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.
Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why 2.1. As set out in response to the Scoping and Call for Sites consultation, Catesby 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. 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 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. Catesby 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 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 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.” 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 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. 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.
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.
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 adopted Plan (37,500). In Coventry, it is likely that their future needs will not be accommodated in full within their area due to its tightly-drawn boundary and so support will be required from neighbouring areas within the wider market area, including South Warwickshire. Notably, the IO document makes reference to two options for contributions towards these wider needs; 5,000 and 10,000 homes. 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.
Q-V3.1 and Q-3.2 3. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 4. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
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.
Q-V3.1 and Q-3.2 5. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 6. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
Q-V3.1 and Q-3.2 5. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 6. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
Q-V3.1 and Q-3.2 3. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 4. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
Q-V3.1 and Q-3.2 3. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 4. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
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.
Coventry City Council considers that the Vision and Strategic Objectives are appropriate. The council supports the creation of well-planned, sustainable and economically prosperous developments in South Warwickshire which provide homes and jobs whilst also facilitating tourism, helping to tackle the causes of climate change and improving the natural environment.
MAOL is supportive of a Vision and Strategic Objectives that are focused on sustainable growth, which, reflective of the National Planning Policy Framework (NPPF), should be at the heart of the SWLP. Our client also considers that the ‘guiding principles’ generally represent sound aspirations for achieving greener, fairer and more connected growth. However, and insofar as our client’s interests are concerned, MAOL considers that the Vision and Strategic Objectives should provide a clearer statement on what will be achieved through the delivery of the SWLP and what South Warwickshire will look like in the future. Notably our client considers that: 1 The Vision and Strategic Objectives should clearly articulate that the delivery of strong and vibrant communities will need to be “balanced” with the protection and enhancement of the natural and built environment. This is one of the main challenges for South Warwickshire where the unique and high quality urban and rural environment, including significant heritage assets, distinguishes it from many other areas within the region. 2 Whilst the SWLP must seek to maintain this balance, development needs must also be met in a sustainable way. Given the importance of tourism in South Warwickshire, MAOL considers that the “development needs” must include reference to people who visit, as well as those who live and work in the Districts. 3 To provide a positive policy framework, the Vision should specifically “support growth”, including for tourism, provided it is sustainably directed and takes place at the right location at the right time. Or client considers that the Strategic Objectives should be developed to provide clarity on how they will be met by the SWLP. This could include a spatial dimension. There is also a disconnect between strategic objectives for growth and strategic objectives that link back to the guiding principles. For example, “Enriching the tourism potential” is under the heading “A well designed and beautiful south Warwickshire” but is clearly also linked to enhancing economic prosperity. This disconnect may be overcome by deleting the subheadings shown in blue text and explaining that the strategic objectives are not mutually exclusive but will work together to guide future development. With reference to specific objectives: 1 The objective at point 3 on “Developing Opportunities for Jobs” should provide a clear statement on how growth in employment opportunities will be delivered by the SWLP. This should include reference to: i Capitalising on South Warwickshire’s heritage assets to ensure a thriving destination fortourism/culture. ii “Supporting” rather than “Delivering” Opportunities for growth, including tourism, to reflect the role of the SWLP in providing a framework for future development. 2 The objective at point 7 on “Protecting and enhancing our heritage and cultural assets” should be a standalone strategic objective because it cuts across other strategic objectives. The wording needs to be developed to: i Explain that heritage assets and their setting will be conserved and enhanced in a manner appropriate to their significance. ii Acknowledge the close connection between the historic environment and economic activity. A great many of South Warwickshire’s business and jobs are dependent on, attracted to or based in historic buildings and spaces. iii Recognise the historic environment’s potential for investment in order to secure sustainable growth. iv Reference “conserving” rather than “protecting” as per the NPPF. 3 The objectives at point 8 on “Enriching the Tourism potential” should include reference to: i Supporting a longer season through the promotion of South Warwickshire as a year-round destination for tourism and recreation. ii Encouraging a tourism/cultural offer that is attractive to a wide range of age groups.
Issue V2; Vision. Overall the Chamber supports the proposed Strategic Objectives and Vision for the plan area. However we would wish to see more explicit reference to creating a policy framework that seeks to support the continued maintenance, development and growth of the local and sub regional economy. Currently this is lacking from the Vision statement. We note that in the previous consultation there was a call for any plan to “be proactive regarding economic growth “. (Ref p 20) V3; Strategic Objectives. (Ref Q-V3.1&2) It must be recognized and evaluated that all new policies will create potential cost impact and the proposed shift in emphasis towards a “Zero Carbon “ South Warwickshire is likely to come at some cost to both public and private sectors. Thus the Chamber would urge that all relevant proposals in this long-term strategy are fully evaluated and costed prior to their introduction for their impacts on the local economy.
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.
Yes, Hill Residential support the overall Vision and Strategic Objectives for the SWLP. In order to meet the ambitious Vision, it will be important to ensure growth is located in the most sustainable locations and align with the Vision as closely as possible. It is likely that these locations will be located within the Green Belt, specifically is those locations identified along rail corridors – such as Hatton.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? 3.1 No. 3.2 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 adopted Plan (37,500). In Coventry, it is likely that their future needs will not be accommodated in full within their area due to its tightly-drawn boundary and so support will be required from neighbouring areas within the wider market area, including South Warwickshire. Notably, the IO document makes reference to two options for contributions towards these wider needs; 5,000 and 10,000 homes. 3.3 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.
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.
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 We support the vision in principle, which seeks to create a prosperous, stronger and sustainable South Warwickshire. The vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8. Strategic Objectives We are 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 128 new homes in Alcester as well as significant open space in a sustainable location, would assist the South Warwickshire Authorities in achieving these objectives.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? 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.
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.
No answer given
Gladman support the vision which seeks to boost and diversify the local economy by meeting South Warwickshire development needs by ensuring the provision of appropriate infrastructure, in suitable locations, at the right time. Gladman consider that as the spatial strategy is yet to be determined, the Councils should be cautious of an extended plan period to 2050. The NPPF requires that plans look ahead a minimum of fifteen years from adoption and that Local Plans are reviewed every five years, therefore there are concerns that this extended approach leaves the Councils with few alternatives to respond to changing circumstances. If the Councils opt to continue with the extended plan period when the preferred spatial strategy is chosen, it is recommended that policies are suitably worded, and that a review mechanism is included in the Local Plan to ensure that the Plan can respond to any change in circumstances that may occur over the plan period.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? The Vision and Strategic Objectives for the South Warwickshire area are broadly supported. It is agreed that it would not be appropriate to include detailed visions for specific places within the South Warwickshire area within the Plan and that a broader vision is appropriate. It is considered that the housing target for the South Warwickshire Authorities should be included under the strategic objective for ‘Delivering homes that meet the needs of all our communities ’ in order to clarify the housing need of both current and future South Warwickshire residents. It is recommended that this is included within the objective. The objective should also make reference to meeting the unmet housing needs of adjacent Housing Market Areas. It is considered that the wording of the Objective in relation to Contributing towards Net Zero Carbon Targets should be re-worded. There should not be a requirement for all development not to cause a net increase in carbon emissions. This will have a significant impact on viability of some developments and does not take into account the potential for mitigation.
The Vision and Strategic Objectives for the South Warwickshire area is broadly supported. It is agreed that it would not be appropriate to include detailed visions for specific places within the South Warwickshire area within the Plan and that a broader vision is appropriate. It is considered that the housing target for the South Warwickshire Authorities should be included under the strategic objective for ‘Delivering homes that meet the needs of all our communities’ in order to clarify the housing need of both current and future South Warwickshire residents. It is recommended that this is included within the objective. The objective should also make reference to meeting the unmet housing needs of adjacent Housing Market Areas. It is considered that the wording of the Objective in relation to Contributing towards Net Zero Carbon Targets should be re-worded. There should not be a requirement for all development not to cause a net increase in carbon emissions. This will have a significant impact on viability of some developments and does not take into account the potential for mitigation.
On reading through the I&O and supporting documentation the emerging approach appears to focus on large-scale development(s) and the concentration of development and growth. This appears to be predicated on tackling climate change and carbon reduction yet the evidence supporting that approach is high level and shows there is relatively little difference in performance between the high-level options.The inevitable consequence of this approach is that it too readily dismisses the potential benefits of more dispersed growth, such as our client’s land at Chessetts Wood Road, Lapworth, which could reduce the number of larger scale developments required to meet needs as well as help spread the benefits of growth more widely, as well as meeting more nuanced needs and demands. The preparation of the local plan in separate Parts 1 and 2 reinforces this outcome because any potential development sites below the scale of strategic allocations and carrying forward of existing allocations and commitments seem to be bumped into Stage 2, ‘some years down the line’. This is illogical. The final version of the local plan is likely to be, and probably should be, an amalgam of several approaches, so it is critical that the shape of the emerging plan is not unduly restricted at this early stage in the process. In respect of climate change and carbon reduction it is suggested that the approach is too heavily based on the benefits of concentration which it is believed are becoming increasingly outdated through, as examples, the rapid shift to zero carbon vehicles and an increased propensity to work from home. Unfortunately, there is a significant risk that the approach in the emerging plan is potentially excluding reasonable options from proper consideration. We support V1, the overall vision as drafted in the consultation document, but wish to stress that a more dispersed pattern of development involving a smaller number of large-scale development could provide at least as good, if not better performance against the overarching principles as set out. In relation to V2, Vision for places, we believe it is fundamental that Part 1 of the plan should set out the scale and pattern of development across the plan area, establishing levels of growth into all local areas and this should take account of a reasonable level of dispersed growth and aspirations for improving services and facilities in smaller settlements and groups of small settlements for the reasons set out above. If Neighbourhood Development Plans are to be part of delivery, then it is important that realistic levels of growth, taking account of realistic opportunities identified through the Call for Sites are established. It would also be important that delays in bringing forward Neighbourhood Development Plans should not be used to delay the bringing forward of otherwise suitable development opportunities. In relation to the strategic objectives, while we are generally supportive, we have the following observations: Providing infrastructure in the right places: as drafted this appears to suggest the plan is to be led by infrastructure provision whereas the opposite should also apply. The provision of new or improved infrastructure should be plan-led. Developing opportunities for jobs: It is important that the plan provides a framework encouraging growth of businesses of all types and sizes and does not unduly focus on the needs of big business. Delivering homes that meet the needs of all our communities: This objective should also refer to market demand and aspirations as well as needs. This is more than simply the numbers of new homes.
There is in fact no specific “Sustainability objective” and certainly no objective.
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.