). This response has been submitted to meet the Duty to Cooperate requirements by Wychavon District Council (and on behalf of the South Worcestershire Councils that include Malvern Hills District Council, Wychavon District Council and Worcester City Council). These are further officer comments to your initial consultation undertaken in June 2021. The joint working approach adopted by Stratford-on-Avon District Council and Warwick District Council is welcome. This reflects the similar working relationship in South Worcestershire, that brings with it benefits of being able to forward plan on a strategic level, and economies of scale etc. It is noted that the SWLP is a strategic level plan, and that further DPD will be prepared covering Development Management policies etc. in due course. Support is given to the plan period up to 2050, and the overarching development principles that are set out in the Issue and Options are also supported. The range of evidence to date is considered to be robust and proportionate. The study covering Settlement Design Analysis is of interest and particularly current given the proposed changes to the NPPF currently out for consultation and the Levelling Up Bill.
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.
As with my previous submission, I agree with the 4 interconnected principles of tackling climate change, promoting wellbeing, improving connectivity and increasing biodiversity. However, these must clearly and effectively put at the heart of the new plan, and we must be bold, radical and ambitious in our vision. I feel there is much more to do with regards to achieving these objectives within the Plan. The South Warwickshire Local Plan should embed environmental sustainability, community resilience and wellbeing, biodiversity enhancement and recovery, and tackling the climate crisis (both with adaptation and mitigation) in its policies. The Plan should make the climate and biodiversity emergencies material consideration in all planning matters and these must inform all policies.
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.
Whilst Claverdon community understands much of the plan’s vision and objectives, it points out that the plan is unrealistic in duration given the rate of social and economic change. It has no milestones, and its scope is much too wide. Additionally, relative to infrastructure, separate elements are not integrated and rely entirely on private sector contributions. Decisions about land allocation must be taken at parish level, with top-down decisions kept to a minimum. Claverdon will ensure through its NDP that the minimum housing requirements are met in ways that are acceptable to Claverdon parishioners.
The Vision The Vision outlined in the Draft Plan is appropriate, as are the objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities. Delivery of the SWLP should be achieved in a sustainable way that responds to the climate emergency and meets the five overarching objectives. This will ensure that the right development will be delivered in the right places. The Strategic Objective A number of the Strategic Objectives identified in the Draft Plan are appropriate and should be translated into policy in the following ways. • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. The land in BTL’s control at Salford Priors is well served by existing infrastructure and be brought forward for development promptly. • Developing opportunities for jobs is an entirely appropriate objective. – There are a number of large villages in the plan area, such as Salford Priors, that have employment sites, services and facilities that create job opportunities. The plan should look to direct housing allocations to these locations to ensure that there is a workforce available. The SWLP should also look to support business in rural areas to help ensure the sustainability of the smaller settlements. • Delivering homes that meet the needs of all our communities. – Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. While the focus should be larger strategic allocation that can make meaningful contributions to the housing need, smaller allocations will still be required to allow smaller settlements to meet their needs. Salford Priors is well placed to deliver development in this regard. • Contributing towards a net zero carbon target – Development opportunities that can provide green infrastructure and have access to services and facilities by sustainable means, such as walking and cycling should be preferred locations for allocations. • Connecting people to places – This is an important objective that will increase and improve access by sustainable and active travel modes. Allocations that are located close to public transport opportunities, educational facilities, green spaces, and employment opportunities, or can provide these opportunities on site, should be preferred. • Protecting and enhancing environmental assets – The SWLP should look to support allocations that can provide significant biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.
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 bias towards development in the greenbelt. The reasoning for this prioritisation is that the greenbelt in the local area has a vital importance in preventing urban sprawl and keeping land permanently open. The protection of greenbelt should be given higher priority to protect the heritage and cultural assets.
No answer given
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.
2.1.1 The intention to develop a vision and strategic objectives that cover the period to 2050 is supported and is in accordance with Paragraph 22 of the National Planning Policy Statement, which states: “Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. 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.” 2.1.2 The longer-term framework is required to inform both plan making and decision taking. However, to accord with this approach, the SWLP should include consideration of the spatial strategy over this period, including future infrastructure requirements. 2.1.3 Paragraph 11 of the NPPF highlights the need for plans to promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. The vision and strategic objectives are too narrowly focused on the main settlements and not therefore compliant with Paragraph 11 of the NPPF. There is a need to ensure that a comprehensive vision for the plan area provided, which will in turn provide a more suitable basis for preparing LP2s for each district. A comprehensive vision that relates to the plan area as a whole should be one of the key drivers for preparing a Joint Local Plan. 2.1.4 The vision and strategic objectives as written are not therefore considered to have sufficient granularity.
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.
Q-V3.1 & 3.2 – Vision and Strategic Objectives I believe the Vision and Strategic Objectives should state that there will be no building on green belt land to ensure that we maintain open spaces and the separation of existing communities. You appear to have a clear bias towards development within the greenbelt. Any residential planning application to build new property in the green belt would guarantee application refusal.
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.
Issue V3: Strategic Objectives 3.2 One of the Council’s proposed strategic objectives is to meet South Warwickshire’s Sustainable Development Needs and in particular developing opportunities for jobs to build upon the strong and diverse economy. 3.3 We support the Council in identifying that developing opportunities for jobs should be a strategic objective of the plan.
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 the local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of the greenbelt should be given higher priority.
Whilst the JPC and the community in Henley support much of the vision and of the objectives put forward, these are undermined by three aspects of the plan. The plan is regarded as unrealistically long given the rate of social and economic change. The plan also has no milestones and is not SMART so that it is not anchored in current reality The very wide scope presented with 16 separate categories and over 100 questions is complex and fragmented. An even more serious problem is that whilst in the infrastructure section there is a strong emphasis on delivering associated infrastructure, the separate elements are not integrated at all. The development options in the plan are not predicated on the delivery of the necessary infrastructure and rely almost entirely on private sector contributions. Development will only be acceptable to the community in Henley if infrastructure needs are identified and committed prior to development commencing. Community opinion in the Joint Parishes is unanimous on this. Third as the merger of Stratford and Warwick councils did not proceed then the relevance of having joint visions and strategies is significantly weakened. In later sections, the JPC response will indicate how some of these issues might be dealt with. One principle which could be adopted from the beginning and possibly added to the vision is that of subsidiarity. If this was adopted any policy decisions or detailed land allocation decisions would be taken at the most local level possible, and top-down policies kept to a minimum. There is no evidence in the vision or objectives of the document that such a principle has ever even been discussed. The JPC is in the process of finalising its NDP and is looking to review once the housing requirement is known in order to control future development from a neighbourhood perspective. We will ensure through the NDP that the minimum housing requirement is met (or exceeded) to meet the Local Plan requirements but of a type, design and in a location that is acceptable locally.