Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
NO. The emphasis is on constant expansion. The sheer quantities of more and more people concentrated into a town (Leamington Spa, in particular), with no current infrastructure to support it. WE already have expansion around South Leamington, with the new estates of identikit houses, and the large student population. Building on large countryside GREENBELT areas is not acceptable. People wish to enjoy open countryside, what is more, they need it. This will not be compensated by the small parks/playing fields added to new estates. The large number of new houses do not have adequate hardens either. Green space is vital to wellbeing.
Most of the objectives seem to be vague and aspirational and cover matters that are largely out of the remit or control of the respective councils. There is as has been suggested above a complete disconnect between the aspiration and what has historically been achieved. There are references to "Providing infrastructure in the right place at the right time" and yet nowhere in the plan is there any kind of transport policy or proposals. Where, for example, are the provisions or plans for new or improved bus routes, proper and additional parking facilities in the town centres, adequate parking or drop off facilities at the railway stations. The only reference to parking is the proposed conversion of existing car parks to housing which ignores the reality that the centre of Leamington Spa, is being decimated by the move of shops to cheaper out of town retail parks which people can drive to do their shopping. It is utterly unrealistic to imagine that anything other than a small minority will ever cycle into town town centres to do their weekly (or any) shopping or go to restaurants or entertainment at night. Having lived in Richmond in London we were able to observe first hand the utter waste of £26million spent in Kingston upon Thames on cycle lanes (lauded as a mini Holland) which for most of every day are barely used and never in inclement weather. You refer to "Creating attractive places - Focusing on the design of new development to create great places, spaces and buildings that are of a high quality and cater for the needs of all users and which respect the setting of our many settlements." and yet anyone driving into Leamington from the south can only be appalled and depressed by the swathes of identikit housing estates that have all presumably been passed and approved by the planning departments of the very same councils. Nowhere is the any evidence of design let alone good design, open spaces or community facilities - simply a race to the bottom to cram as many houses as possible on to each acre of land. We need a plan with real proposals and policies that can be implemented not "woke" platitudes.
No/Don't know Most of this is Motherhood and Apple Pie – ie difficult to argue with, in an ideal world. However we note that only 25% of respondents agreed with your approach to the Vision, clearly many thought Visions should be the remit of NDPs (and we would probably agree!). Does the corollary apply? – ie 75% did not agree? We also note that only 53% of respondents agreed with the Strategic Objectives – disappointingly low for such an important element…
The Vision 2.1 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 2.2 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 [land east of Banbury Road, Southam], which has the potential to deliver up to 200 new homes in Southam as well as significant open space, a community orchard and allotments in a sustainable location, would assist the South Warwickshire Authorities in achieving these objectives.
3. HLM consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and HLM consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. 4. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
4. HLM consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and HLM consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. 5. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
3. Yes, MacMic Group consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities and MacMic Group consider it would be more appropriate to reference meeting unmet needs from the wider Housing Market Areas. 4. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Greater Birmingham and Black Country Housing Market Area with a strong interrelationship and connectivity, and therefore should not be excluded.
The objectives are aspirational and lack detail. New developments will always increase carbon emissions when taking the whole supply chain into account. Instead of satisfying an unscientific aspiration by planting a forest (carbon offset plan) in some distant unsuitable place, why don’t you opt instead for leaving existing green belt land alone, and look to brown field sites? If the whole carbon cost was taken into account, the carbon offset plan would need to be many times greater than most envisage. The carbon offset ‘increase in biodiversity’ cannot be achieved by overpopulating green belt areas with more building and works – wildlife need quiet spaces away from human population and pollution if they are to thrive. Another aspiration lacking detail is “providing infrastructure in the right place at the right time” and “design of developments to…cater for the needs of all users”. If you want to “respect the setting of many settlements” there should be no relaxing of current green belt rules – what is the point of these protections if they can be swept away with new proposals? Where the detailed quality plan for sewerage investment is, schools and health services & hospitals which in parallel need a coherent funding plan for operational costs? Developers are only interested in building low cost/ high profit houses to take advantage of the current demand and are not interested in being held to account by local government to fund their investment shortfalls. More people in green belt areas will lead to congestion, pollution and lack of capacity in facilities for existing residents, eroding long established green spaces.
Bruton Knowles supports Stratford-on-Avon and Warwick District Councils preparing a Joint Local Plan. Working together will help both Councils develop their vision and progress development proposals.
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 proposed planned development. It would appear that this is not currently the situation with a heavy and unjustified bias towards development in the greenbelt. Greenbelt in local areas 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 to avoid turning precious greenbelt land into mini towns by attaching to small villages and hamlets.
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.
Terra consider the Vision and Strategic Objectives for the SWLP to be appropriate in principle, with further commentary as below: • Providing infrastructure in the right place at the right time Terra support ensuring that the right infrastructure is secured at the right time. Planning Obligations and CIL provisions should be used to secure this. • Delivering homes that meet the needs of all our communities Terra support the ambition to deliver housing of a mixture of types, sizes and tenures, to cater for a range of needs. Land at Plough Lane, Bishop’s Itchington is available, suitable and deliverable for residential development. Additionally, the option of providing an all-affordable scheme in this location is achievable, as Terra believe there is a demand for this type of accommodation in this location. The allocation of the site for housing in the SWLP would also help to support the wider ambitions of theSWDP. Terra consider that caution should be taken in promoting self-build and custom-build housing on general housing sites, as such housing can complicate and delay the delivery of much needed market and affordable housing. There should be flexibility as to whether self-build or custom-build housing is provided on qualifying sites and should be a matter for detailed consideration between applicants and the Councils at the planning application stage. • Contributing towards Net Zero Carbon targets Terra support the Objectives of ‘contributing towards Net Zero Carbon targets’. Terra is affiliated with Hayfield Homes, a West Midlands Housebuilding business who have committed to providing betterment to current Building Regulations in all their new developments. Hayfield look to achieve an EPC ‘A’ Energy Efficiency Rating on all their developments – something which only 2% of all new homes in the UK currently achieve. • Creating attractive places Terra support the principles of creating attractive places. It is important that new development is sustainable as well as being responsive to its surrounding context. New development should improve areas for both current and future residents. • Protecting and enhancing our heritage and cultural assets Terra support the general principle of protecting and enhancing heritage assets. However, it should be recognised that the approach for achieving this will vary dependent on the specifics of each case. Sites should be assessed on the basis of the specific heritage asset’s significance, rather than taking a blanket approach.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Yes, Terra generally agree that the Vision and Strategic Objections are appropriate. However, Terra would ask the Councils to consider the below points: • Developing opportunities for jobs The COVID pandemic highlighted that there is a need for economic diversification within the area, particularly for Stratford-on-Avon. Terra agree that developing opportunities for jobs should be a priority, and that the South Warwickshire area has access to a range of transport corridors which can support this diversification. However, Terra consider that the Councils will need to ensure that economic development is carefully balanced with a delivery of residential development. The M40 corridor, and land to the east of Junction 12 in particular, offer a good opportunity to capitalise on the existing travel corridors and employment developments. Within the Core Strategy, Stratford-on-Avon allocated a New Settlement at Gaydon/Lighthorne Heath along with an expansion for the Jaguar Land Rover (JLR) campus. The allocation sought to provide 100ha of land for the expansion of JLR as well as 4.5 ha for the expansion of Aston Martin Lagonda (AML), securing a large amount of employment land along with 3,000 homes to facilitate the new settlement. This capitalises on the existing employment opportunities at JLR and highlighted the importance of this industry in the authority. From the Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA), it is clear that the highest need for General Industrial space is within Stratford-on-Avon. The HEDNA makes recommendations for meeting the Strategic B8 need within Chapter 11, which should be based on the following key locational considerations: • Road accessibility • Power supply • Proximity to Rail Terminals • Labour availability • Neighbouring activities Land east of Junction 12, M40 is well located to the motorway at Junction 12 of the M40. This Junction currently serves traffic to and from the JLR campus and is well place to continue to serve additional growth within the area. Additionally, it is in close proximity to readily available labour from the proposed new settlement at Gaydon/Lighthorne as well as the existing surrounding settlements(Lighthorne, Lighthorne Heath, Gaydon, and Bishop’s Itchington) and proximity to larger settlements, such as Birmingham. Land east of Junction 12, M40 would be suitable for providing a mixed use new settlement with a employment and residential provisions as well as other supporting infrastructure which capitalises on previous growth strategies secured in the Core Strategy at Gaydon/Lighthorne. This aligns closely with the Councils’ aspirations for employment focused growth. The HEDNA envisages that there will be a greater potential role for South Warwickshire in delivering strategic B8 growth that has been seen historically1. This means that the Council will need to think carefully as to where new employment growth will be located to ensure it is delivered in the most sustainable way. • Delivering homes that meet the needs of all our communities Terra support the Councils’ aspirations to support housing growth through the SWLP and ensuring that residential development provides a diverse mix of homes. The November 2022 Coventry &Warwickshire Housing & Economic Development Needs Assessment (HEDNA) highlighted that the population of Stratford-on-Avon has grown by 9.6% since the 2011 census data was collected, which is the third highest rate behind Rugby (10.1%) and Coventry (19.7%), therefore there is a clear requirement for additional housing within the authority. As both Stratford-on-Avon and Warwick are constrained by Green Belt, it is sensible to address housing need through a Joint Plan particularly as the authorities are closely linked.
The Vision for South Warwickshire includes five overarching principles which will determine how development will be delivered. The CEG and Mixed Farms proposals for South East Stratford-upon-Avon are considered against each of these principles to demonstrate how the site can contribute to achieving the Vision: • A climate resilient and Net Zero Carbon South Warwickshire – The proposed development at the site will contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking advantage of two key attributes, size (strategic growth) and location (on the edge of one of the most sustainable settlements in South Warwickshire), the site off Banbury Road will include numerous measures and strategies to encourage local living and support the initiative of 20-minute neighbourhoods. • A well-designed and beautiful South Warwickshire – Development at the site will provide for a mix of housing types and tenures to encourage diverse and intergenerational communities; it will deliver both physical and social infrastructure to benefit existing and future residents and support the growth of the town as a whole; create beautiful homes with gardens that combine the best of town and country to create healthy communities; and retain and enhance existing landscape features including hedgerows and tree belts . • A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable garden community, providing both a range of housing to meet identified needs, and community facilities, focused around a mixed use centre with primary school, convenience and community facilities, mobility hub and potential for live/work community hubs supporting both the development and surrounding villages. This will be set within a substantial green infrastructure network. • A well-connected South Warwickshire - The site will take advantage of the excellent existing facilities for travel choice into Stratford-upon-Avon by active travel and public transport modes and enhance these routes where needed through careful design and investment in sustainable infrastructure which will promote longevity. This means that the site can place walking and cycling at the highest priority, followed by travel by public transport, and develop a community where there is “little” reliance on the private car. • A biodiverse and environmentally resilient South Warwickshire – Biodiversity net gain will be taken fully into account in the proposals for the site. The conceptual framework for the site will retain existing landscape features including hedgerows and tree belts and, in addition, shows a considerable biodiversity parkland, public parkland, and a network of swales
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.
2.2 The Vision for South Warwickshire includes five overarching principles which will determine how development will be delivered. The CEG proposals for Westwood Heath are considered against each of these principles to demonstrate how the site can contribute to achieving the Vision: • A climate resilient and Net Zero Carbon South Warwickshire - The proposed development at the site would contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking advantage of two key attributes, size (strategic growth) and location (adjacent to Coventry and the University of Warwick and the associated employment) development of the site can include numerous measures and strategies to encourage local living, reduce the need to travel and support the initiatives of 20-minute neighbourhoods. This will help the South Warwickshire economy achieve its aspirations for delivering a net-zero carbon economy through the reduction in emissions. This transition will be further supported through the delivery of modern, energy efficient homes and commercial premises of which CEG have a clear track record of delivery. • A well-designed and beautiful South Warwickshire - Westwood Heath is strategically well located to deliver a well-designed neighbourhood that respects the existing beauty and heritage of the area. It is not located within any local landscape designations and whilst situated in the Green Belt, circa 30ha of this is identified as safeguarded land through policy DS21 of the Warwick Local Plan therefore the principle of it being released to meet longer-term strategic development needs has been established. Furthermore, the identified alignment of HS2, provides a new logical Green Belt boundary for the Coventry urban area, and alongside other measures such as proposed green infrastructure corridors, will help to maintain separation with Kenilworth and thus ensure that the development does not contribute to settlement coalescence. Moreover, there are no historic assets located within the site and a limited number in the immediate area. • A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable garden community, providing both a range of housing to meet identified needs, and community facilities, focussed around a mixed-use centre with primary school, convenience and community facilities, sports provision and potential for live/work community hubs supporting both the development and diverse economic uses in the surrounding area. This would be set within a substantial green infrastructure network that will encourage active travel and contribute to enhanced health and wellbeing. • A well-connected South Warwickshire - The site will be integrated and connected with Coventry and the University of Warwick including through a potential green travel corridor providing a sustainable link across the area, supporting walking, cycling and enhanced public transport. The site will also be able to link to existing public transport connections (including access to Tile Hill station). These infrastructure improvements, including an improved southern access to The University of Warwick will align with the significant transport improvements already being implemented in the area, including the improvements at the A46 Stoneleigh Junction and the new crossing of the A45. This corridor also has the potential to integrate with wider connections to the HS2 interchange at Arden Cross. This will further ensure the area is well-connected and realises the benefits of infrastructure investment, ensuring strategic growth is suitably aligned. • A biodiverse and environmentally resilient South-Warwickshire - Biodiversity net gain will be incorporated into the proposals for the site. The conceptual framework for the site will feature and cohesive ecological network that retains existing landscape features integrated with the existing local wildlife sites.
Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Subsequent to the 2021 Scoping Options consultation, St Philips supports the changes to the overarching vision in regard to making clearer the role of housing and jobs to play within South Warwickshire. St Philips also welcomes the acknowledgement of the need to accommodate the unmet needs of surrounding authorities as stated within the vision. This is considered to be legally compliant in accordance with National Planning Policy Framework (NPPF) paragraph 24 which states: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” As discussed in detail below, there is a large quantum of development required throughout South Warwickshire in order to meet both the social and economic needs of the administrative area as well as the neighbouring authorities, such as Coventry and Birmingham. Therefore, St Philips recommends that a suitable quantity of land should be assessed to ensure that the development needs can be met in the most sustainable locations. This would accord with NPPF paragraph 8b in terms of achieving the social objective of sustainable development, which states the following: “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. Additionally, in terms of the presumption in favour of sustainable development, NPPF paragraph 11b states that: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” In consideration, St Philips also supports the strategic objective that seeks to deliver the right quantity of homes in order to “meet the needs of all of our communities”. With regard to the Duty to Cooperate and the unmet needs identified within Birmingham and Coventry, St Philips considers that reference should also be made within this strategic objective towards meeting the unmet needs of neighbouring authorities. Although, it has been acknowledged and welcomed that the overarching vision makes reference to meeting the unmet needs within surrounding authorities.
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. 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 in line with what I understand is a key government aim.
Yes - the focus for the Vision is considered to be appropriate. It is appropriate for the focus in the Vision to be on the delivery of homes and jobs and to identify that this will include, where appropriate, unmet need from neighbouring authorities. The 5no. elements of the Vision are considered to be relevant and valid. The site BDWH is promoting to the north west of Warwick Parkway Railway Station is an example of a site that will fully address each of the 5no. main areas set out within the collective Vision. However it is noted that the vision is set out up to the year 2050. The current National Planning Policy Framework (NPPF) para. 22 states that strategic policies should look ahead over a minimum 15-year period from adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055.
Lapworth Parish Council does NOT consider the vision and strategic options are appropriate. The first paragraph reads as a list of disparate items included as a result of the previous consultation rather than as a vision to aspire to. In particular, the first paragraph fails to articulate what is special about South Warwickshire or why it needs protecting, conserving and enhancing as a place to live and work. We consider it is more important to explain that South Warwickshire, known all over the world for its cultural and historic importance, is the green lungs and heart of the Midlands rather than saying it will meet unmet housing need from elsewhere. There needs to be more emphasis on why the area is special – small historic villages surrounded by open farmed countryside with ancient woodland and hedgerows linked by canals, railways, and narrow winding roads leading to larger market towns. The green belt helps underscore the character, identity and distinctiveness of South Warwickshire. If the Green Belt is to be reviewed, Lapworth Parish Council would like to be involved and consulted. We would also like to draw attention for more explicit reference to include people of all ages, genders and abilities, eg there is very little about young people or differently abled people included in the document. We note also that there is a marked disparity in many ways between the very rural areas and the towns of South Warwickshire and we would like to see a strategic commitment made to redress this imbalance wherever possible. We suggest the following rewording of the vision statement: South Warwickshire is the cultural heart and green lungs of the Midlands and its distinctive identity and appearance is recognised and cherished across the World. The vision is to meet South Warwickshire's sustainable development needs to 2050, while responding to the climate emergency. The plan will provide homes and jobs, 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: • A climate resilient and Net Zero Carbon South Warwickshire – adapting our existing buildings and infrastructure to the effects of climate change and mitigating against its causes across while avoiding any further damage that might arise from development • A well-designed and beautiful South Warwickshire – creating spaces where people of all ages and abilities want to be, which complement, respect and reflect the existing beauty, openness and heritage of the area • A healthy, safe and inclusive South Warwickshire – enabling everyone throughout the whole area to enjoy safe and healthy lifestyles with a good quality of life • A well-connected South Warwickshire – ensuring that new and existing development is physically and digitally reflects its position as gateway to the Midlands from the North and South. New development will be designed to be in accessible locations and promote active travel • A biodiverse and environmentally resilient South Warwickshire – strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire
Subsequent to the 2021 Scoping Options consultation, St Philips supports the changes to the overarching vision in regard to making clearer the role of housing and jobs within South Warwickshire. St Philips also welcomes the acknowledgement of the need to accommodate the unmet needs of surrounding authorities as stated within the vision. This is considered to be legally compliant in accordance with National Planning Policy Framework [NPPF] paragraph 24 which states: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” 2.3 As discussed in detail below, there is a large quantum of development required throughout South Warwickshire in order to meet both the social and economic needs of the administrative area as well as the neighbouring authorities, such as Coventry and Birmingham. Therefore, St Philips recommends that a suitable quantity of land should be assessed to ensure that the development needs can be met in the most sustainable locations. This would accord with NPPF paragraph 8b in terms of achieving the social objective of sustainable development, which states the following: “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. 2.4 Additionally, in terms of the presumption in favour of sustainable development, NPPF paragraph 11b states that: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” 2.5 In consideration, St Philips also supports the strategic objective that seeks to deliver the right quantity of homes in order to “meet the needs of all of our communities” (IO, page 23). With regard to the Duty to Cooperate and the unmet needs identified within Birmingham and Coventry, St Philips considers that reference should also be made within this strategic objective to meeting the unmet needs of neighbouring authorities. Although, it has been acknowledged and welcomed that the overarching vision makes reference to meeting the unmet needs within surrounding authorities.
3.2 IM agrees with and supports the overall vision and strategic objectives for the SWLP. In order to meet the ambitious vision set out in the Issues and Options document, it will be important to ensure growth is located in the most sustainable locations and aligns with the vision as closely as possible. 3.3 The priority for such growth should be those sites which were safeguarded in the adopted WDC Local Plan (2017). Such sites have been determined through large scale public consultation, and by an examination by an Inspector, to be suitable for development and removed from the Green Belt.
3.2 Yes, Taylor Wimpey supports the overall Vision and Strategic Objectives for the SWLP. 3.3 In order to meet the ambitious Vision, it will be important to ensure growth is located in the most sustainable locations and align with the Vision as closely as possible. It is likely that these locations will be located within the Green Belt, such as areas to the north of Leamington.
We consider that the inclusion of the following wording “avoiding any further damage that might arise from development” in the vision principle ‘A climate resilient and Net Zero Carbon South Warwickshire’ is not appropriate. The National Planning Policy Framework (‘NPPF’) (July 2021), requires plans to take a proactive approach to mitigating and adapting to climate change. There is no reference to avoiding any further damage. The wording highlighted would also conflict with the objectives of the Plan to meet the development needs of South Warwickshire. Development may give rise to impacts which may be unavoidable however national policy only requires impacts to be mitigated and adaptation to occur. If the Plan continues to include this reference “to avoiding” it will be inconsistent with national policy and fail the test of soundness. We believe that the specific principle should be amended removing the wording, “avoiding any further damage that might arise from development.”
No answer given
We agree with the overall Vision and Strategic Objectives. The Vision provides a clear framework for strategic sustainable growth over the Plan period (to 2050). However, in combination, the Vision and Objectives are also broad enough to respond to change and provide flexibility, which is a vital requirement in ensuring that the Local Plan can respond to change and remain relevant over the course of the Plan period.
: 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 areas is of vital importance in preventing urban sprawl (especially creeping sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt, and especially farmland, 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-S3.1 - Urban Capacity Study: We feel that the use of Brownfield sites should be prioritsed and that where Brownfield development is not possible, then development should not occur in Greebelt land. In particular, we do not feel that the “call for sites” approach sufficiently prioritises the identification of non greenbelt brownfield or greenfield sites, these should be actively sought out. I feel the consultation document is heavily biased towards development in the greenbelt North of Leamington and this should be avoided, especially when only 1/3 of the plan area is greenbelt. I feel that appropriately planned development from the outset will avoid the need for greenbelt development in “exceptional circumstances”. Greenbelt development must be avoided as an absolute priority.