Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
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.
ISSUE V3: STRATEGIC OBJECTIVES Q – V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q – V3.2 to comment. There is in fact no specific “Sustainability objective” and certainly no objective.
Chapter 3 - Vision and Strategic Objectives Both Councils have declared a climate emergency. If this is to be more than just a ‘political slogan’ it must be the Golden Thread that runs through all the policies in the local plan. At present The Vision has five elements of which ‘A climate resilient and Net Zero Carbon South Warwickshire’ is just one. The other four elements are laudable but must be subordinate to that one key aim of Net Zero Carbon South Warwickshire. Unfortunately the ‘climate emergency’ is glossed over in many places in the document. Set out below are a few examples of a total lack of ambition: P21 the fourth element of the vision statement “A well connected South Warwickshire..” that “promotes active travel”. In view of the climate emergency should this not read, “gives absolute priority to active travel”. P29 Improving connectivity why does this not express an absolute priority for active travel? P67 “Many businesses are reliant on the strategic road network for transporting products, and realistically this is unlikely to change significantly in the near future.” This certainly won’t change unless there are ambitious policies in place now to ensure change happens and as rapidly as possible. P153 penultimate paragraph “If there is a gradual move away from residents relying on the use of a private car….” This must not be a question of “if” but how fast can change occur. The above are just four of countless examples in the document where the wording does not reflect the ‘climate emergency’. It is essential that not only the policies drive this key objective but the wording of the whole document reflects the absolute priority of the need to respond to the climate change emergency.
1. The Vision and Strategic Objectives The TTG supports the Vision and Strategic Objectives given in Chapter 3: A climate resilient and net zero carbon South Warwickshire A well-designed and beautiful South Warwickshire A healthy, safe, and inclusive South Warwickshire A well-connected South Warwickshire A biodiverse and environmentally resilient South Warwickshire However, none of these Objectives mention people. The document states that rephrasing has been done to make the Vision more people-focussed, but this is not apparent. The TTG believe an additional Objective should be added which captures the central requirement for the plan to improve the quality of life for those living and working in South Warwickshire, and that this should be the first Objective.
Vision and Strategic Objectives 3. The HBF support the vision of the Plan to meet South Warwickshire sustainable development needs. The recognition that this should include planning for some of the unmet needs of neighbouring authorities is welcomed. The key aim of the plan to provide homes is supported. 4. Supporting the growth of new homes is an important Strategic Objective. Whilst the importance of infrastructure in delivering housing is noted, the infrastructure required to support growth may be funded in a variety of ways, including public funding and grants, not only through developer contributions. Development is only required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision.
Q-V3.1 and Q-3.2 4. 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. Braemar 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. 5. 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 & 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 & 3.2 – Vision and Strategic Objectives: there is still a national presumption that development will not be undertaken on greenbelt land. This is not reflected in the Vision and Strategic Objectives. The current wording appears to do the opposite. It should state that: 'avoiding development on greenbelt land will be prioritised at all stages of the plan development'. We consider this is of vital importance because the green belt, generally but particularly in this area, plays a key role in (1) protecting the environment and cultural landscape, both now under great pressure partly through the development of HS2 and (2) in preventing urban sprawl (especially the creeping sprawl which appears to be occurring in and around Cubbington. The other effect of privileging the protection of the green belt is that it forces planners and developers to think more carefully about urban regeneration, and using brownfield sites for housing development. Far better to concentrate housing in already built up areas than allowing low density urban sprawl to engulf rural areas.
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 on land such as that at Holly Farm Business Park, 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. The land at Holly Farm Business Park is ideally suited to such an approach. 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.
Q-V3.1&3.2 - Vision and Strategic Objectives: I believe that the Vision and Strategic Objectives should definitely state that development on greenbelt will be avoided as a priority at all stages of the plans development. There is a heavy bias towards the development of the greenbelt. Greenbelt is vital to all of us for food production, wildlife and the human population in our fight to stop climate 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.
Vision and Strategic Objectives: 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.
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. Chapter 3: Vision and Strategic Objectives – South Warwickshire in 2050 Issue 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, Rainier 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. Rainier 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.
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.
Q-V3.1 & 3.2 – Vision and Strategic Objectives: 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”.
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, Rainier 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. Rainier 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.
The declared 5 overarching Principles are supported: Climate resilient and net zero carbon, well-designed and beautiful, healthy, safe and inclusive, wellconnected, biodiverse and environmentally, resilient. The objective that the plan is to be environmentally led with appropriate infrastructure for new development is welcome. Conversely the ‘call for sites’ process, which has become somewhat repetitive, tends toward ‘developer led’ outcomes. As the plan proceeds, it is important that concept of the balance in favour of environment and community leading is not eroded towards being ‘developer led’. It must take into consideration true local influences.
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 (and 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.
Objectives do not give enough weight to the gravity of climate change; there is an over projection of housing needs and developments, and the wrong areas are identified for development. Infrastructure is inadequately assessed with insufficient priority given to green options. There is no real vision of how our world will look in 20 years time, so current strategies outlined will be be 20 years out of detate, assuming their time scale has not fallen behind or costings become excessive. HS2 serves as an example of what can go wrong with misdirected and poorly evidenced strategy and vision. The Green Infrastructure Study in use is already 10 years out of date.
2.1. As set out in response to the Scoping and Call for Sites consultation, Rainier 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. Rainier 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.
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). The respondent would 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:” With regards to V3: Strategic Objectives, the role that all current settlements can play in meeting housing needs should be recognised. 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).
Bullet points one and five of the Vision objectives on page 21 of the SWLP (January 2023) state that: • “…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 biodiverse and environmentally resilient South Warwickshire – strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire…” Lockley Homes response: A climate resilient and Net Zero Carbon South Warwickshire Whilst we support the principles behind the emerging Vision policy approach and the need to adapt to the effects of climate change and work towards achieving a Net Zero Carbon South Warwickshire it is important that any climate resilient and Net Zero Carbon objectives and targets included within the emerging SWLP are both realistic and capable of being delivered in accordance with guidance in paragraphs 16 (indent b) and 35 (indent c) of the Revised National Planning Policy Framework (NPPF) (2021). Paragraph 16 (indent b) is perfectly clear that: “…Plans should: (indent b) be prepared positively, in a way that is aspirational but deliverable…” NPPF (2021) paragraph 35 (indent c) confirms that: “…Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: (indent c) Effective – deliverable over the plan period…” Focusing on the house building development industry, as stated above, whilst we support the principles behind the emerging Vision policy approach and the need to incorporate climate change mitigation features within new development proposals, incorporating these types of features can often significantly increase the financial build costs for new build residential schemes. At a time when the construction sector is already experiencing rapid and significant price increases in the financial costs of building materials, and increased labour costs. We would therefore advise that a pre-cautionary policy approach is therefore taken by the LPA’s preparing the emerging SWLP in relation to this issue, given the severe adverse set of economic circumstances now facing the local area, for reasons already set out within this wider Representations Statement document. Given the above issues, it is important to ensure that a less financially onerous planning policy regime is placed on housing building development industry going forward within the SWLP (2023) to help support the future financial viability of new housing development sites during the very fragile post-COVID-19 economic recovery. Lockley Homes maintains its view that its position on these matters is supported by guidance within paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The rapid and significant shift in adverse economic circumstances now facing the Local Plan area, should now be shaped into a heavily revised planning policy approach being taken forward by the LPA’s within the emerging SAP for the reasons highlighted above. A biodiverse and environmentally resilient South Warwickshire Lockley Homes is a developer of very high-quality new build luxury homes, and as a developer we take our environmental responsibility very seriously, and where opportunities exist, we are keen to support biodiversity within our new residential development schemes. We therefore suggest that the Vision and Strategic Objectives of the emerging SWLP could be significantly strengthened and improved from a nature conservation new habitat creation planning policy perspective, by emphasising the important role that new housing development sites/ proposals can play in helping to promote and deliver new on-site nature conservation habitat features, integral for helping to support the delivery of Biodiversity Net Gain (BNG) across South Warwickshire. These issues are already considered in further detail within this wider Representations Statement.
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.
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
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.
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.