Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? National Highways agrees that the vision and strategic objectives are appropriate for this proposed local plan.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? 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 130new homes in Long Itchington as well as significant open space in a sustainable location, would assist the South Warwickshire Authorities in achieving these objectives.
This point should include reference to the blue infrastructure as well as the green. ‘Protecting what already exists and maximising opportunities for enhancement including improvements to the blue/green networks through tree planting, biodiversity initiatives and protection of the watercourse corridors.
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.
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.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why Lone Star Land Ltd 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 July 2016 and September 2017 respectively. The Vision and Strategic Objectives will set the foundation for the development of policies that will shape the growth and future of South Warwickshire and basing them on a sound set of objectives will ensure that both Councils are able to deliver aspirations across the full range of services which they provide in a comprehensive and coherent manner. A sound set of Objectives will allow the Local Plan to fulfil the requirements of NPPF paragraph 20 by providing for, inter alia: housing development plus appropriate infrastructure and the conservation and enhancement of the environment in an effective manner. Concurrently, it will also ensure that planning combines with the Councils other delivery partners to deliver the Vision and Strategic Objectives outlined within the plan. 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 difference must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the South Warwickshire Local Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Lone Star Land Ltd 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 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.” 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 into the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. The Vision places significant emphasis on responding to the ‘climate emergency’. This principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions, but 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 within the plan period.
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.
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.
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.
Q-V3.1+ Q-V3.2 As set out in response to the Scoping and Call for Sites consultation, Corbally 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. Corbally 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 on to 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 several 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 in South Warwickshire.
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 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. Enriching the tourism potential: This objective should be clear that supporting and enhancing tourist infrastructure will be supported.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
The vision and strategic objectives are idealistic. There is no detail on how these are to be achieved. For instance, “ensuring new development does not cause a net increase in carbon emissions” is highly unrealistic even if there is significant change in new housing policy. How would this be achieved through the whole supply chain? Steel and concrete are carbon intense materials, trucks will be needed to deliver building materials, trees and green land will be destroyed to make way for housing. Even attempts to make the houses sustainable such as the production of heat pumps, creates carbon in the supply chain as well as the fall-out from mining for the components. Creating new developments causes significant carbon emissions whether we like it or not. Of course there are ways to minimise this but to suggest development will be carbon neutral is green washing even with proposed use of off-setting schemes which are often not effective. Comments such as “providing infrastructure in the right place at the right time” and “design of developments to…cater for the needs of all users and which respect the setting of many settlements” sounds good but is not followed through in the rest of the plans. To respect current settlements there would be no talk of relaxing current green belt rules or overriding current neighbourhood plans, and there would be emphasis on ensuring the infrastructure is present or developed to support the planned growth in communities. At present there is no obvious plan/funding to provide infrastructure and this seems left to private developers who have a poor track record in providing such facilities and may not have the correct information regarding what is actually needed. “A healthy, safe…Warwickshire – enabling everyone to enjoy safe and healthy lifestyles and a good quality of life” will not be possible if there are not enough school places/GP surgeries, increased congestion and pollution on our roads and no substantial green spaces left. The plan to achieve a net increase in biodiversity across South Warwichshire is at odds with the extensive plans for development and current strategy to relax green belt rules. We are extremely concerned that the Plan doesn’t include the 20% biodiversity net gain that the Warwickshire Wildlife Trust advocated for, that the Green Infrastructure study is now 10 years old, that your growth and new settlement locations don’t consider local biodiversity and river habitats and you don’t go far enough in tackling the climate emergency. So whilst superficially the vision and objectives look good we find them to be unrealistic and disingenuous, without proper backing in the rest of the plans.
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.
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 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.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. The reasoning for this is that the greenbelt in local area has a vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
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.
We believe that the Vision and Strategic Objectives should specifically state that: 'avoiding development on greenbelt land will be prioritised at all stages of the plan development'. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. Our reasoning for this is that the greenbelt in the local area has a vital importance in keeping land permanently open so protecting the environmental and cultural landscape, and preventing urban sprawl (especially creeping sprawl towards Coventry). Protection of the Green Belt will also assist in urban regeneration by encouraging the recycling of derelict and other urban land. In our view 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.
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.
Q-V3.1 & 3.2 Vision & Strategic Objectives The favouring of Greenbelt land for future development instead of Brownbelt opportunities would result in the area of greenbelt being nibbled away, inviting the opportunity of spreading urbanisation to combine into larger areas. Protected greenbelt is a vital way to prevent the loss of forestry, vegetation and rural lifestyle and the Vision and Strategic Objectives should provide protection to avoid this happening.
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.