Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability

Infrastructure should be prioritised and looked at holistically. Not just a zoomed in look at each individual development. The mess around Europa Way is a perfect example. Two lanes funneling down into one lane. Literally what use is that? People now queue two abreast instead of a single queue. That isn't progress, that's a missed opportunity. Like the Tollbar Island debacle. Make that quicker and guess what? The TGI island was then a bottleneck and they have had to deal with that. Similarly along Europa Way, you still have bottlenecks because the infrastructure hasn't been looked at holistically. Bishops Tachbrook can't have a set of traffic lights making the right turn from Mallory Road onto the Banbury Road safer even though that's 1500+ houses trying to get out. But Mallory Grange gets a set of lights onto the Tachbrook Road for less than 500? And because there's more developments on Europa Way and Harbury Lane the traffic towards the motorway the traffic going past that junction from the right is increasing. As the Gaydon developments are populated the traffic from the left increases. But because these developments don't show the knock on effect on Bishops Tachbrook residents requests for traffic lights get ignored. Infrastructure should be delivered before any homes are occupied. The school off Harbury Lane should have been built alongside the houses and opened to allow the families decent access to a local school. Instead families are left without a local school (Whitnash is NOT local to Harbury Lane and Warwick Gates) and infrastructure mistakes made with old Warwick Gates have been repeated for new Warwick Gates!

No answer given

Any future development must only take place with Climate Change the premier criteria. Walking, cycling, public transport must be the prime driver in reduction of CO2 The 15 min town / development attached to existing settlements will both improve residents' lives and help control CO2 emissions

Key infrastructure must be shown to be viable, financing secured and ideally delivered in advance of development. Mitigation is not sufficient.

There are considerable challenges in terms of existing infrastructure - water, utilities, broadband in South Warwickshire and Lapworth Parish is a good example. Much of the area is not connected to main sewers and storm drains are poor or inadequatly maintained eg the closure of the Old Warwick Road due to flooding. Climate change is leading to more frequent 1 :100 year floods and a programme of infrastructure improvement throughout the area should be aimplemented over the next 30 years over and above any infrastructure required by new developments. Much of rural SW outside the towns relies on fossil fuel for heating and this makes Net Zero Carbon reductions a challenge. The plan refers in part to a "stick" approach to reducing reliance on fossiil fuels eg the suggested option below to require any application for planning permission (even the most minor such as a dropped kerb) to include a full net zero refit to achieve at least category C energy efficienty but fails to refer to any "carrot" schemes. in other areas County and District Councils have taken the lead in energy generation eg Telford and Wrekin solar farm but no provision is identified for this. We are unable to comment on the deliverability of the proposals as this lies outside our expertise. The Sustainability appraisals should however consider all aspects not just whether areas are on a railway corridor.

- Q-I3: We have concerns regarding CIL which has not been equitable in its implementation to date. The current system results in smaller (non-strategic) residential development sites effectively being hit twice through both the levy and s106 agreements. In terms of the options going forwards, it is difficult to see how CIL could be agreed separately under a joint Local Plan and therefore a South Warwickshire approach seems sensible but it is critical that it includes different zones within the levy to take account of different market areas.

In regard to Issue I3 relating to CIL, whilst we understand the logic of a South Warwickshire CIL, we do not have a fixed view at this stage. What is most important is that the required infrastructure is provided for developments at all scales, types and locations. The Council must also ensure that it adopts an approach which balances the deliverability of infrastructure and viability. We feel that CIL has not been equitable in its implementation to date so would raise concerns about it going forward although it depends very much on what and where development allocations are proposed. The current system results in smaller (non-strategic) residential development sites effectively being charged twice through both the levy and s106 agreements. In terms of the options going forwards, it is difficult to see how CIL could be agreed separately under a joint Local Plan and therefore a South Warwickshire approach seems sensible. However, it is critical that it includes different zones within the levy to take account of different market areas and the levels of growth and therefore the infrastructure needs within each area.

No mention of consideration of local community need.

Reflection of what has been achieved so far indicates questions in the viability and delivery of a much larger outcome. There are significant questions related to all options. For example, Option B around main bus routes minimum service of an hour. Main areas for amenities are in Stratford-upon-Avon. There is a limitation of bus services which are not bedded into the locality. Service providers have recently changed, and provision is limited to 30 minutes. Pharmacy is at Meon Medical centre and is open during normal opening times. Any outside normal hour’s access to medication is a bus ride away to the Rosebird centre or Stratford. Looking at the map there seems to be little connectivity being made to proposed infrastructure future developments and the options being suggested. Meon Vale/Long Marsden Airfield is significantly short of transportation infrastructure. It is questionable due to this criteria that the Long Marsden/Airfield could be seen as a potential option chosen by 16 groups, with an average of 30 - 40 ha placed under the two scenarios. If it is to be taken seriously then perhaps the exiting commitments should be met and maybe any further plans believable. One hour is not sufficient. The bus route from Meon Vale to Stratford does not meet the criteria: • The bus finishes on Saturday early around 6pm, which means residents cannot take advantage of other social amenities in Mickleton or Clifford Chambers. • no service for the whole of Sunday. • Residents of the area are stuck with expensive taxi services or not going out. There are few amenities and the ones that do exist are not supported and run the risk of closing or are closing down. The only local public houses are in Lower Quinton and Long Marsden, who desperately need financial support, especially after covid. Promised additional amenities have not transpired. This does not bode well for a future that is not integrating the national and international economic setting.

Current infrastructure in a lot of villages and rural locations does not support increasing the number of houses to be built. Specifically referring to Wootton Waven- roads around the school and surrounding areas cannot support a significant increase in vehicles/ traffic. Also don't have park/ playground for children at the moment. When any issues on M42/ M5 motorway, traffic gets re-directed through Henley in Arden and roads are completely grid-locked so roads cannot support major increase in traffic.

I am concerned about the sheer volumes of traffic everywhere, it is becoming increasingly dangerous, with the sheer frustration of, for example trying to get to Kenilworth from Leamington, and vice versa. Surely all new builds will inevitably lead to at least 2 cars per household. At least the smaller villages, for example Old Milverton/Blackdown offer alternative routes. These will become rat runs.

Warwick District Local Plan: H03 East of Whitnash /South of Sydenham No Infrastructure Requirements - compare to other sites! No Infrastructure for previous 2 developments totalling already 572 dwellings off the single access point. 2.47 partial rebuild and extension of Campion School that will ENABLE access to be provided – is this at all likely, there is no provision for the loss of land of an expanding school in W/22/0232; W/21/0590; W/20/0617? DS15 Comprehensive Development of Strategic Sites - H03 not included!

The document states, dismissively, that there is a “view that in the past infrastructure provision has not matched the level of growth and/or not been delivered at the right time”. HOW TRUE THAT IS, particularly for WDC where we already have the chaos of Europa Way – once a magnificent gateway to Leamington from the south, being sequentially destroyed to be replaced by a running-sore dual carriageway race-track cum parking lot.

The plan identifies that the infrastructure required for new or expanded settlement takes several forms. Key infrastructure such as transport should be financed and delivered in advance of the development to unlock the building of homes, as it is done elsewhere in the UK. This should apply to all proposed or existing settlements.

Issue S1: Green & Blue Corridors 3.5 As shown on the Vision Document (Appendix 2) and Illustrative Masterplan for Land east of Banbury Road, Southam, it is proposed to retain and enhance the majority of the existing landscape features, including hedgerows. The proposals will deliver a number of landscape benefits, including new Public Open Space, recreational routes and a community orchard. 3.6 SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. 3.7 Therefore, the proposals for land east of Banbury Road, Southam demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.

Q-12: Please select the option which is most appropriate for South Warwickshire: a: Set out infrastructure requirements for all scales, types and location of development b: Focus on strategic infrastructure relating specifically to the growth strategy The South Warwickshire Local Plan should consider infrastructure need within the plan area, given that strategic infrastructure will be needed to ensure the deliverability of the plan. Q-15: Please add any comments you wish to make about infrastructure, viability and deliverability. Agree that identified Sites should be capable of being delivered within the plan period.

Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development If this detail was included within the Part 1 Local Plan then the requirements would be established which apply equally across South Warwickshire. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy In this option, the focussing only on infrastructure relating to the growth strategy would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, theexisting Core Strategy and Local Plan policies would be retained, resulting in different approachesacross the two Districts. The delivery of supporting infrastructure is fundamental to the delivery of any site, whether strategic or non-strategic. However, the Part 1 Plan seeks to focus more so on the strategic growth elements. Therefore,Option 12b would be more appropriate. However, Terra believe that both options should be amalgamated in some form to ensure that infrastructure delivery is suitably accounted for. The Councils run the risk of neglecting smaller settlements, such as Bishop’s Itchington, which are in need of infrastructure improvements if they focus purely on the strategic options. Further, leaving infrastructure provisions to a Part 2 Plan could cause significant delays if the Part 2 Plan is delayed or, indeed, the strategy changes. This could exacerbate existing or future problems. Therefore, Terra believe that it would be more appropriate to identify the infrastructure requirements through the Part 1 Plan, with any additional detail being introduced through the Part 2 Plan. Q-I3: Please select the option which is most appropriate for South Warwickshire. Terra agree that a single Levy should be applied to the entire South Warwickshire Authority as this will enable to Councils to deliver their joint strategy in an effective way. The charge should additionally be zoned to enable it to react to varying markets and viability conditions. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability As detailed above, Land at Plough Lane, Bishop’s Itchington as identified at Figure 1 is available and suitable for development. The site is capable is of delivering residential development, with generous open space and a biodiversity net gain. Additionally, there is an opportunity to bring the site forward as an all-affordable development to help meet the needs of the village. Terra would ask that the Council take these points into account when assessing the villages for potential allocations.

Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development If this detail was included within the Part 1 Local Plan then the requirements would be establishedwhich apply equally across South Warwickshire. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy In this option, the focussing only on infrastructure relating to the growth strategy would mean thatrequirements in other locations would not be set until the Part 2 plan was adopted. In the interim, theexisting Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. The delivery of supporting infrastructure is fundamental to the delivery of any site, whether strategic or nonstrategic. However, the Part 1 Plan seeks to focus more so on the strategic growth elements. Therefore Option 12b would be more appropriate. However, Terra believe that both options should be amalgamated in some form to ensure that infrastructure delivery is suitably accounted for. The Councils run the risk of neglecting smaller settlements which are in need of infrastructure improvements if they focus purely on the strategic options. Further, leaving infrastructure provisions to a Part 2 Plan could cause significant delays if the Part 2 Plan is delayed or, indeed, the strategy changes and this is not continued with. This could therefore worsen any existing or future problems if there are delays. Therefore, Terra believe that it would be more appropriate to identify the infrastructure requirements through the Part 1 Plan, with any additional detail being introduced through the Part 2 Plan. Q-I3: Please select the option which is most appropriate for South Warwickshire Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan A single Levy for the whole of South Warwickshire could provide developers with greater certainty regarding likely development costs. It is possible to charge different rates of CIL in different zones within a single Levy. Option I3b: Each District Council to produce its own Levy Separate Levies could have the potential to better respond to different conditions in different areas of South Warwickshire, with the potential that reviews could be undertaken more easily to react to changing circumstances. Terra agree that a single Levy should be applied to the entire South Warwickshire Authority as this will enable to Councils to deliver their joint strategy in an effective way. The charge should additionally be zoned to enable it to react to varying markets and viability conditions. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability As detailed above, Land to the East of Junction 12, M40 as identified at Figure 1 is available and suitable for development. If the Council do wish to allocate sites for new settlements, a strategy which was adopted previously by Stratford-on-Avon, the Councils should be clear on the expectations of supporting infrastructure (including education, health, transport, Green Infrastructure) and affordable housing provision. This will feed into viability assessments for the delivery of the New Settlements, so these provisions need to be identified as early as possible.

Q-I2 Option I2a: Set out infrastructure requirements for all scales, types and location of development Infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire, are key for the Local Plan. The NPPF requires Local Planning Authorities (LPAs) to plan for, and allocate, sufficient sites to deliver the strategic priorities of the area (see NPPF paragraph 23). The extent and costs for the supporting infrastructure required should be understood at an early stage.

Q-I3 Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan Whilst it would be simpler to have a single levy for the whole of South Warwickshire, market characteristics are important when deciding on an appropriate level of CIL levy (as evidenced by the different rates between the LPAs at present). These area-based characteristics could be picked up through the appropriate use of zoning across this wider area under a single South Warwickshire CIL. It is important to consider the viability of individual sites when determining the CIL charging rates (see PPG Paragraph: 021 Reference ID: 25-021- 20190901).

Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability Infrastructure, viability and deliverability are all key considerations in the production of the SWLP. At this stage, key documents such as the Infrastructure Delivery Plan (IDP) and Housing and Economic land Availability Assessment (HELAA) are yet to be produced, and therefore the key underlying assumptions of any viability work are unknown. Once evidence base documents such as the IDP and HELAA are available, the Councils should undertake a detailed viability assessment to inform the preferred options consultation. To ensure that the SWLP is consistent with national policy, as required by NPPF paragraph 35, any requests for contributions should be made in compliance with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010, and confirmed at paragraph 57 of the NPPF. As identified in NPPF paragraph 34 the policies and levels of contributions included within the Local Plan should not undermine the viability and deliverability of the Local Plan.

Question I2: Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy 3.6 IM agree that the Local Plan, where appropriate, should set out the requirements for strategic infrastructure where it specifically supports the growth strategy. However, it is important that the need for infrastructure identified within the Local Plan is fully supported by the underlying evidence-based documents. 3.7 The Site, along with others located to the south of Coventry (as part of the south Coventry Masterplan), can support the case of the proposed A46 Link Road (promoted by WDC, WCC and CCC). Furthermore, due to the overall quantum of development that could be delivered as a direct result of the proposed Link Road, any new homes within this area can assist in supporting the funding. The south Coventry Masterplan will also form part of the outline business case in support of the link road, which will need to be submitted to the Department for Transport (DfT). 3.8 It should however be noted that the delivery of the Site is not reliant upon the Link Road coming forward. The Site remains a sustainable location for development adjacent to existing urban areas, where facilities and connections are already available. The emerging proposal for the Site, enclosed with the Vision Document at Appendix 3, demonstrate how the Site can be delivered ahead of the Link Road whilst not impeding its future delivery.

3.12 It should be ensured that any policies set out within the SLWP in relation to infrastructure do not undermine the viability of development proposals.

Q13 Option 13b, each district produces its own levy to enable them to respond better to local conditions.

Q-I2 Response: The Local Plan should contain enough flexibility to adapt to change over the course of the Plan period. To ensure that the Plan remains relevant for the duration, it would not be appropriate to set out all of the infrastructure requirements at all scales immediately. This would remove flexibility and could result in the Plan becoming hostage to fortune. If option 12a was taken forward it would need to be a relatively high level approach to the infrastructure requirements, so as not to prejudice opportunities in the future. In this context, option 12b would appear to be the most appropriate option to take forward. It would help to secure the delivery of any specific, targeted, strategic infrastructure identified as being required now, whilst enabling the Councils to adapt to changing circumstances and requirements in the future. Q-I5 Response: We agree that the development strategy needs to “be both deliverable and viable”. It is imperative that the Plan is able to deliver on its ambitions, in order to ensure that the social, economic and environmental objectives are met. Notwithstanding, it is important that the Plan appropriately acknowledges the significant investment that development can bring to local areas and, indeed, at scale, regions. In this context, it is also vital that development is not constrained through a lack of ambition or delivery of strategic infrastructure. The relationship between infrastructure, investment and development is reciprocal and not mutually exclusive. It is of paramount importance to the success of Strategic Plans that key infrastructure is in place to support the developments coming forward and the communities that they affect. Land at Red House Farm presents a superb opportunity for the Council to allocate development which has the capacity to help deliver a significant employment scheme, alongside addressing existing connectivity issues surrounding junctions 13 and 14 of the M40, through the introduction of an entirely new junction and the closure of these two, under-performing junctions.

Q-I2: Please select the option which is most appropriate for South Warwickshire Response - Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy: Paragraph 8a of the NPPF relates to the ‘economic’ objective of sustainable development, stating that the planning system should identify and coordinate the provision of infrastructure. In applying the presumption in favour of sustainable development for plan making, paragraph 11 outlines that all plans should “align growth and infrastructure”. Furthermore, paragraph 22 details that “Strategic policies should…anticipate and respond to longterm requirements and opportunities, such as those arising from major improvements in infrastructure”. Given the above, national policy is clear that Councils should, through plan making, positively plan for infrastructure. Having regard to the extent of the area covered by the SWLP, period it proposes to cover and likely scale of growth it will accommodate, it is considered that the SWLP should focus on strategic infrastructure to deliver the growth strategy. Furthermore, the SWLP should also consider what opportunities arise from major improvements in infrastructure, which is particularly relevant in the context of the area south of Coventry, noting the potentially transformational change that could occur in this area through infrastructure, as acknowledged in the framework masterplanning exercise commissioned for this area by WDC.

Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development 2.15. The Respondent considers Option I2a as being most appropriate to ensure a consistent approach across the plan area and avoid disconnect between the SWLP and current extant Local Plan policies. 2.16. While the Respondent would not object to the utilisation of a combination of S106 Planning Obligations and Community Infrastructure Levy (CIL) as per the current system, any policy must reflect the provisions of the CIL Regulations 2010 (as amended) and particularly Regulation 122, which requires S106 obligations to be fairly and reasonable related in scale and kind to development. Q-I3: Please select the option which is most appropriate for South Warwickshire Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan 2.17. The Respondent considers that a single CIL for the whole of South Warwickshire is most appropriate since it will provide greater certainty to developers. While the Consultation Document indicates that separate levies could better respond to different conditions in different areas of South Warwickshire (i.e., the Stratford-on-Avon and Warwick Districts), in the Respondent’s view, this can equally be achieved through the implementation of different charging zones where these are justified. 2.18. The Consultation Document confirms that an Infrastructure Delivery Strategy (IDS) will be prepared which will set out the key pieces of new infrastructure needed to deliver the Councils’ growth strategy and how such infrastructure will be delivered. The Respondent is supportive of this action and considers the preparation of an IDS to be an essential component of the evidence base. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 2.20. Completion of a robust and comprehensive Plan Viability Assessment will be essential to ensure that the SWLP is viable and deliverable in a timely manner. The Respondent considers that both an IDS and Viability Assessment should be prepared at an early stage and used to inform a preferred strategy. Any such documents should be made available for comment as part of the Preferred Options Public Consultation.

Question I2 Option I2b: Focus on the strategic infrastructure relating specifically to the Growth Strategy 3.3 It is important that the focus in this plan is on the strategic infrastructure needed to support the growth anticipated across south Warwickshire by 2050 and specifically to the south of Coventry, as set out above.

1. It is essential that all planning policies enable flexibility within the NHS estate. Where it can be demonstrated that health facilities will be changed as part of wider NHS estate reorganisation programmes, it should be accepted that a facility is neither needed nor viable for its current use and Planning policies within the Local Plan must support the principle of alternative uses for NHS land and property. This will ensure that there is not a delay to vital reinvestment in facilities and services for the community. 2. NHS land and property should be able to grow and expand on existing NHS sites and on land across the borough unhindered. Policies should support the delivery of public service improvements as quickly as possible and allow for adaption to meet changing needs for health buildings. 3. There is a well-established connection between planning and health. Planning policies can not only facilitate improvements to health infrastructure, but also provide a mechanism to improve people’s health. We request that the Local Plan includes policies for health and wellbeing which reflect the wider determinants of health and promote healthy and green lifestyle choices through well designed places. 4. In areas of significant housing growth, appropriate funding must be consistently leveraged through developer contributions for health and care services in order to meet growing demand. We request that when setting planning obligation policies, the Councils seek to address strategic as well as local priorities in planning obligations and engage the NHS in the process as early as possible.

Issue I 2. Infrastructure Requirements: It is sensible that Local authorities should think about funding and delivery of strategic infrastructure to support major new development and ensure that this is derived from contributions from land value. However, there is also a need to think about protecting existing services and facilities in established rural communities and to spread development carefully to ensure that shops, pubs, schools and businesses are supported and where possible revived. There is a clear danger that this Local Plan concentrates entirely on large urban extensions and new settlements so that problems and obligations can then be out-sourced to the private sector at the expense of existing communities – on the basis that the latter can look after themselves. This could be picked up under section I4 which at present just focuses on big-ticket items – like the M40 and HS2. Issue I 3. Community Infrastructure Levy: Doubtless Stratford DC and Warwick BC will wish to include a CIL (or future IL) system for sourcing development funding, but they will need to; firstly, recognise that CIL funding is only for future development, (not for addressing existing shortfalls in funding), secondly, they need to be explicit and open about how money is spent, and thirdly, they should acknowledge that in practice, CIL does not overcome site specific requirements which may still be required under S106 to release sites. Above all, the Councils need to robustly test the implications of applying a CIL and recognise that smaller builders are not as readily able to support all the onerous infrastructure requirements (including BNG and other levies) which local authorities now expect. SDC and WBC need to pay more than lip service to the concept of supporting SME’s. Issue 1 4. Infrastructure Safeguarding: As mentioned above, protecting and safeguarding infrastructure should go beyond simply reserving land for major strategic projects but also thinking about protecting small scale infrastructure such as shops, pubs, schools and bus services which are the life-blood of so many rural communities. It is of concern that the Local Plan is becoming too ‘centralist’. Issue I 5. Viability and Deliverability: This is a major issue for smaller builders. The Councils will need to judge whether infrastructure expectations are realistic and whether schemes are viable. This will involve generic and specific testing. Too often strategic sites are allocated in order to achieve more expensive infrastructure and services from the value of the land – but by pushing for major strategic items, the level of affordable housing is often reduced. LPA’s need to think more carefully about whether large new settlements are a more efficient way of delivering housing rather than established rural communities which are often then simply neglected. (Are new settlements simply a political choice to reduce the scale of objections from established communities and minimising the ‘political pain’?)