Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire?
Whilst the overall figures as to future levels of employment need are not disputed, no recognition has been given to the specific employment land needs of Jaguar Land Rover to grow and expand its operations at Gaydon and Fen End as submitted through the call for sites. These needs should be reflected in the next iteration of the HEDNA as a separate, specific component of employment land need.
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Growth should be limited to maintaining a steady economic growth both for urban and rural areas.
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NO, we do not believe that HEDNA evidence provides a reasonable basis for employment (OR HOUSING NEED!) across SW. It takes no notice of the changes in work patterns brought on by improved technology and post-pandemic changes, principally to remote/hub working and WFH. Such changes are likely to be permanent, should be fully recognised and actively encouraged. Beyond that full attention should be paid to the CPRE analysis of the HEDNA and the earlier criticisms raised by Ray Bullen of BTPC should be revisited in order to come up with more realistic demands for employment and consequential housing need.
11. Whilst the overall figures as to future levels of employment need are not disputed, no recognition has been given to the specific employment land needs of Jaguar Land Rover to grow and expand its operations at Gaydon and Fen End as submitted through the call for sites. These needs should be reflected in the next iteration of the HEDNA as a separate, specific component of employment land need.
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We consider that the HEDNA provides a reasonable basis to begin identifying future levels of employment need. However, it should not be relied upon solely. As we noted in our representations to the previous consultation, the evidence base should not only focus on past trends, but consider, as far as possible, likely future impacts and cumulative effects of historical and ongoing shortages. The last few years have shown, albeit in unprecedented circumstances, how quickly change can come about. This has served to highlight the need for the ability to provide rapid responses to a changing context throughout all forms of Plan making. In this regard, the Local Plan should include sufficient flexibility to meet anticipated need and adopt to unanticipated changes. This requires the Plan to be ambitious in its growth proposals. Figures derived from the HEDNA should be set as minimum requirements and should not place a cap on the level of economic development to be delivered.
The HEDNA is an appropriate starting point for identifying future levels of employment need across South Warwickshire. The HEDNA is a policy off document and assesses the needs arising within South Warwickshire only. It is therefore an appropriate starting point for identifying employment needs across the area before any “policy on” decisions are taken. Although there is some concern that the methodology employed underplays the total needs. Our main concern about the HEDNA as currently drafted is that it does not provide any account for non-strategic B8 development within the district level requirement and also over simplifies strategic employment needs as being solely for B8 uses. In reality of the market, at a local level is that employment parks provide a range of B2 and B8 uses and likewise at a strategic level there are some B2 requirements that are more than local. We therefore disagree with the way the needs have been categorised and there is a need to recognise the fluidity between Use Classes B2 and B8 in the market.
- The HEDNA is an appropriate starting point for identifying future levels of employment need across South Warwickshire. The HEDNA is a policy off document and assesses the needs arising within South Warwickshire only. It is therefore an appropriate starting point for identifying employment needs across the area before any “policy on” decisions are taken. Although there is some concern that the methodology employed underplays the total needs. - Our main concern about the HEDNA as currently drafted is that it does not provide any account for non-strategic B8 development within the district level requirement and also over simplifies strategic employment needs as being solely for B8 uses. In reality of the market, at a local level is that employment parks provide a range of B2 and B8 uses and likewise at a strategic level there are some B2 requirements that are more than local. We therefore disagree with the way the needs have been categorised and there is a need to recognise the fluidity between use classes B2 and B8 in the market.
In the HEDNA for Warwick, it is acknowledged that ‘Coventry and Warwickshire is a £26 billion economy, accounting for 19% of West Midlands GVA. Immediately prior to the Covid-19 pandemic, growth in GVA was slightly out-performing regional and national trends reflecting stronger performance of the sub-regional economy post 2013. Total employment in 2019 across Coventry and Warwickshire is estimated at 526,900 jobs’. Therefore, it is considered that Thwaites is a significant contributor to this figure given that Thwaites annual revenue since 2012 has trebled to circa £95M, this significant increase in demand has been attributed to the housing market in both the UK and continental Europe, HS2 in the UK, and infrastructure projects. Overall, we consider in response to question E1.1 that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire. However, emphasis that to sustain the growth of the established Thwaites employment site removal of the land from the Green Belt is required.
Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 3.28 The HEDNA1, published in November 2022, represents the most up to date assessment of South Warwickshire’s employment land requirements, concluding an overall need for 248.1ha of employment land in Stratford-on-Avon District and 97.2ha in Warwick District over the period to 2050 2. 3.29 The largest proportion of this overall need is attributable to general industrial (including non-strategic B8) which accounts for 240.9ha and 81.4ha of the requirement respectively across each District. The employment land requirement for offices is much lower at 7.2ha in Stratford-on-Avon and 15.8ha in Warwick District 3. 3.30 These requirements exclude land for strategic B8 warehousing, the need for which has been assessed separately in the HEDNA at a sub-regional level, equating to a requirement for some 709ha of land across Coventry and Warwickshire over the period to 2050 4. 3.31 The HEDNA assesses quantitative needs using a variety of methods consistent with PPG, concluding that a labour demand approach based on baseline forecasts produced by Cambridge Econometrics (CE) is the most representative scenario for assessing office needs. In view of the limitations of this approach for assessing industrial land needs, projections based on an annualised average of past completions over the period from 2011/12 to 2019/20 are used to establish employment land requirements for local industrial and non-strategic warehousing uses. 3.32 Rainier broadly support the approach to assessing needs adopted in the HEDNA but has concerns regarding the employment land requirements established for South Warwickshire, in particular Warwick District, where it is felt the Authorities should be planning for a higher overall requirement. 3.33 Furthermore, whilst the methods used are broadly consistent with PPG, as a subregional study the HEDNA does not robustly consider trends at a sub-area level or the balance between supply and demand which will be key factors in influencing the land requirement and locations where employment growth should be directed. 3.34 These omissions, which represent important steps in forming a complete view of future employment needs for the emerging Local Plan in line with PPG, are explored in more detail in response to Q-E1.2 below. Q-E1.2: If your answer to E-1.1 is No, what would be a more appropriate approach to calculating future needs for this Local Plan? 3.35 Rainier support the use of a labour demand approach for assessing future office needs in South Warwickshire but would highlight – as recognised at para 9.7 of the HEDNA – that these take account of expected economic performance moving forward relative to past trends 5. 3.36 It is evident that potential above trend job creation in sectors likely to occupy office and R&D space (for example by interventions or targeted investments at known Major Investment Sites identified under Issue E7 and in the Draft Economic Strategy for South Warwickshire) is unlikely to be reflected with no adjustments seemingly made to account for this. In a departure from best practice, the baseline CE forecast has also not been compared to another forecast to test its representativeness. Such an exercise might indicate different rates of growth from which a preferred forecast and scenario could be derived which best reflects the economic opportunities presented in South Warwickshire and growth potential of high value sectors being targeted by the authorities. 3.37 Rainier would also highlight that unlike the other Coventry and Warwickshire authorities where a 2-year margin for flexibility has been added to the land requirement, no buffer has been added to the office requirements for Stratford-on- Avon or Warwick, this seemingly ‘due to data issues’. The HEDNA therefore recommends the authorities to ‘treat figures a minima, but this should be informed by detailed consideration of the office stock and trends in losses’ 6. 3.38 The above limitations are perhaps reflective of complexities of undertaking this exercise across multiple local authorities, but nonetheless do cast a degree doubt over whether the office land requirement in Table 8 of the Issue and Options Consultation document is ambitious enough and representative of Warwick District’s growth potential, noting the ambitions to growth the economy in the draft Economic Strategy as well as Warwick/Leamington’s cited status as one of the main office markets in Coventry and Warwickshire 7. Indeed, owing to this status Warwick/Leamington is a location where it is expected that future office supply will be focussed 8. 3.39 In terms of assessed industrial land requirements, Rainier also broadly support the HEDNA’s use of past completion trends but would note that projected requirements for Warwick are comparatively low compared to the other Coventry and Warwickshire authorities, including Stratford-on-Avon in the South Warwickshire context. The HEDNA rightly identifies that this distribution has been influenced by land availability, however in the context of recent demand, the cited growth potential of low carbon transport cluster and the areas role in the heart of the Midland’s engine, Rainer consider that the Authorities should be planning for a higher requirement, particularly in Warwick District. 3.40 It is of note the HEDNA’s conclusion that circa 81.4ha of employment land would be needed between 2021 and 2050 is currently based on the recorded take-up between 2011/12 and 2019/20. This has then been multiplied over the plan period to 2050, before a margin for flexibility, equivalent to a further five years, is then added. Whilst a detailed breakdown of annual take up is not presented in the HEDNA, interrogation of Warwick District’s latest Annual Monitoring Report (AMR)9 shows a comparatively low level of employment land being delivered between 2011/12 and 2015/16, averaging 2.2ha per annum. In more recent years this has increased and between 2016/17 and 2020/21 averaged 3.9ha per annum over 5 years. Evidently, if employment land in Warwick continues to be taken up at the rate seen over the last five years, then some 132.6ha of industrial land could be needed in the District over the plan period when consistently applying a five year buffer like the HEDNA. 3.41 It is Rainier’s view that the quantitative requirements presented in the HEDNA should be treated as a minimum and consideration given to a higher requirement for Warwick District to avoid unduly constraining the market. Other limitations 3.42 As outlined above, the HEDNA does not consider the balance between supply and demand in line with PPG, resulting in gaps in the evidence needed to form a complete view of future employment needs and policies in the emerging Local Plan. This is important in the context of the draft Economic Strategy for South Warwickshire, which seeks to ensure an adequate supply of employment land and affordable employment premises in the right locations through the SWLP 10. These objectives having seemingly been set in response to identified opportunities for significant growth and investment but also the perceived threat that the existing supply of employment land and space “may not be suitable for business needs” 11. 3.43 To address these gaps it is recommended, in line with PPG for assessing economic needs, that the analysis in the HEDNA is supplemented with a sub-area analysis of market demand 12 to gain a deeper understanding of whether there are specific requirements in the local market which affect the types of land or premises needed 13. 3.44 The HEDNA already recognises the potential greater role of South Warwickshire in accommodating strategic B8 warehousing, including along key corridors along the M40 and A4614, however further consideration of location and premises requirements across other sectors being targeted by the Authorities is also recommended to help inform potential locations for employment growth. Such an analysis is also important for assessing the balance between and demand to identify whether there is a mismatch between quantitative and qualitative supply of and demand for employment sites. This will enable an understanding of which market segments are over-supplied to be derived and those which are undersupplied 15 1 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022 2 Stratford-on-Avon District Council & Warwick District Council (2023) Stage 2: Issues and Options Consultation – January 2023, Table 8. 3 Ibid. 4 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, Table 10.19 5 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 9.7 6 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 11.15 7 Ibid. para 3.9 8 Ibid, para 3.41 9 Warwick District Council (2021) Annual Monitoring Report 2020/21 10 Ibid. p22 11 Ibid. p19 12 Paragraph: 026 Reference ID: 2a-026-20190220 13 Paragraph: 032 Reference ID: 2a-032-20190722 14 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 11.25 15 Paragraph: 029 Reference ID: 2a-02920190220
Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? Recent events, such as Covid19 and the energy crisis, have led to less commuting to town centre offices and more internet shopping; these trends will lead to increased change of use in urban areas, increasing windfalls. The HEDNA does not take this changing trend fully into account. Q-E1.2: If your answer to E-1.1 is No, what would be a more appropriate approach to calculating future employment needs for this Local Plan? The Local Planning Authorities have repeatedly backed unjustified hopes of employment growth, for example claiming special circumstances to release Green Belt land at Coventry Gateway (Whitley South) for JLR and at Coventry Airport for a battery gigafactory - neither of these 'special circumstances' sites has supported any new jobs in reality. [Redacted Text]. The appropriate approach would be to encourage change of use, for example from redundant offices to research and development labs, and to take such windfalls fully into account.
This emerging Local Plan needs a fundamentally new approach to the provision of employment land requirements, particularly in terms of the Plan period to 2050. Covid brought a substantial increase in the number of people working from home and particularly those who use broadband and the internet and can work from their own homes. The South Warwickshire Local Plan should have properly commissioned a new employment and economic study from independent consultants which should focus on providing focused growth for those employment activities related back to growth in the national economy. Without this independent Study we believe that the approach taken is imbalanced and particularly at a critical time generally after Covid. In addition this study should also focus on the opportunities to provide employment in a sustainable form along rail corridors and at key settlements near to train stations for some important kind of employment use. Not everyone wants to work from home, some need small start-up accommodation and the focus of some B1 office / business uses near to rail stations could be extremely helpful to the economy as a whole. Generally economic growth comes from small busineses expanding.
This emerging Local Plan needs a fundamentally new approach to the provision of employment land requirements, particularly in terms of the Plan period to 2050. Covid brought a substantial increase in the number of people working from home and particularly those who use broadband and the internet and can work from their own homes. The South Warwickshire Local Plan should have properly commissioned a new employment and economic study from independent consultants which should focus on providing focused growth for those employment activities related back to growth in the national economy. Without this independent Study we believe that the approach taken is imbalanced and particularly at a critical time generally after Covid. In addition the reasonable expansion of Hatton Park could provide focused employment growth on farming and farming-related activities. Generally Economic growth comes from small businesses expanding.
Whilst we suggest that more up to date evidence is needed and will be subject to more detailed review as the SWLP develop. However, we welcome the data provided to date which identifies a clear need to plan effectively for employment growth. The HEDNA provides details of the market needs and uses different data in order to anticipate office, industrial and warehousing net land needs until 2050. The HEDNA concludes that in the round the labour demand models best represent future needs for office floorspace (paragraph 11.3) the findings for Stratford on Avon are summarised in the following tables: Summary of Labour Demand – Net Land Needs 2021 – 2041 ha. (Table 9.4) Offices Stratford on Avon 5.2 Total 30.3 Summary of Labour Demand – Net Land Needs 2021-50 ha. (Table 9.5) Offices Stratford on Avon 7.2 Total 42.0 The above show that there is a need for offices in Stratford on Avon and a significant need across the region as a whole. In addition these offices will need to be high quality and meet occupiers needs. In terms of industrial and warehousing space, Paragraph 11.10 states that the completions data is likely to be the best representation of market needs for the next phase of plan making , particularly for the short/medium-term. For 2021-41 this equates to a need of 132.9 ha. for Stratford on Avon and 1029.8 ha. total need (see Table 9.12). For 2021 – 50 there is a forecast need of 192.7 ha. for Stratford on Avon and total need of 1493.2 ha. (see Table 9.13). The HEDNA also notes that consultation suggests that B8 demand is very strong, and that there is a need for separate allocations for B1c/B2 where land is delineated from sites going for B8 in order to support the manufacturing sector. There is a strong manufacturing sector in the sub-region which needs to be provided for (paragraph 11.11). Overall there is a need for employment floorspace across all three sectors, the site at Southam would be able to assist in meeting this need. We would welcome discussions with Officers as to the role that the site can play in meeting growth objectives.
Issue - E1.1: Support. RBC would agree that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire. Although the issue around the amount of land for B8 warehousing remains to be determined RBC looks forward to working with you to resolve this matter. Duty to cooperate response: The joint HEDNA sets out a sub-regional figure for a total hectarage of B8. We will need to work together to derive a mutually acceptable figure for each plan area.
2.30 Response: In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.31 The Local Plan should indeed support the growth of new industries/sectors as part of a portfolio approach to supporting economic growth within the Districts. 2.32 It is evident that some allocations in the current development plan have failed to deliver new employment development. The availability of such sites to contribute to the supply of employment land opportunities should be reviewed. No purpose is served in allocating land for employment development where the land is not then brought forward into development. The effective supply of employment land is then over-estimated, which frustrates new investment and jobs. It would be inappropriate to envisage that existing employment sites are capable of producing new sources of land for investment. The joint Plan must allocate new land for employment development on the urban edge of the main settlements. The land must be suitable and attractive for new inward investment.
Claverdon subscribes to a number of principles in the section on the environment and the economy. It would like to see the evidence that economic proposals will benefit measurably. The Core Opportunity Area is to the South of Stratford and do not reinforce the choice of Claverdon as a possible area of expansion. It’s important that additional housing aligns with business and vice versa.
But important to give consideration, in Stratford Upon Avon in particular, that the risk of poor infrastruture not being suficient to support a growing population may mean a reduction in visitors to stratford upon avon and therefore less available jobs in the town.