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

Q-I3: Please select the option which is most appropriate for South Warwickshire It is considered that both options (considering a South Warwickshire CIL and each district producing its own CIL) are important. Producing a wider CIL will help to assist in identifying and delivering wider strategic infrastructure requirements which span across both districts. There needs to be a joined-up approach to deliver such strategic infrastructure. It will however be important for each district to work to identify more localised requirements of certain areas/ zones to ensure these more accurately reflect site specific circumstances. It is imperative also, in considering any option, that any existing bespoke CIL provisions that have been agreed for specific allocations or projects (e.g. Long Marston Garden Village where CIL rating is zero for residential floorspace) are carried across to ensure that any amended provisions do not prejudice the deliverability of such sites, especially as a number of these schemes plan to deliver their own infrastructure.

Goverment Guidelines Central Government Policy is currently in a state of flux. Central Goverment "guidance" on housing numbers are being challenged. "Levelling Up" policy is still somewhat unclear and concepts such as "Investment Zones" have sprung from nowhere and then disappeared. I think that it is notable that nationally some local authorities have suspended preoaration of their plans awaiting clarification from Governemt. The South Warwickshire Plan makes reference to previous iterations of "Government Guidance" which may now be outdated and not relevant. Meeting the Needs of South Warwickshire The primary aim of this plan should be to meet local needs not to meet dictats from London. Local needs are: Improving on current levels of infrastructure, housing for local people, a range of employment opportunities, general control of development particularly protecting the character of our communities and the unique South Warwickshire countryside. Town centres have been allowed to decay particularly Stratford which no longer provides an adequate retail function. Infrastructure to be provided before any development Stratford District in particular has an extremely poor record of permitting large amounts of development generating insufficient Comminuity Infrastructure Levy then not spending adequate money to provide the facilities and services to serve the development. Examples are Meon Vale and transport routes, Gaydon and health provision, Shipston and sewerage. There are many more. No development should take place before proper infrastucture is in place. I have particular concerns about the University and Airfield developments on the capacity of the A429 to cope - particularly if the huge sand and gravel site at Barford is permitted.

Issue I2: Infrastructure Requirements and delivery: We acknowledge and support this approach around heritage and cultural assets, health and wellbeing, improving connectivity and biodiversity, creating well designed and beautiful spaces. It is likely that the Plan will need to explore creative far reaching Green Financing initiatives to support existing funding vehicles such as Biodiversity Net Gain, CIL, S106 etc. in order to create incredible green spaces that meet the aspirations of the plan in certain cases - Green Finance Institute (https://www.greenfinanceinstitute.co.uk/).

Q-I2: 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 It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: A: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan B: Each District to produce its own Levy It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage. As intimated at NPPF para 58.

Q-I3: 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.

Q-I2: Why have a joint plan if there are to be different approaches simply because there are separate administrations. Moreover the timely delivery of infrastructure is critical and has not always been achieved so far. We would have welcomed more discussion about why infrastructure lags behind and what is needed to improve matters. Q-I3: Option a. Simpler Q-I4.1: Yes, but we don’t know why you ask.

Issue I2 Infrastructure Requirements and Delivery Q12a: This option, to set out infrastructure for all scales, types and location of development within Part 1 of the Local Plan is considered is preferred. This would allow the requirements to be applied equally across the District and provide developers with more certainty when coming to consider implications for proposed development/proposed sites across both Stratford and Warwick. Issue I3 CIL Q-13a: This option for CIL is preferred, which would set a single levy for the whole of South Warwickshire. This would give developers greater certainty regarding likely development costs.

Issue I2 Infrastructure Requirements and Delivery Q12a: This option, to set out infrastructure for all scales, types and location of development within Part 1 of the Local Plan is considered is preferred. This would allow the requirements to be applied equally across the District and provide developers with more certainty when coming to consider implications for proposed development/proposed sites across both Stratford and Warwick. Issue I3 CIL Q-13a: This option for CIL is preferred, which would set a single levy for the whole of South Warwickshire. This would give developers greater certainty regarding likely development costs.

INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable.

Q-I-2 Loss of farm land and the impact on food production in the area must be considered. We cannot afford to build on productive land. Promoting wellbeing by looking after the local environment and wildlife is extremely important to the residents of Kenilworth.

Q-I3: Neither option 13a or 13b are appropriate for a Development Plan. All planning obligations must satisfy the statutory requirement of the CIL Regulations 2010 as amended (Regulation 122). A statement in a Development Plan cannot make lawful a demand for obligations which fail to meet its statutory tests. A Development Plan can include a general policy as to the formal Council seeking planning obligations to offset the impacts of new development where such a requirement meets the statutory tests.

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 3.11 Rainier support Option I2a which would result in the SWLP Part 1 Plan setting out the infrastructure requirements for all scales, types, and location of development, to be applied equally across South Warwickshire. 3.12 In light of the new growth required across South Warwickshire up to 2050, new infrastructure is also needed to support this growth, and this should be considered as a strategic matter, as there will be cross-boundary infrastructure requirements. 3.13 Part 1 of the SWLP seeks to set the Vision, Strategic Objectives and Strategic Policies for South Warwickshire and therefore the infrastructure that is required to accommodate this strategic growth should be considered now, at this stage of the plan making process. 3.14 If infrastructure delivery was left to Part 2 of the SWLP, this would create a risk of a fragmented approach to infrastructure delivery across South Warwickshire, which could ultimately stall potential development sites in the future. 3.15 It is therefore recommended that the emerging Part 1 Plan sets out the infrastructure requirements for South Warwickshire now, where strategic site allocations are identified, alongside the infrastructure requirements for the entire plan area. This approach is in accordance with Paragraph 8 of the NPPF which acknowledges the importance of coordinating the provision of infrastructure with the objective of building a strong, responsive, and competitive economy.

Q-I2: Please select the option which is most appropriate for South Warwickshire Crest Nicholson supports option I2a. Infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire, are key for the Local Plan. At an early stage this should be considered in relation to all proposed / potential growth areas and allocation sites (irrespective of whether these will be included in Part 1 or Part 2 Local Plans) in a joined up fashion, to ensure that there is clarity in relation to how infrastructure is being planned for across the Local Plan area. 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. Crest Nicholson considers that the most efficient way for the South Warwickshire LPAs to achieve this would be to progress a single Local Plan, as opposed to a plan in two parts. This would ensure that there is suitable confidence that the infrastructure to deliver all housing supply is available and has been suitably planned for. It is not considered to be either necessary or efficient for the emerging Local Plan to be split into two parts. It should also be noted that the proposals being mooted through the Levelling Up and Regeneration Bill seek to speed up the Plan-making process and do not align with the sort of two-part approach being sought by the South Warwickshire authorities. The production of a single Local Plan would therefore be the simplest and most transparent option for enabling the South Warwickshire authorities to provide certainty and demonstrate at the earliest opportunity that it has an up-to-date deliverable Development Plan that can achieve the NPPF allocation and land supply requirements, backed up with a robust plan for the delivery of infrastructure. Crest Nicholson understands that the approach jointly proposed by the Councils to prepare the Plan in two separate parts, to first set out a Vision, Objectives and Growth / Strategic Policies (Part 1) followed by Detailed Policies and Strategic and Smaller Site Allocations (Part 2), is intended to enable the first part of the Local Plan to be prepared more quickly. However, this is likely to lead to specific site allocations taking longer to be adopted. The plan will only become effective once specific locations for development are identified. Without these, unplanned development may come forward and unsustainable patterns of development are at risk of being perpetuated. Q-I3: Please select the option which is most appropriate for South Warwickshire At present both Warwick and Stratford-on-Avon district Councils have a CIL charging schedule in place, which have different charges payable for residential development. Our initial analysis has shown that for general residential development at present this CIL charge can vary from £82.01 per sqm. in Warwick town, to £168.51 per sqm. in the wider Stratford on Avon area. Therefore, Crest Nicholson consider that market characteristics are important when deciding on appropriate level of CIL levy (as evidenced by the vastly differing rates between the LPAs at present). These area-based characteristics could either be picked up through the appropriate use of zoning across this wider area under a single South Warwickshire CIL, under a joined up approach to charge and collect funds for delivering infrastructure that served this Local Plan area, or through separate CILs for each LPA as long as there is a suitable mechanism to ensure that the funds are spent in a way that reflects the joined up nature of the wider development strategy. Under whichever option is pursued, it is important to consider the viability of individual sites when determining the CIL levels to charge (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 South Warwickshire Local Plan. 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 Council should undertake a detailed viability assessment to inform the preferred options consultation due to take place later this year. To ensure that the plan is consistent with national policy, as required by NPPF paragraph 35, any requests for contributions could 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.

Issue I2: Infrastructure Requirements and delivery 3.1 In response to this question, RPS would point out that the over-arching approach in the SWLP is to take a two-part approach; Part 1 dealing with strategic policies and proposals; and part 2 addressing non-strategic policies and site allocations. 3.2 RPS is broadly supportive of a two-part approach, which decant non-strategic site to the part 2 stage. The site at Goose Lane would fall into this later stage. On this basis, any infrastructure requirements relating to this site were it to be allocated in the SWLP should be addressed at the part 2 stage. RPS supports option I2b. Issue I5: Viability and Deliverability Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.3 RPS would recommend that when considering individual site preferences, the Council should support sites that can be brought forward relatively quickly, and in locations which are already served by existing infrastructure, including the Goose Lane, Lower Quinton site. This reflects circumstances for example where sites that rely on funding for strategic infrastructure projects could be substantially delayed (i.e. South Western Relief Road and delivery of Long Marston Airfield).

Q-I3 Each District Council should produce its own Levy, to ensure that it can produce a bespoke offer which suits its needs and would not result in hindering development if prepared jointly.

Q-I2: Please select the option which is most appropriate for South Warwickshire: Bellway supports option I2a. Paragraph 16 of the NPPF requires plans to be shaped by “early, proportionate and effective engagement between plan-makers and…infrastructure providers”. Paragraph 20 goes on to require strategic policies to make sufficient provision for infrastructure. The NPPF (paragraph 34) also requires plans to set out what contributions are expected from development towards infrastructure. Therefore understanding infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire across the plan period, are key for the SWLP to address. It is important for infrastructure providers to be engaged at an early stage of the SWLP process so that it is clear that proposed allocations are deliverable within the plan period and contributions requested will not impact on the viability of a scheme. Q-I3: Please select the option which is most appropriate for South Warwickshire At this stage, Bellway has no preference on whether the Councils pursue Option I3a (establish a South Warwickshire CIL) or Option I3b (produce separate CILs). However, currently Warwick and Stratford-on-Avon District Councils have separate charging schedules in place. Should a joint levy be pursued, market considerations of both areas should be considered and it is likely that levy charges will need to vary depending on the location of the development. No matter which option is pursued, it is important to consider the viability of individual sites when determining the CIL levels to charge and whether there is scope for exclusions to apply to larger strategic sites (Planning Practice Guidance (‘PPG’) Reference ID: 25-021-20190901). Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability At Examination, there is a requirement for plans to meet the NPPF’s test of soundness (paragraph 35) and be legally compliant. 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. There is a greater emphasis in national policy on testing viability at the plan making stage. A Viability Assessment will be required to demonstrate that the proposed policies and strategic sites within the SWLP are viable (PPG Reference ID: 10-002-20190509 and 10-005-20180724). Plan makers are required to engage with developers and infrastructure providers in order to confirm costs and values included within the viability assessments (PPG Reference ID: 10-006-20190509). It is imperative for the viability assessment to be kept up to date and to be informed by reasonable assumptions on all costs expected. Key statutory consultees must be involved in order to inform the assumptions made on costs (e.g. education, NHS, highways).

Viability and Deliverability Issue I5 within the consultation material seeks comments regarding sites being viable and deliverable. It is important that allocations are deliverable and market attractiveness and location will have a significant role to play in deliverability. It is notable for example that Startford-on-Avon’s 2016 Core Strategy allocated 10ha of land at Atherstone Airfield which still remains without planning permission. The site is located away from the main motorway and A road network and it is therefore less attractive to the market than other sites such as Redditch Gateway which have been part completed and the residual (south site) commences construction this Spring. The land that Stoford are promoting to the south east of junction 3, M42 is more akin to Redditch Gateway. The A435 is a strong link to the M42, and in turn the location is attractive for companies seeking direct access to the midlands motorway network. In addition, the significant benefits of this location are the opportunities for pedestrian and cycle connections that can be improved to serve the local railway stations of Earlswood, Wood End and Danzey – which are on the direct line through to Stratford, Birmingham and intervening stations.

Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire As referred to earlier in our representations, it is our view that it would be preferable to prepare a single Local Plan rather than a two part plan. Adopting this approach would remove the complications identified on page 30 of the draft Plan regarding the way in which a two part plan could secure appropriate infrastructure provision with new developments. However, if the Council decide to pursue a two part Local Plan we suggest that the policies guiding the development of the strategic allocations identify the infrastructure requirements for the developments. Given the nature of strategic allocations the infrastructure requirements will vary from site to site. We support the recognition that the infrastructure requirements of the development strategy are critical in ensuring that development is truly sustainable. That being the case, as part of the site selection process one of the critical considerations should be the onsite infrastructure that is being proposed to support the development. Long Marston Airfield has planning permission for the development of 3,500 dwellings, employment land and supporting infrastructure. However, it is our understanding that there are currently highways infrastructure constraints capping the amount of development that can come forward on the site. These constraints effect the ability of the land south of Stratford-upon-Avon to accommodate any additional development. This is a matter that must be resolved to allow Long Marston Airfield to be delivered, and to allow development to take place in the general proximity of one of the plan areas most sustainable settlements. The SWLP should be prepared on the basis of a strategy that looks to resolve any highways constraints associated with development to the south of Stratford upon Avon. Alongside the site specific requirements, a general infrastructure policy could be included within the plan for windfall sites and other sites that come forward for development prior to the adoption of the part two plan. This would provide certainty to developers as to what infrastructure would be required as part of their development proposals. Q-I3 – Please select the CIL option which is most appropriate for South Warwickshire This matter should be kept under review. It is possible that the CIL system will have been replaced by the time the plan is adopted. If the Councils do pursue a CIL its requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. The impact on CIL on the ability of sites to secure affordable housing provision must also be considered. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability We support the recognition that the development strategy needs to be deliverable and viable and that there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. The SWLP should play a key role in looking to support the provision of the infrastructure required to deliver new development. We note that all development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. We fully support this approach. It may be appropriate, in certain instances, for the SWLP to prioritise the funding of certain infrastructure improvements, such as those identified on page 32, over other planning obligations. These infrastructure improvements will help deliver key objectives of the SWLP and facilitate development generally.

Issue I2: Infrastructure Requirements and delivery and Issue I3: Community Infrastructure Levy QI-2: 3.1 Option I2a states that Part 1 of the Local Plan would set out detail for all scales, types and location for development equally across South Warwickshire, whilst Option I2b would only focus on the strategic infrastructure relating specifically to the growth strategy. 3.2 However, the scope of the Plan as stated on Page 2 of the Consultation Document is that the Part 1 document would set out the overall strategy for the pattern, scale and design quality of places within South Warwickshire. This includes the provision of housing, employment and infrastructure at the strategic level. 3.3 Subsequent Part 2 Plans would then ‘set out detailed policies for specific areas, neighbourhoods or types of development. This could include allocating sites and the provision of infrastructure at a local level, establishing design principles and setting out other more detailed planning policies’. 3.4 In this context, Option I2b is most appropriate, as the Part 1 Plan cannot pre -determine the infrastructure provision that may be required following the identification of sites through Part 2 Plans. To do so would otherwise be pre-emptive of the location and scale of growth to be provided through Part 2 Plans. 3.5 The Councils should nonetheless be clear that infrastructure identified within the Part 1 Plan should be funded through a combination of developer contributions from strategic sites, combined with other sources of external funding. Strategic infrastructure provision should not be reliant upon funding from sites brought forward under Part 2 Plan; again, as to do so would otherwise be pre- emptive of the location and scale of growth to be provided through Part 2 Plans. Moreover, any viability assessment undertaken in support of the Part 1 Plan cannot accurately assess the viability of Part 2 sites, given their full infrastructure requirements cannot be known. QI-3: 3.6 The establishment of a CIL charging schedule (Issue I3) is also directly related to Issue I2: Infrastructure Requirements and delivery. In this regard, we consider that the approach should be informed by a robust viability assessment. We note the government’s recent consultation outlining the Infrastructure Levy, which should be considered once further detail is published.

3.8 Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments will be undertaken as the Local Plan progresses to ensure that what is put forward as a preferred development strategy is both deliverable and viable.’ 3.9 Catesby Estates strongly emphasises that the required viability work should be undertaken as a priority, ahead of and to inform the next stages of the Part 1 Local Plan. Matters relevant to viability and deliverability should be considered at the earliest stages of plan -making, to ensure that any allocations identified are viable and deliverable, including identifying infrastructure requirements.

We must look at amending our planning conditions to ensure that doctors surgeries, schools etc are in place long before occupancy. We must look at road infrastructure being in place before occupancy and we must ensure public transport is put in place without there being a timeline. All too often developers pay for something to be in place for a short period of time and then it ends and there is no financial support for it to continue.

Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire As referred to earlier in our representations, it is our view that it would be preferable to prepare a single Local Plan rather than a two part plan. Adopting this approach would remove the complications identified on page 30 of the draft Plan regarding the way in which a two part plan could secure appropriate infrastructure provision with new developments. However, if the Council decide to pursue a two part Local Plan we suggest that the policies guiding the development of the strategic allocations identify the infrastructure requirements for the developments. Given the nature of strategic allocations the infrastructure requirements will vary from site to site. We support the recognition that the infrastructure requirements of the development strategy are critical in ensuring that development is truly sustainable. That being the case, as part of the site selection process one of the critical considerations should be the onsite infrastructure that is being proposed to support the development. In this regard, as detailed in our Call for Sites submission, Vistry’s land interest at Southam will provide land for a new two form entry primary school, public footpath and road crossing enhancements and significant areas of public open space. Q-I3 – Please select the CIL option which is most appropriate for South Warwickshire This matter should be kept under review. It is possible that the CIL system will have been replaced by the time the plan is adopted. If the Councils do pursue a CIL its requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability We support the recognition that the development strategy needs to be deliverable, viable and that there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. We note that all development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. We fully support this approach. It should be informed by the information provided with the Call for Sites submissions. Vestry’s land interest at Southam is viable, deliverable, and it is expected it will provide a ‘full’ S.106 package.

Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire As referred to earlier in our representations it is our view that it would be preferable to prepare a single Local Plan rather than a two part plan. Adopting this approach would remove any complications identified on page of the draft Plan regarding the way in which a two part plan would need secure appropriate infrastructure provision for new developments. However, if the Council decide to pursue a two part Local Plan we suggest that the policies guiding the development of the strategic allocations identify the infrastructure requirements for the developments. Given the nature of strategic allocations the infrastructure requirements can vary from site to site. We agree with the recognition that the infrastructure requirements for the development strategy are critical in ensuring that development is truly sustainable. That being the case, as part of the site selection process one of the critical considerations should be the onsite infrastructure that is already available to support the development. Q-I3 – Please select the CIL option which is most appropriate for South Warwickshire This matter should be kept under review. It is possible that the CIL system will have been replaced by the time the plan is adopted. If the Councils do pursue a CIL its requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability We support the recognition that the development strategy needs to be deliverable and viable and that there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. We note that all development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. In order to inform this process regard should be had to the site specific submissions put forward through the Call for Sites process. As detailed in MPTL Call for Sites submissions the proposals at Stoneleigh Park and Kingswood Business Park are readily deliverable.

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 2.10. 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. 2.11. 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 2.12. 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. 2.13. 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-I4.1: Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Y/N/DK 2.14. Yes. The Respondent considers it sensible to include a policy that safeguards land that will facilitate the delivery of key infrastructure projects where this is justified. The Respondent recognises that safeguarding would be difficult to achieve post adoption of the SWLP and is best considered at an early stage of the plan preparation process to ensure that the growth strategy is capable of being delivered. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 2.15. 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.

We would comment that focusing new infrastructure on existing transport routes such as rail and stations would be the best use of scarce resources, particularly where new infrastructure could upgrade those existing stations and as a result improve the rail timetables particularly where there are opportunities to move rail travellers onto main line routes speedily and easily, such as at Claverdon. In addition the positive linking of new employment with housing in appropriate locations has a high level of sustainability and that should be the focus for improved infrastructure and delivery Q-I2: In the list of options there should be a much stronger Economic focus on the sustainable benefits of providing new employment with new housing in appropriate locations and also the sustainable connectivity with providing that growth at Key transport hubs such as stations. There is therefore in this instance an all round Economic benefit in focusing economic infrastructure provision for the benefit of both the District and South Warwickshire. Q-I5: This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assesed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.

Issue I2: We would comment that focusing new infrastructure on existing transport routes such as rail and stations, and closely connected settlements such as Hatton Park, would be the best use of scarce resources, particularly where new infrastructure could be accommodated easily within a reasonable expansion of Hatton Park. Q-I2: There are opportunities within the settlement of Hatton Park and its extension to include local forms of employment most related to farming and the settlement itself. Q-I5: This really is one of the most important parts of this emerging Local Plan and really seems to have been dismissed in the two paragraphs which discuss it. All Local Plans are critically assesed by the Planning Inspectorate to see whether land use options for growth are properly and reasonably viable and most particularly deliverable within the Plan period. This is not made clear in this Plan at this stage and it should state that all growth options, whatever size, should be properly tested from a viability and deliverability tests before this emerging Local Plan reaches consideration by Regulation 18.

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 Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy Paragraph 11(a) of the NPPF makes clear that all plans should inter alia seek to meet the development needs of their area and align growth and infrastructure. Moreover Paragraph 34 also states that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. There is a need to understand the infrastructure requirements from the growth strategy set out across the plan area through the preparation of an Infrastructure Delivery Plan or such other similar report. This is needed to inform the approach to the SWLP. In respect of Option I2b the commentary notes that this option would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. Part 2 of the Plan will need to be consistent with the growth strategy set out and adopted at Part 1 therefore the infrastructure needs would already be known to an extent. Moreover, the IDP i s a ‘live’ document that can evolve and be updated at Part 2. Q-I3: We consider that Option 13a is preferrable as it enables a consistent approach for the delivery of the sustainable growth and the required infrastructure across the whole plan area. Indeed, a similar approach was taken by South Worcestershire Councils (Malvern Hills, Worchester City and Wychavon) who prepared a joint Local Plan and then common CIL Charging Schedules. The CIL charging schedule was supported by an IDP as highlighted above. This provides a consistent approach across the plan area.

Q-I2 - Please select the option which is most appropriate for South Warwickshire The two options set out within the consultation document are as follows: 1) 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. 2) 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, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. These options are unclear because option 12b proposes to relate infrastructure to the growth strategy, which is the same as option 12a which will set out infrastructure requirements related to all scales, types, and location of development. All scales, types and location of development will be the growth strategy, therefore the options are the same. We will however stress it is important that there is clarity about the infrastructure requirements needed to support the growth strategy, and that the type of infrastructure and route options are decided on as early as possible to provide certainty. For example, in West Northamptonshire the Northern Orbital Route has been committed so far along, but then no progress has been made on the route options for the remainder of the route from Pitsford to Moulton. This has meant that as the work on West Northamptonshire’s Strategic Plan has progressed, growth options have been proposed which would be reliant on the completion of the Northern Orbital route, and there is uncertainty for developers as these sites are promoted about whether or not there will be significantly more infrastructure costs than would otherwise be the case. Historically, as part of our previous submissions to the emerging Local Plan, we have submitted evidence showing how Clopton Quarter is capable of coming forward for residential development and be acceptable in highways terms. In order to mitigate impact on the highway network as a result of the development low intervention measure such as traffic control at Bishopton roundabout would offset the development’s impact as shown by previous reports by ADC Infrastructure. However, we recognise that the growth of Stratford from other sites is likely to require more advanced traffic intervention, and as such, we propose contributions towards upgrading Bishopton roundabout to a ‘hamburger’ roundabout which will be partially traffic signal controlled with a westbound A46 cut through. The roundabout is capable of being delivered within highway land and land controlled by Davidsons, without the use of all of the proposed safeguarded land shown within the emerging Site Allocations Plan. This is considered the best solution to accommodate future growth in the area as a solution that solves the infrastructure constraints currently in Stratford for and beyond the plan period. An early plan showing these proposals is provided at Appendix 3. National Highways have no identified or committed scheme to address the identified need for improvement at the Bishopton roundabout in the next 8-18 years of their RIS2 and RIS3 policies. Therefore, this constraint to highways at the key junction for Stratford has the potential to prove a bottleneck for delivering the required housing growth in the next Local Plan period. The South Warwickshire Plan Officers are therefore encouraged to proactively lead these conversations with National Highways and the site promoters who are capable of delivering these solutions to unlock the Local Plan growth. In terms of direct access from the Clopton Quarter site, we propose installing a new roundabout connecting onto the A46 which will be acceptable in highway terms. Discussions with National Highways are ongoing, with the latest meeting being held in December 2022. The final investigation works looking at matters including layby surveys and recommissioning the Road Safety Audit will be carried out in Spring. This approach resonates with the IM land approval further south on the A46 which also includes direct access from the A46. Q-I3 - Please select the option which is most appropriate for South Warwickshire: 1) Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan. 2) Option I3b: Each District Council to produce its own Levy. Option 13a – a South Warwickshire CIL covering the whole of the District – is most appropriate. This will give developers more certainty about the amount of chargeable CIL that will apply to a development and, as the consultation highlights, different CIL zones can be established within a single levy which would be able to respond to different areas and changing circumstances.

I am concerned that, without the creation of new employment opportunities, further housebuilding south of the river would exacerbate existing problems with congestion and pollution in Stratford-upon-Avon. Given the limited number of crossings over the river Avon, there is the likelihood of an ever-increasing number of vehicles, including HGVs, being funnelled across the medieval Clopton Bridge designed for horse and cart. This ancient, Grade 1-listed structure is already the cause of major bottlenecks for traffic travelling into the town from south of the river, leading to diminishing air quality as fumes are emitted from vehicles at a virtual standstill. The switch to electric vehicles will not come quickly enough to eliminate this hazard to the health of Stratford’s residents and commuters alike. If passengers and freight are to be taken off the road network, the development of better public transport links and cycle paths are vital. Any new settlements need to be located near existing – and, preferably, expanding - rail corridors, and bus services to and from rural areas should be greatly extended to get private vehicles off the road. Here, the Society agrees with the Stratford-upon-Avon Town Transport Group that a Transport Plan should be a key element of any proposals for future development. There are no cross-town cycle routes in Stratford, and none across the Avon. Routes which exist are poorly signed markings now invisible, and dangerous for the unconfident cyclist – too narrow and lacking barriers to other road users. Only a radical approach to cycling (Cambridge) will make any impact on the level of traffic in the town. Any development, housing or employment should be considered in line with whether or not it will increase traffic flows across either of the two bridges across the Avon in either direction. Furthermore, to support any new development in South Warwickshire, an Infrastructure Plan needs to be developed and, very importantly, delivered in a timely manner before residents move in. This should include the provision of schools and medical facilities which match the level of growth. It is a given that these should be built to the highest environmental standards, using green energy. Without such facilities, together with employment opportunities and transport links, the idea of creating 20-minute neighbourhoods falls flat. In conclusion, there are key issues to be addressed before options for the extent of further housing, and where it should go, can be properly assessed. Only then can consideration of the need for more development be balanced against the impact on the built and natural environment of South Warwickshire.

Q-I2: Paragraph 11(a) of the NPPF makes clear that all plans should inter alia seek to meet the development needs of their area and align growth and infrastructure. Moreover Paragraph 34 also states that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such a s that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. There is a need to understand the infrastructure requirements from the growth strategy across the plan area through the preparation of an Infrastructure Delivery Plan or such other similar report. This is needed to inform the approach to the SWLP. In respect of Option I2b the commentary notes that this option would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts . Part 2 of the Plan will need to be consistent with the growth strategy set out and adopted at Part 1 therefore the infrastructure needs would already been known to an extent. Moreover, the IDP is a ‘live’ document that can evolve and be updated at Part 2. Q-I3: We consider that Option 13a is preferrable as it enables a consistent approach for the delivery of the sustainable growth and the required infrastructure across the whole plan area. Indeed, a similar approach was taken by South Worcestershire Councils (Malvern Hills, Worchester City and Wychavon) who prepared a joint Local Plan and then common CIL Charging Schedules. The CIL charging schedule was supported by an IDP as highlighted above. This provides a consistent approach across the plan area.