Q-E11: Please add any comments you wish to make about delivering South Warwickshire's economic needs

we need prosperous town centres and industrial estates as well as encouraging the further develoment of Silicon Spa

The last 3 years have seen major changes to what we assumed was an economy that was stable which would merely evolve organically without the need for major blue sky design of something fit for 2050. The reality of change to a cashless society, working from home and ongoing evolution of technology demonstrate that a project is overdue to design the optimum future economy for the area. One that recognises it still has significant agriculture, the rural scene hos to be valued and protected and its economic contribution encouraged. It supports tourism and is the basis of why many people want to live in the area - both existing and potential residents BUT it must recognkse that we have poor exisitng infrastructure that must urgently be upgraded if there is to be any secure economic future. Major support for education skills and training should be a vital part of what is followed coupled with health and welfare..

As has happened in Cornwall, allowing accomodation for tourists takes housing stock away from residents. Care must be taken in the plan to learn from history and what has happened in other tourist towns.

With regard to QE10, we disagree with the premise that tourism is unaffected by spatial planning. There are key issues to be addressed around infrastructure in and around areas of development that not only supports its residents but those visiting the area. The impacts that these developments and associated economic plans will have a direct impact on workforce that feed the tourism sector. We also add that the RSC feels strongly about the need to build cultural capacity in the town/region, which is supported by appropriate infrastructure, which can support economic growth of the area.

The wonderful asset to tourism and leisure we have in Earlswood Lakes and Woods and the rural roads for horse riders, cyclists, and walking groups is being threatened by over development of housing, not only in these proposals but also in those of neighbouring authorities. The nature of this part of the county is under threat.

- Q-E2: We support Option E2a as the there is a need to promote the principle of a low carbon economy but such policies should not be overly prescriptive as much of the guidance for sustainable design comes through national policy and building regulations which ensures a consistent approach across the country. Local policies or requirements above national policy may discourage economic growth in South Warwickshire. - Q-E5: Option E5b – We do not support the inclusion of policies which dictate employment unit sizes. Whilst we understand the reasoning, the reality is that the market supplies business units of all sizes and responds to market gaps. If there is an under supply in one area, the market will respond. - Q-E6: We support Option E6a, to include a policy which generally protects South Warwickshire’s economic assets but such policies must always be written flexibly to allow for changes in circumstances and provide criteria for acceptable land use change. - Q-E7.1: We support the inclusion of a policy that would direct employment to the identified Core Opportunity Area, as identified. This will help provide spatial clarity to the economic strategy and help to focus growth in the most appropriate locations. - Q-E7.2: As part of a comprehensive approach to economic growth, we consider it would be appropriate to include a policy to support additional growth at existing major investment sites. Specifically with regard to the Gaydon Area, the existing land that has been allocated in the Stratford Core Strategy for use by JLR only should now be reconsidered and brought forward for general light industrial, manufacturing and logistics uses. It has become very clear in recent years that JLR does not have a direct requirement for expansion into this area but the site remains extremely well located to support both the manufacturing industry and the logistics market. The release of this site should come forward ahead of any additional employment land in the Gaydon area. We strongly disagree with the suggestion that the area would not be suitable for logistics. - Q-E8.1: Yes, we strongly agree that existing employment allocations should be carried over into the SWLP, specifically in regard to Land at Gaydon. However, as per our response to E7.2, the occupier specific restriction relating to JLR should be removed when carried forward to the SWLP. Given the lack of take up from JLR since the adoption of the Stratford Core Strategy, we consider that the allocation should be brought forward for general light industrial, manufacturing and logistics uses. Of course, this wouldn’t preclude JLR from occupying the site (or part of) and meeting any expansion growth requirements in the future. The site is extremely well located to support both the manufacturing industry and the logistics market and given that this site is an existing allocation, this site should come forward ahead of any additional employment land in the Gaydon area.

Limit town centre shops and businesses away from tourist specific and revert to small business shops.

Issue E2: A Low Carbon Economy - We support Option E2a as the there is a need as part of the wider green agenda to promote the principle of a low carbon economy. However, such policies should not be overly prescriptive as much of the guidance for sustainable design comes through national policy and building regulations which ensures a consistent approach across the country. Local policies or requirements above national policy may discourage economic growth in South Warwickshire. Issue E3: Diversifying the economy - We support Option E3d. Local employment should always be supported but we do not consider it necessary for planning policies to include specific local employment strategies, which can in some instances conflict with employment law and often the operational requirements of successful businesses, which may act as a deterrent to those choosing to locate in South Warwickshire. Where these are in place in other authorities the effectiveness is very questionable and the related planning conditions/s106 obligations just add more unnecessary red tape. Issue E5: Lack of business accommodation - Option E5b. We do not support the inclusion of policies which dictate employment unit sizes. Whilst we understand the rationale, the reality is that the market supplies business units of all sizes and responds to market needs and gaps. If there is an under supply in one area, the market will respond. For example, A.C Lloyd has recently developed 61 SME business units all under 100 sq.m on a site in Tachbrook Park, Warwick. This scheme wasn’t delivered because planning policy required it, rather because there was an identified market shortfall of such units in the area and therefore it was market driven. Planning Policy should not get involved in commercial market requirements and should allow flexibility on sites for the market to deliver to meet actual needs and demands. Issue E6: Core Opportunity Area and Major Investment Sites We support Option E6a, to include a policy which generally protects South Warwickshire’s economic assets where they remain suitable and viable, but such policies must always be written flexibly to allow for changes in circumstances and provide criteria for acceptable land use change. Issue E7: Core Opportunity Area and Major Investment Sites - We support Option E7.1a for the inclusion of a policy that would direct employment to the identified Core Opportunity Area, as identified. This will help provide spatial clarity to the economic strategy, focussing economic activity near to the main existing towns and settlements, near to existing infrastructure and strategic links, and near to where we believe the majority of new homes should be located. - We support Option E7.2a. As part of a comprehensive approach to economic growth, we consider it would be appropriate to include a policy to support additional economic growth at existing major investment sites. This would make best use of existing infrastructure and support existing business clusters. Any such policy would have to be criteria based and should not exclude new investment locations being brought forward in appropriate locations.

There are several large shops which have closed in the town centres which could be used as hotels to encourage tourists to stay overnight eg BHS and Debenhams in Stratford-upon-Avon, Marks and Spencers food store by the bus station in Warwick and House of Fraser on the Parade in Leamington.

E5. Option E5a – Include a policy to support a range of business units – not necessarily new business units – taking full note of the numbers of vacant units which are currently available and which should be preferentially utilised rather than building new, for convenience, on new sites, and also allowing for the reduced demands as discussed in E.1 above.

E6. Answer Option E6a Include a policy to protect SW’s EXISTING economic assets. NB: We have a particular interest in FULLY protecting Wellesbourne Airfield and its associated businesses – and not losing any of its current functionality to unwanted residential or commercial development. We are also supportive of the Warwick University Wellesbourne Campus but wary that overdevelopment of that site will have significant deleterious impacts across our three parishes through increased traffic on the A429 – which then may not be viewed as Sustainable Development.

E7.1 Answer E7.1a – Include a Core Opportunity Area policy with the proviso that it does not lead to the whole of that area being over-developed and hence a sprawling “conurbation” over the whole of the COA, so perhaps it needs to be qualified with specific identified sites/areas within the COA.

E9. Answer: E9b – Save existing retail area boundaries in Part 1 but prepare to relax such policy in Part 2 to allow for the probable/inevitable reduction in in-town retail use; allowing easier conversion to other uses, specifically, office or residential or even small scale manufacturing/studios/workshops.

It is hard to understand how, in a very low unemployment area, it is not recognised that the concept of attracting in NEW business, investment and jobs MUST mean bringing in more people, who will require more homes, in addition to any that might already be needed for current residents, who will have more cars and/or require more infrastructure, which will NOT BE MET and the situation will get worse, rather than better.

Stratford - There should be a whole town approach to planning the future of the town that addresses the traffic concerns, provides good quality land for a range of types of employment, housing and the necessary community infrastructure. The town centre is becoming better but more work is needed to make it the attractive profitable centre it deserves to be.

Option E6a: Include a policy which protects South Warwickshire’s economic assets. 12. Jaguar Land Rover would support a policy which protects it current use, and provides support for further investment within land under its control. Jaguar Land Rover would welcome the opportunity to work with the Councils to agree the wording of any policy for both Gaydon and Fen End. Such policy would need to be included within Part 1 of the Plan. Q-E7.1a: Core Opportunity Areas 13. Jaguar Land Rover support the inclusion of Gaydon within the Core Opportunity Area as a Major Investment Site. However, Jaguar Land Rover objects to the exclusion of Fen End which is equally important to the business, and this should be recognised and included within the Core Opportunity Area as a major investment site. Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 14. Jaguar Land Rover support a policy allocating additional land for specific employment uses at Gaydon and Fen End on sites identified as 375, 376 and 138 on the Interactive Map. Further evidence as to the suitability of the sites 375 and 376 for development for Jaguar Land Rover’s purposes has been submitted with these representations. Jaguar Land Rover would welcome the opportunity to work with the Councils to agree the wording of any policy for both Gaydon and Fen End. Such policy would need to be included within Part 1 of the Plan.

Q-E7.1: Please select the option which is most appropriate for South Warwickshire Option E7.1a: Include a policy directing employment to the Core Opportunity Area. This policy would look to direct employment growth to the Core Opportunity Area with areas outside of this, providing opportunities for more local investment. Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. This could mean that South Warwickshire fails to capitalise on employment opportunities or that newinvestment is focused outside of the Core Opportunity Area and fails to capitalise on the connectivity that the core opportunity area brings. Terra believe that the Councils should be focusing on directing employment to the Core Opportunity Areas. These areas clearly have a strong potential for providing and supporting additional employment growth and should be further explored within the Local Plan. Terra particularly agree that the Gaydon Area / M40 Junction 12 should be explored for additional growth. Land east of Junction 12, M40, as identified at Figure 1, is available to provide a mixed use New Settlement, if the Council seek to pursue this option.

Lapworth Parish Council note that there seems to be some differences in approach between the two districts; we would like to see identification of opportunities for younger residents as a specific target.

3.38 The Housing and Economic Needs Assessment (‘HEDNA’) (November 2022) sets out the economic and employment land needs for Coventry and Warwickshire from 2021 to 2050. In summary, the HEDNA forecasts overall economic growth and significant need for additional employment land to 2050. Overall, a total need for 345.3 hectares of employment land exists in South Warwickshire between 2021-2050 (248.1ha in Stratford District and 97.2ha in Warwick District). 3.39 Strategic sites can make a significant contribution and opportunity for delivering these economic and employment land needs, including as part of residential-led mixed use proposals, delivering self-sufficient and sustainable neighbourhoods. This approach towards such mixed-use strategic sites should be taken to assist in delivering the ambitions for employment growth in South Warwickshire. 3.40 Specifically, this should be considered through support for strategic mixed-use proposals such as Land North of Leamington. Sites such as Land at North of Leamington can make a notable contribution towards South Warwickshire’s economic needs, in the most sustainable location and where the need would be the greatest, in the immediate vicinity alongside residential development.

Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the sub-regional Strategic Distribution Needs, including through identifying some provision East of Junction 12 of the M40, will ensure the South Warwickshire plan takes a positive position on economic growth and in turn support the South Warwickshire Economy. Further to these over-arching needs, there is immediate demand for space within the District and CEG have very strong occupier interest for this area. Q-E3: Please select all options which are appropriate for South Warwickshire 4.6 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.7 Given that the scope of the South Warwickshire Local Plan is a Part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth, therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.8 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.9 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including Gaydon, and major road infrastructure aligned to the key settlements of Stratford - upon-Avon, Warwick and Leamington. 4.10 Therefore, to ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.11 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.12 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. 4.13 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.14 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.15 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.16 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Councils do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this, but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.17 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to the Gaydon/Lighthorne Heath new settlement which provide access to an emerging and growing labour market. 4.18 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the Automotive cluster further expands the likelihood for further associated distribution space is likely to increase. 4.19 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and this Site would help to realise the potential of the Gaydon area/M40 Junction 12 as a Major Investment Site.

Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The Iceni report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs. It is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the Strategic Distribution Needs, including through some provision at Gaydon/Lighthorne Heath, will ensure the South Warwickshire Plan takes a positive position on economic growth which in turn will support the South Warwickshire Economy. Issue E3: Diversifying the economy Q-E3: Please select all options which are appropriate for South Warwickshire 4.6 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.7 Given that the scope of the South Warwickshire Local Plan is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors. There is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.8 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.9 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including Gaydon and major road infrastructure aligned to the key settlements of Stratford -upon-Avon, Warwick and Leamington, specifically the M40 corridor. 4.10 To ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.11 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.12 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. Specifically, previous work undertaken by CEG and the Bird Group relating to the area subject to these representations consider that the site / area has the potential to become a regionally significant employment hub augmenting the current economic strengths associated with the Jaguar Land Rover / Aston Martin Lagonda operations. 4.13 Initial master planning and economic modelling of the land identified for employment (albeit for the benefit of JLR in current policy) in the adopted ‘Land at Gaydon / Lighthorne Heath Supplementary Planning Document ‘demonstrates that the Site can accommodate in the region of 2.8 million sq ft of employment floorspace. This has the ability to generate approximately £11.6 million in business rates; 6,000 direct full-time jobs and £1.0 Billion additional GVA to the local economy from the ongoing operation of the employment area. Importantly, it would contribute significantly to the identified Coventry and Warwickshire economic needs as set out in the 2022 Needs Assessment (prepared by Iceni); providing a range of employment activities in support of the supply chain activities associated with the Regions automotive and technology-based research and manufacturing industries. 4.14 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.15 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.16 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.17 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Council’s do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.18 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to Upper Lighthorne which provide access to an emerging and growing labour market. 4.19 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the automotive cluster further expands, the likely demand for further associated distribution space is likely to increase. 4.20 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and providing open-market commercial space at Gaydon/Lighthorne Heath would assist with realising the wider potential of Gaydon as a Major Investment Site.

Issue E1: Growing the South Warwickshire economy Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 Answer – Yes 4.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.3 Looking at the combined need for Stratford-on-Avon and Warwick District’s, the requirement to plan for 345.2ha of B2/B8 up to 2050 is considered to be a robust level of need. 4.4 In addition to the general industrial needs, the HEDNA looks at Strategic Distribution (B8) needs across Coventry and Warwickshire, i.e units in excess of 9,000sqm. The study concludes that in overall terms, taking into account a margin for flexibility, 606 ha of employment land is required across Coventry and Warwickshire for Strategic Distribution when planning to 2041, increasing to 709 ha when planning to 2050. This over-arching need is also considered to be robust. 4.5 Planning for the specific needs of Stratford-on-Avon and Warwick Districts alongside making an appropriate contribution to the sub-regional Strategic Distribution Needs, including through identifying some provision South of Junction 12 of the M40, will ensure the South Warwickshire plan takes a positive position on economic growth and in turn support the South Warwickshire Economy. Further to these over-arching needs, there is immediate demand for space within the District and CEG have very strong occupier interest in this Site for employment use. An application is being prepared accordingly. Q-E3: Please select all options which are appropriate for South Warwickshire 4.1 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 4.2 Given that the scope of the South Warwickshire Local Plan is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth therefore making the strategy more vulnerable to wider structural economic changes which could take place over the plan period. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 4.3 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 4.4 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including the Gaydon and major road infrastructure aligned to the key settlements of Stratford – Upon-Avon, Warwick and Leamington. 4.5 Therefore, to ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area it is considered that a high-level policy to direct employment within this area should be included. However, this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 4.1 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 4.2 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth to these Major Investment Sites. This would allow additional commercial development to take place to help drive inward investment and support the South Warwickshire economy. 4.3 This Site, south of Junction 12 of the M40, could play a significant role. Initial master planning undertaken by CEG has identified that the Site has the capacity for circa 90,000 sqm of commercial floorspace. Economic modelling has confirmed that this could generate in the region 1,900 full-time equivalent (FTE) jobs on site and 1,000 indirect FTE jobs through the supply chain. The approximate operational economic output (GVA) is estimated at £398 million. This would contribute significantly to the local economy and to the identified Coventry and Warwickshire economic needs as set out in the 2022 Needs Assessment prepared by Iceni. 4.4 However, through planning for growth at the Major Investment Sites in a subsequent policy, it is important to recognise the findings of the Council’s own evidence base particularly regarding the potential role of the M40 corridor. 4.5 Within the Strategic Distribution study section of the Iceni report, whilst it does not seek to distribute the identified needs for Coventry and Warwickshire, it identifies key potential corridors where it could be accommodated based upon existing settlement patterns and concentrations of populations, these are the M42/A446, M6, M45/A45 and the A5. Importantly, and as a point of principle, many of these locations are located within the Green Belt. 4.6 Notwithstanding the Green Belt constraint for many of the identified locations / corridors the study also recognises (para 11.25) that over-concentration in these areas in the North-West of the sub-region could create pressures, particularly in terms of the highway network and labour market. Therefore, Iceni consider “that there is the potential for other corridors within the sub-region, particularly in South Warwickshire, to play a greater potential role in providing for strategic B8 development than they have historically”. Specifically, regarding South Warwickshire, linked to recent strategic B8 development at Banbury and Bicester it highlights the significant potential of the M40 corridor and the potential to consider provision to or close to junctions on this corridor. 4.7 These recommendations are in contrast to the narrative regarding the Gaydon Area/M40 Junction 12 as set out on page 89 of the Issues and Options report. Whilst recognising the importance of the area as an automotive hub which can be capitalised on through the SWLP, the “Council’s do not see this as appropriate location for strategic logistic use (i.e. Use Class B8)”. Unfortunately, no further justification is provided on this but we assume the references relate to the development of a regional / sub-regional distribution park such as Magna Park on the A5 or DIRFT on the M1, rather than B8 uses per se as part of a mixed employment offer. More clarification on this issue is needed as an element of storage and distribution as a component of a mixed employment offer servicing local and national business distribution interests are key elements in supporting inward investment and business growth. 4.8 Junction 12 is in a unique position; close to the automotive cluster where JLR and Aston Martin Lagonda are situated, its proximity to the M40 corridor and its recognised potential to provide more space for economic growth, including storage and distribution use, alongside its proximity to the Gaydon/Lighthorne Heath new settlement which provide access to an emerging and growing labour market. 4.9 Providing for B2, B8 and class E(g)(ii & iii) in this location would build on the existing sector strengths and encourage further diversification in a complimentary manner. Open-market commercial space would enhance the role of the automotive cluster through providing space for related businesses to locate. Furthermore, as the Automotive cluster further expands the likelihood for further associated distribution space is likely to increase. 4.10 The NPPF is clear about the need for plans to set out a strategy which positively and proactively encourages sustainable economic growth (para 82) and Land at Junction 12 would help to realise the potential of the Gaydon area/M40 Junction 12 as a Major Investment Site.

Q-E2 Response: With regard to the low carbon economy, we believe that option E2a would be the most appropriate and sustainable option. However, any emerging policy should not be too prescriptive and risk stifling innovation. The transition to a low carbon economy is crucial, but this must be balanced with realistic ambitions and objectives. Businesses striving to deliver on sustainability objectives for a low carbon future should be encouraged to invest in South Warwickshire through innovative and exciting policy ambitions, which enable them to demonstrate their approach to addressing the climate emergency.In this context, there is not a ‘one size fits all’ approach to delivering a low carbon economy and the Local Plan should be clear that innovation is encouraged. Q-E3 Response: Of the options presented Policy E3c appears most sustainable. It allows flexibility in enabling employment training provision to be tailored to any site or development specific context. This is the process followed by other Councils, so there is a proven track record of this approach. Q-E7.1 Response: We agree with the ‘Core Opportunity Area’ identified in Figure 21 of the consultation document and the principle of Option E7.1a. The area identified is a logical focused area for strategic employment growth, covering the main towns and villages within South Warwickshire and incorporating the key junctions and accesses associated with the Strategic Road Network. The HEDNA identifies a need to meet strategic B8 requirements and highlights key locational considerations for assessing the appropriateness of sites. These include road accessibility; power supply; labour availability; and neighbouring activities. It states that there is the potential for the sub-region, specifically South Warwickshire, to play a greater role in providing strategic B8 development, including along the M40 corridor where there “is potential to consider provision at or close to junctions on this corridor within the sub-region”. The proposed Core Opportunity Area appears to positively respond to the HEDNA findings.The Red House Farm site is situated centrally within the Core Opportunity Area, which highlights not only its excellent strategic location for employment growth but also the opportunity for the site to improve connectivity along the M40 and provide an enhanced ‘Gateway’ into Royal Leamington Spa and Warwick within this wider area of opportunity.As noted in the supporting text, South Warwickshire benefits from various sites and businesses which already make a significant contribution to the local and regional economy. These sites and businesses should be protected and retained to allow South Warwickshire to achieve its full potential in both investment and economic output.Importantly, new sites, such as Red House Farm would not detract from the existing employment locations, rather, they would open up further opportunities for investment, both complementing and diversifying the offer available to businesses and investors. Q-E7.2 Response: Whilst the ambitions of including a policy to direct specific types of development to the existing major investment sites is rational, it could have unintended consequences of stifling investment opportunities by placing unnecessary restrictions on existing sites. It could also prevent other sites, which may better suit some occupiers’ requirements, from receiving investment. Consequently, we consider that Option E7.2b should be taken forward. Nevertheless, we agree with the supporting text which, with regard to the Gaydon Area/M40 Junction 12, states “Whilst well-located to the M40, we do not see this location as appropriate for strategic logistic uses (i.e. Use Class B8).” This location is an automotive hub and should be encouraged to capitalise on that status.

E.1.1: - Response: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 4.1 The University considers that the HEDNA evidence provides a basis for identifying future levels of employment need across South Warwickshire. The ICENI report follows the methodology set out in National Planning Practice Guidance, looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a past-trends approach is an appropriate basis for identifying future needs, and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 4.2 For Stratford-on-Avon and Warwick Districts combined, the requirement to plan for 345.2ha up to 2050 is considered to be robust. 4.3 The University is supportive of the principle of carrying out a cross-boundary assessment of economic needs. E2: Response: Option E2a- Include a policy which encourages businesses to be low carbon 4.4 Yes, the University fully supports the Local Plan including policies to support low carbon aspirations. 4.5 Firstly, the University encourages the South Warwickshire Local Plan to take this chance to encourage a reduction in the reliance on the private vehicle in favour of active travel and the Masterplan is supported by a forwardthinking mobility strategy. This seeks to provide innovative transport infrastructure such as mobility hubs to improve travel options and a consolidated delivery hub to reduce congestion on campus whilst also improving air quality. The University is supportive of the use of electric vehicles for business and the Masterplan provides this as a focus. 4.6 The University considers that planning at a large scale, such as the opportunity at the Innovation Campus, allows for a more comprehensive and site wide strategy for reducing energy use through building standards, travel planning and comprehensive drainage strategies. The University is committed to becoming a SMART carbon neutral campus by 2030, through measures such as improving resource efficiency and reducing campus energy demand, generating and storing green energy to support the campus and local communities and embodying the use of SMART technologies across the campus The University supports the principle of low carbon building. E3a: Include a policy expanding on SDC’s existing policy 4.7 Given that the scope of the South Warwickshire Local Plan is that of a part 1 local plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. 4.8 The University does not consider it appropriate to include too much detail on specific sectors to be accommodated, as this risks frustrating the ability of newly emerging sectors to deliver economic growth and is likely to be more vulnerable to wider structural economic changes which may arise during the plan-period. E7.1: Response- Option E7.1a: Include a policy directing employment to the Core Opportunity Area 4.9 Yes, the University believes it important to direct employment, and subsequently economic growth, to the Core Opportunity Area. 4.10 As set out through these representations, the Core Opportunity Area represents an important opportunity for the South Warwickshire economy and represents an area which combines several major investment sites including the University and major road infrastructure aligned to key settlements. 4.11 Therefore, to ensure that the South Warwickshire Local Plan sufficiently realises the potential of this area, it is considered that a policy directing employment to the Core Opportunity Area should form part of the Local Plan, however this should be closely tied to the role of Major Investment Sites to ensure that the crucial role these sites play in the economy is not undermined. E7.2: Response- Option E7.2a: Include a policy relating to additional economic growth at the major investment sites 4.12 The University welcomes the identification of the Campus within the Wellesbourne Area as a Major Investment Site. It considers that promoting economic growth at major investment sites, such as the Innovation Campus, to be of critical importance to the delivery of the Councils’ objectives regarding economic development. 4.13 Major Investment Sites are clearly key economic drivers of the South Warwickshire economy. Therefore, this should be underpinned through the inclusion of a policy which specifically directs economic growth to the Major Investment Sites. This would encourage the capitalisation of the existing high performance of these sites and help to drive inward investment and support the South Warwickshire economy. 4.14 Additional growth of employment opportunities would offer increased resilience to the local economy and assist in increasing the retention of residents in the area. The University is ideally placed to support the diversification of the local economy and support new business sectors, through its acknowledged reputation for excellence in research, training, and innovation and with strong links to business and industry. The University is already one of the area’s biggest employers and a study carried out by London Economics measured the University’s impact on the economy in 2019-20 and found that it generated over £1.15billion for the local economy alone. 4.15 The Innovation Campus is already home to applied research groups from the University’s School of Life Sciences and WMG (Warwick Manufacturing Group), together with over 20 businesses including the Lotus Advanced Technology Centre, Corteva Agriscience, Rimac Automobili, and a host of growing SMEs all of which are critical to the economic future of the region and the UK as a whole. 4.16 The University has a long-term vision for the Innovation Campus, focussed on significant growth, and working together, the University and South Warwickshire can complement the ambitions of each party through the continued promotion of the Innovation Campus as a location for growth. 4.17 It is therefore critical to the local, regional and national economy that the South Warwickshire Local Plan continues to provide a positive policy context for the growth of the Innovation Campus and to help to realise the potential of its extensive landholding to accommodate a diverse range of new employment generating land uses to contribute to the broader economic growth ambitions of the area.

Issue E1: Growing the South Warwickshire economy Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 5.1 Answer – Yes 5.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 5.3 This will ensure the ability to positively plan for economic growth and in turn support the South Warwickshire Economy. Issue E3: Diversifying the economy Q-E3: Please select all options which are appropriate for South Warwickshire 5.4 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 5.5 Given that the scope of the SWLP is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth and is likely to be more vulnerable to wider structural economic changes. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 5.6 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 5.7 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including the University of Warwick Main campus and major road infrastructure aligned to the key settlements of Stratford – Upon-Avon, Warwick and Leamington. However, it is also considered that the role of Coventry should be more clearly reflected in the Core Opportunity Area diagram. 5.8 Therefore, to ensure that the SWLP sufficiently realises the potential of this area it is considered that a policy to direct employment within this area should be included however this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 5.9 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 5.10 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth at the major investment sites. This would allow additional commercial development to take place to help drive inward investment.

Surprised that 70% of South Warwickshire (page 8) is agricultural land but only accounts for 3,700 people employed in agriculture (p15) of. With a population of 273,177 that equates to 1.3%. The SWOT analysis (p18 & 19) is succinct and useful.

2.1 Under the heading “Delivering South Warwickshire’s Economic Needs”, the Issues and Options Consultation identifies a ‘Core Opportunity Area’ (shown on Figure 21 replicated below) which comprises the five main towns, the A46 Trans-Midlands Trade Corridor and the central section of the M40. This includes the University of Warwick's two campuses (one on the edge of Coventry identified as Major investment site no.7 and one at Wellesbourne identified as number 5). 2.2 The Core Opportunity Area aims to attract inward investment in accessible locations to drive the South Warwickshire economy. University of Warwick Main Campus Area 2.3 The University is recognised as a leading employer, playing an important role within the local economy as well as being of national and international importance. 2.4 The Issues and Options Consultation acknowledges the University’s ambition to continue improving and developing its campus, and states that the Plan will “need to ensure that the aspirations of the University can be met, whilst ensuring any impacts of growth are mitigated”. This will be achieved in detail through saved Policy MS1 in the short term, and a review of that policy in the longer term, but equally there are a range of more strategic policies which will impact on the University. 2.5 We are pleased that the Councils are working with the University to update the Masterplan, looking ahead to 2031, and recognise that, beyond 2031, the Plan will continue to support the University as a major employer and support its continued growth and the benefits arising to the local economy and local communities. South of Coventry Area 2.6 The University is also recognised as part of an area to the south of Coventry that is seeing considerable change through strategic housing allocations, the sub-regional employment site south of JLR and the approved gigafactory. 2.7 The authorities are considering further transport investment, including Very Light Rail, a new railway station and the potential for a transport corridor connecting the new A46 Stoneleigh Junction to the University with strategic connections onto the proposed HS2 Interchange at UK Central in Solihull, where the University is partnering on a major healthcare investment. 2.8 Warwick District Council agreed at its Cabinet meeting on 20 April 2022 to progress masterplanning work alongside Coventry City Council, Warwickshire County Council and the University of Warwick which would: • map and understand the planned and emerging developments in the area • explore how to maximise community benefits including through improvements to green and blue infrastructure and connectivity • assist partner organisations in preparing their own masterplans for specific sites and to reflect their aspirations in the wider planning of the area • understand how the climate emergencies declared by Warwick District Council, Warwickshire County Council, the West Midlands Combined Authority and the University of Warwick, should inform the future planning of this area • provide a focus for considering how best to engage with HS2 in terms of how it can bring improvements to the area • provide a context for considering travel and transport improvements in the area, which should prioritise active and sustainable travel but also consider the purpose, justification and business case for a strategic transport corridor • provide a framework and rationale for future business cases and bids to deliver transport infrastructure projects • enable, subject to wider work on growth options across South Warwickshire and any agreement within the SWLP as to the development strategy, consideration of whether, where and how this area may be suitable for further growth as part of the Local Plan. 2.9 The University wishes to remain closely involved in these discussions and will assist in exploring all options to ensure that the campus can continue to thrive and that the University’s ongoing contribution to the South Warwickshire economy, the retention of graduates in the area, and its sustainable development is not thwarted. The University’s Growth Ambitions 2.10 The University of Warwick is now a world class higher education institution, ranked best in the West Midlands, 8th in the UK and 62nd in the world. It delivers over £1billion of economic impact to the region, with over 7,300 directly employed staff and 9,000 additional jobs supported across the West Midlands. 2.11 The main campus has developed over the past decade in line with a 2009 Masterplan and the 2019 Capital Plan Hybrid Permission, both of which were developed in line with existing and emerging policy. 2.12 The University is committed by 2030 to develop one of the world’s most distinctive university campuses, with redevelopment and refurbishment of buildings in its central area, creating a more people-friendly environment, continuing the modal shift towards greater use of public transport and active travel, and transitioning towards net zero through adoption of renewable technologies and other carbon reduction measures as part of its declaration of a state of Climate Emergency in 2019. 2.13 A new Masterplan will look ahead to at least 2030 and will evolve alongside the South Warwickshire Local Plan. Its highest priorities will be to transform the University’s STEM (Science, Technology, Engineering and Maths) teaching and research facilities, provide a new Social Sciences Quarter as the home for Warwick Business School, redevelop some of the original student accommodation on campus providing a net increase in bedspaces, and develop in phases a major new greenspace – the Ecopark – which was announced at the time of the 2021 Scoping Consultation. 2.14 In the University’s representations to the Scoping Consultation in 2021, we set out a number of key points which remain relevant as the Councils explore Issues and Options: • The University fully supports the South Warwickshire Local Plan in taking a long-term view of growth, particularly as decisions around major infrastructure provision need to create certainty and confidence to underpin further investment in the area. • The University’s Mobility Strategy is already driving long term behavioural change towards more sustainable and active travel modes which is recognised through work we are doing with the highway authorities. • The University supports in principle the creation of a new transport corridor, including provision of a new rail station and Very Light Rail route from Coventry City Centre, which would significantly improve connectivity to the HS2 Interchange Station and other key innovation hubs across the region. • These major infrastructure projects, along with the construction of HS2 close to campus, will serve to redefine how people get to campus and, in turn, how the University plans the growth of its campus, whilst improving conditions on the local highway network for residents in south Coventry and Kenilworth. • The University will seek approval for its new Masterplan before the South Warwickshire Local Plan is adopted, in line with existing policies whilst making strong commitments to ever more sustainable development. This will contain growth within its original boundaries whilst incorporating the proposals for the ecopark to the south of campus, providing land for enhancing biodiversity and renewable energy generation as well as a recreational facility for staff, students and the local community. This will be delivered in phases as land is returned from HS2 and once any new transport corridor has been identified. • The University therefore seeks a supportive policy framework within which these proposals can come forward and be approved. It is not proposing any change to the current Green Belt boundary in relation to its growth ambitions for the campus although the University will continue to work collaboratively with the local authorities and other partners to plan more strategically for the area. 2.15 In doing so, the University wishes to play its part in developing wider plans for the area, recognising the catalytic role it can fulfil in meeting the plan’s five objectives.

Q-E6: Protecting Economic Assets 3.5 The University supports Option E6(a) to include a policy which protects South Warwickshire’s economic assets. Those identified including the University are critical to the success of the local economy and therefore it would have strategic significance if their continued success was undermined. Q-E7.1: Directing employment to the Core Opportunity Area 3.6 The University supports Option E7.1a to include a policy directing employment to the Core Opportunity Area. As well as its own direct employment, the University supports many additional jobs in the regional and local economy and the benefits of co-location and accessibility to other economic assets is key both to protecting existing and generating new jobs. Q-E7.2 Additional economic growth at major investment sites 3.7 The University supports Option E7.2a to include a policy relating to additional economic growth at the major investment sites, including the University of Warwick (both main campus and Wellesbourne). These are of strategic significance and whilst detailed Development Management policies can follow in Part 2, the University attaches considerable weight to the support it receives from the local plan.

Q-E2. Please select all options which are appropriate for South Warwickshire Options E2a and E2c. We consider that both of these options are essential components of tackling the climate emergency. Q-E4.1. Please select the option which is most appropriate for South Warwickshire Option E4.1a. Diversification is essential for ensuring that rural areas continue to thrive and make a positive contribution to the local economy. Having a specific policy supporting diversification will help to achieve this. Within the Cotswolds National Landscape and its setting, this diversification should be delivered in a way that is compatible with - and, ideally, positively contributes to – conserving and enhancing the natural beauty of the area. Q-E4.2: Please select the option which is most appropriate for South Warwickshire Supporting small-scale employment opportunities is essential for ensuring that rural areas continue to thrive and make a positive contribution to the local economy. Having a specific policy supporting small-scale employment opportunities will help to achieve this. Within the Cotswolds National Landscape and its setting, these small-scale employment opportunities should be delivered in a way that is compatible with - and, ideally, positively contributes to – conserving and enhancing the natural beauty of the area.

South Warwickshire is made up predominately of agricultural land and approximately half the population lives in rural areas. Planning policy must reflect this is it wants to create a sustainable and vibrant economy. Business and employment opportunities must be equally spread out in order to reduce commuting and to ensure that rural areas are sustainable and are allowed to maximise their potential to the benefit of South Warwickshire.