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

Wellesborne airfield is a travesty, facilitating carbon emitting, noise generating joy riding for a privileged few, whilst failing to recognise this a top quality brown field site for mixed use development, capable of providing housing and jobs whilst protecting greenfield sites.

There is no clear question about the Core opportunity Area under Issue E8. (Shown in Fig 21). This is not a suitable concept and should not be included. The individual industries, further education and research establishments are significant but they do not have much, if any interrelationship, except for the JLR sites. The Fig 21`concept drawing would wrongly imply that there is one. Between the various sites and establishments listed is generally open countryside, some of it best and most versatile agricultural land. The concept plan would risk giving support to industrial development in the countryside if it lies in the zone shown. It should be deleted as not necessary and potentially having adverse consequences.

In setting out its strategy to meet the economic needs of South Warwickshire, careful consideration will need to be given to supporting areas which provide specialist types of employment (i.e. manufacturing and education), and to ensure that the provision of employment opportunities is distributed across all areas of the region. A challenge of successfully implementing the 20 minute neighbourhood concept is acknowledged to be the difficulty in providing an appropriate variety of employment opportunities. In particular, this means providing a suitable variety of employment to enable the local workforce to access their workplace within a 20 minute travel time. In this regard, the opportunity to plan from the outset a new settlement, such as LMA, which incorporates the principles required to successfully deliver a 20 minute neighbourhood should be encouraged over other forms of more piecemeal development. As the HEDNA confirms, Stratford-on-Avon provides an important role in driving economic growth across the sub region, being the 3rd largest economy after Coventry City and Warwick. Stratford-on-Avon has also seen significant housing growth, with notable allocations such as LMA Garden Village, and it is therefore imperative that sufficient growth stimuli are directed towards SoA to continue providing sufficient employment opportunities to match associated housing growth. In this regard, it is important that South Warwickshire provides support for the diversification of economic opportunities at a local level to help prevent out-commuting. This will both support the aim of sustainable development with local residents reducing travel to work by car and also ensure that there is not an outflow of skilled labour from the area. Additionally, there should be an acknowledgement of the shift that has occurred in office based working, with the upward trend of home working and a shift to ‘hybrid working’ where workers spend a larger part of the working week at home. As the HEDNA (2022) confirms, 36% of adults reported working from home at least once in the last 7 days. There will of course be some residents who work much more frequently from home and the design and mix of housing within new development can help to support this.

Comment: E7.2a Support investment at Major Investment Sites and specifically at Long Marston. Issue E7 correctly identifies the Long Marston Rail Innovation Centre(LMRIC). The presence of Porterbrook Train Leasing company at LMRIC since June 2021, offers major investment and employment potential, having already invested £3m in the site and development of Hydroflex trains. It will also put Warwickshire on the global map for rail innovation and expertise. As the UK’s only looped test track and with its connection to the national rail network, providing a unique opportunity to act as a catalyst for growth in the rail technology sector. Long Marston Airfield Garden Village will also offer employment sites in addition to LMRIC.

Issue E9: Supporting our changing town centres The existing Town Centre Boundary for Stratford-upon-Avon includes areas which are not primarily in retail use, while the Primary Shopping Area is focussed on a small number of central streets. The Greenhill Street Site is within the Town Centre Boundary though not within the Primary Shopping Area under existing policy. The consultation document states that a Town Centre study is being undertaken which will look at how much retail will need to be planned for over the Plan period as well as the functionality and vision for Town Centres. This will also look to identify locations of where more detailed information/Area Action Plans may be required. The results of this will be used to inform the Preferred Option. The emergence of this evidence will be useful to inform the strategy for the ground floor units on the Greenhill Street Site. Orbit are keen to work with the Councils to develop an appropriate scheme for the Site which retains active frontages at ground floor level.

Issue E7 Q-E7.1: Please select the option which is most appropriate for South Warwickshire Option E7.1a: We would support the inclusion of a policy directing employment to the Core Opportunity Area, which look to attract inward investment, to drive the South Warwickshire economy. The Plan notes that ‘through the South Warwickshire Local Plan, there is an opportunity to capitalise on the existing economic base and grow this area with further automotive-related manufacturing,’ and it notes that 105ha are already allocated in the Core Strategy for employment purposes. The document goes on to note that; ‘The ability to bring forward employment sites on the scale of 100ha is of regional West Midlands importance.’ Our client’s site, and the wider land holding previously submitted, lies within the COA, and has the potential to make a significant contribution to the aims of the COA. It lies adjacent to the land already allocated, and thus lies close to the motorway and also has the added advantage of proximity to rail. Much of the area identified as COA does not have this benefit, nor of excellent accessibility to the wider highway network. Employment development should therefore be directed to the COA, and to land in close proximity to one of the focus points within the COA, the JLR/ALM site, which lies just on the opposite side of the M40 from our clients’ site. Q-E7.2 Please select the option which is most appropriate for South Warwickshire Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. We would support this option bur consider that the wording should be changed to ‘at and adjacent to the major investment sites’ to facilitate growth and provide the ability for the expansion of the existing sites or co-location with them. Q-E8.1: Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP? We support this proposal in order to provide long term continuity to businesses, and to enable planning for adjacent residential uses.

The delivery of employment land to meet economic needs should not be viewed in isolation to the delivery of residential development. To support local and national economic objectives, it is essential that sufficient employment land is delivered to meet the needs of South Warwickshire and any unmet need from neighbouring Authorities. In location’s where substantial residential growth is proposed, it would be beneficial to increase employment land to support the economic vitality of the settlement and reduce the communities need to travel to access employment. As part of the proposal for Land North of Stratford Road, Warwickshire Property Development Group are proposing to deliver circa 1.8 hectares of industrial land which will be accessible from the existing industrial development and Grafton Lane. This development will make effective use of the previously developed land and will provide employment opportunities to existing and future residents of Bidford. The provision of a local centre and care home along Stratford Road will also provide a small number of jobs for the local community. Boosting the supply of employment land is particularly important to assist in the current economic recovery and to support the creation of a strong, responsive and competitive economy. Elevating the economy of Bidford will have a knock-on effect on the wider area and a prosperous economy can also assist in contributing to local and national environmental and social objectives.

Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? Yes – We consider that detailed policies for tourism, including policies for the provision of new hotels, should be addressed in Part 2 (as with St Mary’s Land Masterplan Allocation), provided that the vision and strategic objectives in Part 1 includes the protection and growth of tourism/visitor attractions as suggested in our response to Q-V3.1.

Issue E8: Existing employment sites The Thwaites site although not an allocated employment site it is well established and the Local Plan Policy EC1 supports new employment development in rural areas in certain circumstances, this includes for sustainable development within Growth Villages. Therefore, other than to say that existing businesses should be fully supported (as pe the NPPF) we have no further comment in relation to the carry over of existing employment sites in relation to question E8.1. Issue 11: Any other economic issues It is recommended that the land shown in the accompanying location plan be removed from the Green Belt. It is required to enable Thwaites, an established business (who has been operating for almost 80 years), to expand in a sustainable way and continue to provide employment for the existing community throughout the plan period.

Warwick Racecourse JCR is the largest racecourse group in the UK by turnover and attendees. It is governed by a Royal Charter and its profits are reinvested in the long term development and enhancement of its racing venues and British racing as a sport. JCR is the longstanding operator of Warwick Racecourse, which is one of the 15 leading racecourses which form part of JCR’s national portfolio. It is a National Hunt racing venue and holds 17 race meetings per annum. Horseracing at Warwick Racecourse has a longstanding history as early as the turn of the 18th century, and it is the first course to host a jump race in the UK. Therefore, it is important to the District and the racing industry in terms of its history and heritage, as well as being part of the social, cultural and economic infrastructure of the District. More specifically, the Racecourse’s primary function as a racing venue, it brings significant economic benefits, as a visitor attraction and an employer. There is a need for Warwick Racecourse to diversify the function of the racecourse facilities in order for the primary function as a racing venue to be financially viable in the long term. in addition to the principal business of the Racecourse as a horseracing venue, there are other complimentary function and activities operated by the Racecourse, which are integral to JCR’s businesses all year round outside the racing calendar. These include: • The Racecourse’s facilities being used for hosting corporate events, conferences, meetings, weddings, exhibitions and trade shows; • The operation of the Caravan Park which is located within the race track; • Hosting a number of community events in conjunction with Rotary Club, the Court Leet, Warwick Lions, contributing valuably to their valuable causes. The Racecourse is therefore a major leisure and sporting venue and visitor attraction in the District. The diverse range of functions and activities provides evidence for the Racecourse’s important role and function as key social, cultural and economic infrastructure. JCR continually strives to improve business operations and will look for opportunities for improvements to, and enhancement of, the existing facilities. In this regard, JCR has a number of key objectives, including: • Securing the long term future of Warwick Racecourse as a National Hunt racing venue through investing in the ongoing improvement to the facilities and business operations, including supporting the provision of a new visitor accommodation. • Giving consideration to the future modernisation and upgrades of the facilities as a major sporting venue and visitor attraction. • Retaining and creating jobs through the year-round employment of administrative staff based at the Racecourse, the employment of additional staff during race meetings and other events, and the potential for further employment through future enhancement of the facilities. JCR seeks to ensure that there is an appropriate planning policy framework for the racecourse, which protects and supports the ongoing operation and future improvements/enhancements of the racecourse and its diverse functions to secure the long term future of the venue as a racing facility. St Mary’s Land Masterplan Policy The Racecourse is within the “Warwick Castle and St Mary’s Land” under Policy CT6 of the adopted Warwick District Local Plan (2017) (‘WDLP’). Within the designation, development will be permitted where it is brought forward in line with an approved Masterplan setting out the development principles and broad areas of development, including the type of uses proposed. The WDLP recognises that Warwick Racecourse provides an important recreation, leisure and entertainment facility and plays an important role in the local economy and community. Therefore, its ongoing vitality and viability of the facility through the development for uses associated with visitor accommodation, recreation, leisure and horse racing is supported provided that they are sensitive to the heritage assets, the setting of the town and ongoing enjoyment of the area for recreational purposes and the need to maintain local biodiversity. A Masterplan for St Mary’s Lands is being advanced by Warwick District Council and prepared by a Working Group which is made up of key stakeholders including JCR. Therefore, JCR is working collaboratively with Warwick District Council and other stakeholders on its development aspirations as part of the Masterplan preparation.

Q-E3: Please select the option which is most appropriate for South Warwickshire 3.45 Rainier is supportive of the emerging Local Plan’s objectives of diversifying the economy to help prevent out-commuting and retain residents within South Warwickshire. A policy which expands on SDC’s current existing policy (Option E3a) setting the principles for economic activity, how much employment provision needs to be provided across each district and where this activity will be focussed (i.e. employment growth locations) is considered to be the most appropriate approach for South Warwickshire in the emerging Local Plan. 3.46 Importantly, the plan should ensure that there is sufficient and appropriate employment land provision available to meet the existing and future needs across all employment sectors in locations where industry want to invest. 3.47 Whilst being informed by assessed needs by sector, there is a risk that having separate policies for individual sectors could be viewed as a limit on the amount of land and floorspace to be delivered, in turn acting as a constraint to growth and the Authorities’ ability to respond flexibly to changing market conditions and unforeseen needs over the Plan period. Q-E6: Please select the option which is most appropriate for South Warwickshire 3.48 Rainer would support the inclusion of a policy which protects South Warwickshire’s economic assets on the basis that any such policy is also accompanied by policies which ensure that there is sufficient and appropriate employment land provision available to meet the existing and future needs across all employment sectors in locations where industry want to invest. Q-E7.1 Please select the option which is most appropriate for South Warwickshire 3.49 Rainier support the inclusion of a policy directing employment to the Core Opportunity Area as a means of encouraging inward investment in the most accessible parts of South Warwickshire. South Warwickshire’s strategic gateway location on the M40 and accessibility to London, the Chiltern Mainline and Birmingham, has already made the area an attractive location to invest and grow a business and capitalising on this will be important for achieving a number of objectives set out within the draft Economic Strategy for South Warwickshire. 3.50 South Warwickshire also exhibits a concentration of skilled residents with approximately 49% of the population have attained high level NVQ4+ qualifications 16. Currently, however, workplace earnings fall below resident-based earning indicating that the areas higher skilled worker are commuting outside of the area for work. Placing new employment development close to labour and consumer markets in the Core Opportunity Area would evidently help to reduce the need to travel and encourage more sustainable patterns growth. 3.51 For these reasons it is considered that Warwick, as one of the main urban areas, should remain focal point for future employment growth in the Core Opportunity area. This reflects wider economic objectives and the potential to attract and accommodate investment in higher value sectors offering employment commensurate to the skills of the workforce and high proportion (58%) of residents living in Warwick and Leamington who already working in the top 3 occupational groups (Managers, directors and senior officials; Professional occupations, Associate Professional & Technical occupations) 17. 3.52 Rainier consider that opportunities to build on existing clusters of employment to the south west of Warwick, an area identified in earlier consultations as a potential ‘Growth Hub’ location, should continue to be explored. This is a highly sustainable and proven employment location with potential to accommodate a mix of employment close to labour supply in Warwick, but also other parts of South Warwickshire owing to the accessibility provided by the A46 and M40. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 3.53 It is of note that the Draft Economic Strategy has set a short-term vision that by “by 2028, Stratford-on-Avon and Warwick District Councils will have contributed to creating a larger, stronger, greener and more inclusive economy” 18. Rainier consider that all potential locations for growth within the Core Opportunity Area need to be considered to achieve this vision. 3.54 Paragraph 8 of the Framework requires employment land of the right type in the right locations to be provided to support growth and innovation. When assessing economic land availability PPG also highlights that employment site suitability, availability and achievability should be guided by market signals, including consideration of the appropriateness and likely market attractiveness for the type of development proposed 19. 3.55 As confirmed in PPG for assessing economic need Authorities should also have regard to trends at a sub-area level and the distinct property market that exist not just between but also within local authority areas 20. 3.56 Analysis of office and industrial property transactions over the past five years reveals demand for employment land and floorspace in locations outside of the major investment sites. 3.57 The HEDNA also reports strong demand relative to supply of both office and industrial floorspace across South Warwickshire. In the industrial market, for example, vacancy rates point to a continued need for the delivery of new industrial floorspace 22, with limited industrial supply remaining in Warwick/Leamington. The principal availability was reported as being the remaining plots at Spa Park and Tournament Fields 23, although in the case of the latter it is understood that a Reserved Matters application 24 for the final vacant development plot was approved in November 2022, adding further weight to the attractiveness and suitability of south west Warwick as a location where the need for additional employment land should be met. 3.58 Only focussing economic growth at the Major Investment Sites would fail to recognise these market dynamics, potential unmet business needs and the suitability and deliverability of other sustainable locations for employment growth. Consideration should therefore be given to other employment growth locations without prematurely discounting sites because they are not already allocated or located at Major Investment Sites. QE8.1: Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP 3.59 Rainier are supportive of this approach in principle, subject to the authorities also undertaking a up to assessment of the ongoing suitability and deliverability of the identified allocations and allocating additional land to meet any identified shortfall. 3.60 Rainier would highlight the following in respect of the existing allocations being relied upon in Warwick District: • Site allocation E1 ‘Land at Thickthorn, Kenilworth’ comprises 8ha of employment land which was the subject of a planning application approved in outline in December 202125. The permission permits the intended B2 and Class E floorspace and therefore has a reasonable prospect of being delivered for its intended employment use. 3.61 It is of note that Warwick District Local Plan 2011-2029 also allocates, at Policy DS16, a Sub-Regional Employment site on the southern edge of Coventry. This site comprises 235ha of which 6.5ha has been allocated to meet employment land in Warwick with the remaining 228.5ha being developed to meet the employment needs of the wider sub-region of Coventry and Warwickshire. In responding primarily to sub-regional needs, the site cannot be relied upon in the emerging SWLP to meet the locally assessed needs. 3.62 The implied employment land supply from existing allocations in Warwick (26.2ha) when added to land with permission (12.71ha) and other land identified as available (23.93ha) reported in the latest Annual Monitoring Report26 (AMR) equates to 62.84ha. Whilst this position is likely to have evolved since the 2020/21 AMR was published, the available evidence suggests that, even where existing allocation are carried over, they will not be sufficient to meet the identified need for 97.2ha in Warwick District. In total some 34.36ha of additional employment land needs to be allocated to meet this quantitative shortfall. 3.63 Employment land supply is Stratford-on-Avon will also be insufficient, with Table 38 of the Council’s latest AMR27 confirming a remaining employment land supply of 179.1ha, comprising 45.7ha with outline permission and 133.4ha from allocated sites without permission. Again, comparing this to the assessed need for 248.1ha would again result in a shortfall of land, with at least 69ha of additional land being required to 2050. This would increase to 169ha where land safeguards for the expansion of JLR is excluded from the available supply. 3.64 It follows that there will be a shortfall of land across South Warwickshire to 2050. Additional allocations will therefore be needed to ensure that sufficient employment land of a suitable quality is available over the plan period to meet identified needs. It is Rainier’s strong view that consideration should be given to new employment opportunities in south west Warwick to meet this need. 16 ONS via Nomis (2021) Annual Population Survey (T19) 17 ONS via Nomis (2021) 2021 Census (TS063 – Occupation) 18 Stratford-on-Avon District Council and Warwick District Council (2023) An Economic Development Strategy for Stratford-on-Avon and Warwick Districts to 2028 – Draft for Consultation (February 2023), p20 19 Paragraph: 018 Reference ID: 3-018-20190722 20 Paragraph: 028 Reference ID: 2a-028-20190220 21 CoStar and Turley Analysis, 2022 22 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 3.64 23 Ibid. para 3.82 24 Application reference W22/1017 25 Application Ref W/20/2020 26 Warwick District Council (2021) Annual Monitoring Report 2020/21 27 Stratford-on-Avon District Council (2022) Annual Monitoring Report 2021/22

Issue E6: Protecting South Warwickshire’s economic assets (incorrect title on page 85: Core Opportunity and Major Investment Sites) Historic England notes that a number of heritage assets are included within the list of ‘Unique economic assets in South Warwickshire’ and are therefore protected under heritage legislation and the guidance contained within the NPPF. Whilst we are aware that heritage can be utilised as a way of strengthening the economy, economic growth should be balanced against protecting and enhancing the historic environment in order to achieve sustainable development through the three interdependent overarching economic, social and environmental objectives set out in the NPPF (para.8). Issue E9: Supporting our Changing Town Centres Historic England recognises the important role of town centres in the economic, social and cultural well-being of an area. We therefore consider that Local Plans should promote their long-term vitality and viability through policies to encourage the restoration of disused and dilapidated historic buildings into new homes, shops, workplaces and community spaces, restoring local historic character and improving public realm. Issue E10: Tourism Historic England recognises the significant role that tourism plays in the economy of South Warwickshire and is supportive of the Local Plan helping to create the conditions for a thriving heritage and cultural sector. Given the importance of tourism in the area we consider that it plays a spatially strategic role and therefore should be addressed in Part 1 of the Local Plan and not left to be addressed in Part 2.

Issue E10 – Tourism In response to Q-E10, Bourne Leisure strongly considers that tourism should not be only addressed in the Part 2 SWLP. Referring back to Bourne Leisure’s comments made at the Scoping Consultation stage, the tourism industry is of strategic importance to South Warwickshire. The rationale for not including a Part 1 SWLP tourism policy is noted, although this is inconsistent with the approach taken elsewhere in the consultation document where non-strategic policies are being considered to be taken forward in the Part 1 SWLP. Such non-strategic policies include matters of landscape and heritage. As the consultation document recognises the importance of tourism to the economy of South Warwickshire, a Part 1 policy setting out an overarching approach to tourism would reaffirm the economic and social role of tourist assets in South Warwickshire. This is particularly important given how tourism assets need to continue to evolve to meet visitor expectations and how the visitor economy has changed as a result of the Covid-19 pandemic. A more detailed Part 2 tourism policy can then be based on the overarching Part 1 tourism policy if necessary

The importance of shifting to a low carbon economy is understood and shared. If a specific policy which encourages businesses to be low carbon is brought forward – as per Option E2a of the consultation document – emerging low carbon objectives and requirements must be based upon a justified evidence base that is informed by technical feasibility and viability across all sectors. Such a policy should align with the wider transition to a low carbon economy over the proposed plan period, to reduce the prospects of adopting carbon reduction requirements that are too onerous to meet for rural businesses, such as tourism venues that typically are located in countryside locations. Emerging low carbon requirements will, therefore, need to be established within a clear and positive framework so that all types of existing businesses can continue to invest in South Warwickshire. Closely linked to the above, regardless of whether a specific rural diversification policy is brought forward (as per Option E4.1a) or rural diversification is factored into a broader economic diversification policy (as per Option E4.1b), Bourne Leisure considers that there is a need to ensure that the Part 1 SWLP clearly establishes how existing rural businesses, such as Warner Leisure Hotels, will be supported and encouraged to invest so they can assist in delivering the objectives of the emerging plan.

Economic Needs The HEDNA shows that 345ha of office and industrial land is required across South Warwickshire to 2050. In addition, South Warwickshire will take a proportion of 709ha that the HEDNA identifies is required to be distributed for B8 purposes. Stoford await the Council’s apportionment of this figure before offering further comment on whether the needs of the two Districts are being catered for sufficiently. Stoford note the options at Q-E3 within the consultation material, and we support a policy approach that sets out the overall employment land requirement, as opposed to a criteria based policy that would limit provision to certain sectors. It is important that the Plan remains flexible, and able to respond to changes within the market, especially given the prior of the Plan to 2050. Core Opportunity Area and Major Investment Sites Within Issue E7 of the consultation material, the matter of the Core Opportunity Area (COA) (Figure 21) and Major Investment Sites is discussed. The supporting text on page 88 states: The Core Opportunity Area looks to attract inward investment to drive the South Warwickshire economy as well as encourage inward investment in the most accessible parts of South Warwickshire. Stoford believe that the COA could be extended to include the area of land centered around junction 3 of the M42. This could extend either side (north and south sides) but would enable this key motorway junction, served by local rail stations including Earlswood and Wood End, to deliver on this aim of attracting inward investment and being one of the most accessible areas within South Warwickshire. The strong rail connections, bus route (along the A435) and motorway junction underpin this view. We accept that the area if selected may not necessarily be joined to the COA proposed boundaries, however this should not detract from the facts that this location is comparable and in many cases performs better in terms of sustainability, than other areas on the fringes of the proposed COA. Therefore, in response to Question E7.1 of the consultation material, as it currently stands, directing employment (which we take as all employment) to the COA proposed, is rather limiting and does not take the Plan to a position whereby opportunities for responding to market signals and securing strategic employment sites within walking and cycling distances of rail stations are taken account of. Stoford do acknowledge the role of the COA, however this should either be extended to fully apply to the most accessible parts of South Warwickshire (which it currently doesn’t); or, any such policy for directing employment to the COA, should not be limiting in its approach. Therefore, being clear that there are places currently not in the COA, that offer equal or better levels of accessibility and have a stronger market facing presence. Stoford also support the proposition of question E7.2, that recommends Major Investment Sites (MIS) could cater for additional employment needs. We would add that the suggestion of sites being used for ‘specific employment uses’ only is exercised with caution. We note the JLR site at Gaydon Lighthorne Heath for example and how this site has been effectively kept aside for one specific end user. In locations where this is associated with a major employer already located nearby, this is understandable to a degree, however new MIS if pursued should not stand mothballed and undeveloped from one five-year period to the next. Any criterion should allow for the review of the site and the specified uses, thus allowing for changes within the market sectors to be fully accounted for and not ruled out because of an overly restrictive policy/allocation. Further details on the suitability of land south east of junction 3, M42 are included within the enclosed Vision Document, submitted alongside this letter of representation.

There is quite a large section on the Economy in which the rural economy gets a mention. We should encourage them to keep thinking about this. The main bit is however about the “Core Economic Opportunity Area” – the corridor from Stratford to Kenilworth via Warwick – which underlines the expectation that most development will be in the north.

Q-E.1.1 – Do you think the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? The HEDNA advises at Table 6.5 – Projected Growth in Employment by District, that Stratford-on-Avon and and Warwick District’s employment levels are expected to increase by 11% and 14% respectively during the Plan period. The Draft Plan highlights that South Warwickshire has been successful over many years in attracting major employers across a range of high value sectors, notably vehicle design and engineering, software and games development and HQ and professional and financial services. It has also benefited from a robust tourism sector, linked to its various cultural assets such as Stratford-upon-Avon and Warwick Castle. The area benefits from a strong strategic highways network including the M40 and A46 that make it an attractive area to invest. The HEDNA states that the strategic road network lends itself to logistics operations and there is strong interest from occupiers, but there is concern that logistics do not maximise the economic potential for South Warwickshire. It is also advised that the area has failed to capitalise on the strength of existing sectors and skills of the workforce. In accordance with the findings of the HEDNA the Draft Plan confirms that the South of Coventry Area has started to see and will continue to see considerable change. This includes the sub-regional employment site to the south of Jaguar Land Rover’s Head Quarters at Whitley that is under construction. Warwick University is situated within this area and can help facilities high quality job creation. Coventry Airport is also located within the area. A planning application has been granted for a gigafactory for battery production on the airport site to support the country’s shift towards electric vehicles and ultimately carbon neutrality. This development would have the potential to complement existing facilities in the area including the Battery Industrialisation Centre on Whitley South, facilities at JLR and Warwick Manufacturing Group at the University. Significant transport infrastructure improvements have been implemented, are ongoing and are being explored in the area. These include a new bridge over the A45 and transport improvements to connect JLR/Whitley Business Park to the new sub-regional employment site comprising Whitley South and Coventry Gateway. A new £38m scheme under construction will see a new bridge across the A46 and realigned slip roads forming the basis of a new signalised gyratory system at the Stoneleigh Junction of the A46. Further transport investment is being considered in the area, including whether the Very Light Rail project led by Coventry City Council that could serve the university and development in this area. The potential for a new railway station near Kenilworth is being explored. A potential transport corridor, potentially incorporating Very Light Rail and to cater for other sustainable travel modes connecting the new Stoneleigh Junction to Warwick University and with strategic connections towards the proposed HS2 Interchange at UK Central in Solihull is also being explored. The SWLP should seek to maximise the employment opportunities presented by high value sectors in this location. The HEDNA confirms the opportunity for the local economy to grow. As detailed in our call for sites submission, Stoneleigh Park and Kings Wood Business Park should be key allocations to facilitate employment growth and take advantage of the opportunities to grow high quality jobs in this location. We support the HEDNA’s conclusions that a minimum of 345.3 hectares of land for office and general industrial uses is required, however, it is not clear from the conclusions of the HEDNA how research and development floorspace and other forms of floorspace have been considered. For example, it is advised that there is a need for separate allocations for B1(c) – Light Industrial (now Use Class E(g)(ii)), alongside B2 allocations. However, the employment land needs tables in the HEDNA (Tables 15.2 and 15.3) and Table 8 of the Draft Plan, specifically to office and general industrial land, with no reference to research and development or light industrial land. It should be clarified if the 345.3 ha employment land required includes research and development and light industrial land, or if there is a separate requirement for these types of land. We also support the recognition that in addition to this Stratford-on-Avon and Warwick district should play an active role in delivering a proportion of the 709 hectares of strategic B8 employment land required in the Coventry HEDNA area during the course of the plan period. This should form a separate element of overall employment allocation. As a final point, it is our view that the employment requirements of the plan should be treated as absolute minimum. The emerging plan is expected to run until 2050. It is highly likely that there will be significant changes in the economy during the course of the next 27 years. The emerging plan should include a suite of flexible policies designed to support economic growth throughout the plan area and maximise the opportunities presented by the plan area. Option E3a – Should the SWLP include a policy expanding on SDC’s current existing policy? We support the inclusion of a policy in the SWLP that sets out the principles for economic growth and also provides a minimum employment land requirement, as referred to above. In this regard we note that it is advised that South Warwickshire has an existing high skilled and qualified workforce that should be supported. This is in combination with a large number of people employed in hospitality, retail and tourism sectors. It is imperative that the SWLP makes provision for a range of different employment types in a variety of locations to boost the local economy. Option E3b – Should the SWLP have separate policies for individual sectors? Given that the plan period is scheduled to run to 2050 the SWLP’s employment policies need to be flexible and capable of adapting to changing circumstances as the local and national economy evolves. That being the case, whilst we have no particular concerns with inclusion of policies in the SWLP for individual sectors, however, they cannot be overly prescriptive. The policies in the SWDP should be designed to support all forms of employment development and not put in place any form restrictions that could prevent economic growth in sustainable locations. This would reflect the objectives of paragraph 81 of the NPPF, that states that planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential. Option E3c – Should the SWLP include a policy that secures employment strategies through S.106? It is suggested that the SWLP could include a policy that seeks to reserve certain jobs for local people. This is problematic. In the first instance, we are concerned that such a policy may not be fair or legally appropriate, given that it would prevent people from outside a certain geography applying for jobs. In addition, what constitutes a “local person” is not clear. This approach could also have a potential to reduce the amount of labour available to support the local economy. It could prevent people from outside the plan area moving to South Warwickshire for work. Q-E4.1 – Sustaining a Rural Economy We support the inclusion of a policy in the SWLP that seeks to support the rural economy. This approach is in accordance with the guidance contained in the Supporting a Prosperous Rural Economy section of the NPPF. Stoneleigh Park is a large scale employment site that is over 100 ha in size. It is one of the largest employment sites in the plan area and has historically had a rural activity focus. However, Stoneleigh Park needs to evolve. HS2 now passes through the Park making it less suitable for a variety of the uses that have taken place there historically. Furthermore, as a consequence of HS2 and extant planning permissions there are now large parts of the wider estate that comprise, or could become, previously developed land that will need to be repurposed. These sites are well suited to large scale employment development. The site falls within the Economic Strategy for South Warwickshire Area and is in close proximity to the large scale residential development, including Kenilworth and the built up edge of Coventry. There is the opportunity to deliver large scale new employment development in a highly sustainable fashion. Further details of this matter can be found in our Call for Sites submission in respect of Stoneleigh Estate. Q-E6 – Should the SWDP include policies that protect South Warwickshire’s economic assets We fully support the inclusion of a policy in the SWLP that seek to protect the growth of South Warwickshire’s economic assets. We also fully support the identification of Stoneleigh Park as one of these economic assets. As detailed in our Call for Sites submission, Stoneleigh Park is a key employment site both nationally and regionally. It supports a large number of jobs and businesses. Its role has, however, been significantly affected by HS2. HS2 has reduced the amount of land available on site for events and has also made it a less attractive location for certain businesses that are adversely affected by high speed rail. It is, therefore, essential that the SWLP includes a policy supporting the growth and evolution of Stoneleigh Park as a consequence of HS2 and the changing economy. In addition to the Park itself, it is necessary to include positive policy guidance in respect of the estate as a whole. HS2 has resulted in the creation of a large compound area within the estate that is previously developed land. Furthermore, planning permission has been granted for other buildings outside of the estate boundary that can introduce significant new development into the Green Belt. The SWLP should include a policy to guide the development of these sites to ensure that the best use is made of these brownfield assets. Indeed, the HS2 compound in particular should be re-purposed once it is no longer required by HS2 and brought forward for a beneficial use. The compound is located next to the A46 where the Stoneleigh Junction has been upgraded. It also benefits from road infrastructure put in place with the HS2 works. As detailed in our Call for Sites submissions, it can help create a new gateway to Stoneleigh Park, provide a bypass to Stoneleigh village and facilitate for regeneration of the wider area. Q-E7.1 – Should the SWLP include a policy directing employment to the Core Opportunity Areas We fully support the SWLP including a policy that directs employment development to the Core Opportunity Areas. We welcome the acknowledge that “Stoneleigh Area” is designated a Core Opportunity Area by the emerging Plan. Stoneleigh Park is a major site in the Green Belt and the home of the number of important countryside organisations. The Park plays an important role in hosting events and shows and is established part of both the local and national rural economy. We also welcome recognition that the Park will be “significantly” impacted by HS2 and this necessitates changes to the Park. The SWLP provides an opportunity to assess the use and purpose of the site and the density of development within it. It also provides the opportunity to explore and improve access to and through the site with potential benefits if the main entrance is repositioned to the north-western section of the Site with access coming from a new A46 Stoneleigh junction. This would redirect traffic through Stoneleigh Park and have a positive impact on Stoneleigh village. Q-E7.2a –Should the SWLP include a policy relating to additional economic growth at Major Investment Sites We fully support a policy directing additional employment growth to the Major Investment Sites and the identification of Stoneleigh Park, an existing Major Investment Site (Site 8). As detailed above and as referred to in our Call for Sites submission, this site is ideally placed for significant new employment development.

Q-E2: Given our reply under Q E1.1 above, the ability now to provide low or zero carbon employment growth together with environmental recycling should be the aim for new employment locations and particularly in sustainable settlements and not just in the major towns for South Warwickshire. Q-E4.1: Bearing in mind our replies on the various issues above relating to the economy, sustainability, sustainable travel and provision of new employment, provision of some employment land to assist rural diversification of the economy is important. Q-E5: This question is badly worded in that there are actually no options listed. However, sites have to be sufficiently large to provide the range of “grow-on” accommodation that is suggested is required. This is really more applicable to the provision of new employment in or adjoining existing towns. For instance there really does need to be provision for “new grow-on accommodation” at towns in South Warwickshire, like Alcester, or alternatively on land adjoining small employment areas in rural settlements such as at Claverdon. Q-E6: This question is again badly worded because there are no specific options but where in a sustainable rural location new business opportunities provide themselves, particularly in conjunction with farming and agricultural production then support should be given through this emerging Local Plan for such opportunities as farm shops, farm cafes, farm-related tourism ie visitations by the general public to farming operations of interest. Q-E8: There are small existing rural employment sites that really need further consideration and expansion where an appropriate opportunity is available.

Q-E2: Please select all options which are appropriate for South Warwickshire: Option E2a: Include a policy which encourages businesses to be low carbon. This is essential in order to address the climate crisis. Option E2c is particularly inappropriate, as illustrated by the gigafactory site which has failed to attract a suitable business. Q-E7.1: Please select the option which is most appropriate for South Warwickshire: Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. The identified Core Opportunity Area is mostly greenfield with much of it in the Green Belt. As indicated under Q-V3.1, this proposed Area conflicts with the Strategic Objectives. Development at Stoneleigh and South of Coventry are particularly inappropriate because they are in the Green Belt. Option E7.2b: Do not include a policy relating to additional economic growth at the major investment sites. As noted under earlier questions, the policy should be to encourage economic growth by re-use of existing buildings and redevelopment of brownfield sites, not development on greenfield sites.

Q-E2: Given our reply under Q E1.1 above, the ability now to provide low or zero carbon employment growth together with environmental recycling should be the aim for both new employment locations and particularly in sustainable settlements, such as at Hatton Park, and not just in the major towns for South Warwickshire. Q-E4.1: Bearing in mind our replies on the various issues above relating to the economy, sustainability, sustainable travel and new employment with particular provision for some employment land to assist rural diversification of the economy seems to us to be very important. Q-E5: This question is poorly worded in that there are actually no options listed. However, sites have to be sufficiently large to provide the range of “grow-on” accommodation that is suggested is required. This is really more applicable to the provision of new employment in or adjoining existing towns. Q-E6: This question is again poorly worded because there are no specific options. However, where in sustainable rural locations such as Hatton Park new business opportunities can provide themselves, particularly in conjunction with farming and agricultural production. We believe that support should be given through this emerging Local Plan for such opportunities as farm shops, farm cafes, farm-related tourism ie visitations by the general public to farming operations of interest. Q-E8: There are small existing rural employment sites that really need further consideration and expansion where an appropriate opportunity is available.

Q-E7.1: The SWLP highlights that this policy would look to direct employment growth to the Core Opportunity Area with areas outside of this, providing opportunities for more local investment. Supporting Figure 21 Core Opportunity Area sets out the spatial extent of the Core Opportunity Area and includes Southam and the Former Southam Cement Works site. We would welcome employment development in this location as it represents a logical location for employment which follows the principles of a 20minute neighbourhood . Again, we would welcome further discussions with Officers.

Issues E6 and E7: Core Opportunity Area and Major Investment Sites With good access to the M40 and M6 and two railway lines, the South Warwickshire Plan area is an important strategic location for large employment sites of regional significance which could help serve the wider West Midlands area. Birmingham City Council has recently evidenced a shortfall of 73.64ha of employment land against its identified need to 2042 through its Issues and Options Consultation Document but also lacks the opportunities for further large employment sites. The City Council would therefore support proposals within the South Warwickshire Plan which protect major investment sites, particularly those which would have the potential to provide wider regional economic benefits for the West Midlands.

Q-E7.1: 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.

Issue E4: Sustaining a Rural Economy Q-E4.2: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land prefers Option E4.2a: Include a policy supporting small-scale employment opportunities in rural areas for the reasons given in the consultation paper. It will encourage the growth of small scale businesses in rural areas, support local communities, and reduce the need for many to travel. Issue E7: Core Opportunity Area and Major Investment Sites Q-E7.1: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land prefers Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. The creation of a Core Opportunity Area may have a negative effect, taking potential businesses away from the District. Potential employers may see the policy as preventing economic development elsewhere, and it may unnecessarily raise land value in the Core Opportunity Area making it less affordable to smaller occupiers. Current employment policies are generally seen as successful but there needs to be more support for employment opportunities in rural areas which could cut commuting distances. Issue E10: Tourism Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? Rosconn Strategic Land considers that a policy promoting and supporting tourism, which isan important element of the local economy, is an essential part of the emerging Local Plan. Rosconn Strategic Land would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.

It is reasonable to conclude from the 2022 HEDNA that there is a sizeable quantitative need for further employment land in South Warwickshire. In terms of how this need is captured in the SWLP, we would recommend that the plan include a single policy setting out the level of employment provision required over the plan period (Q-EQ: Option E3a). We also suggest that any figures relating to the provision of employment land are expressed as ‘minimum’ or ‘approximate’ to remove the risk of perceived ceilings on employment development. The use of ‘minimum’ or ‘approximate’ prefixes would provide flexibility so that the SWLP can adapt to any changes in the employment market and respond positively to inward investment opportunities, thus helping maximise the economic potential of South Warwickshire. The Councils’ stance on promoting employment and skills for local people as part of the development process is something we support. However, we do not feel it is necessary for the SWLP to include a policy that secures employment strategies by a planning obligation (Q-E3: Option E3c). It is in the Councils’ gift to request that a developer submit a scheme detailing arrangements to promote employment and skills development opportunities for local residents throughout the construction and/or operational phase of a development by way of an appropriately worded planning condition. We consider the use of a planning condition a more appropriate and proportionate basis in which to pursue this aim.

Protecting and enhancing South Warwickshire’s economic assets There are a number of unique economic assets across South Warwickshire that together comprise the foundation of the local economy. We agree that the SWLP, along with the Economic Strategy, should seek to capitalise on these assets and maximise and enhance their economic potential. As noted in the consultation document, the Councils’ development plans do not include a policy which protects all these unique assets; however, there are several policies which refer to specific assets and look to protect them, e.g., Policy AS.9 of the Stratford-on-Avon District Council Core Strategy and Wellesbourne Airfield. Core Opportunity Area and Major Investment Sites The consultation document identifies an economic ‘Core Opportunity Area’, comprising the five main towns, the A46 Trans Midlands Trade Corridor, and the central section of the M40. It further notes that the Core Opportunity Area looks to attract inward investment to drive the South Warwickshire economy as well as encourage inward investment in the most accessible parts of South Warwickshire. In our view, the broad geographical extent of the Core Opportunity Area has been correctly identified. We, furthermore, endorse the Councils’ identification of Wellesbourne Airfield and the University of Warwick’s Wellesbourne Campus as major investment sites within the Core Opportunity Area. To reflect that status of Wellesbourne Airfield as a major investment site, we would suggest that the Councils amend future iterations of ‘Figure 21 – Core Opportunity Area’ to include reference to the airfield in the plan’s key. In terms of a policy approach, we are content for the Part 1 SWLP to include a policy which looks to direct employment growth to the Core Opportunity Area (Q-E7.1: Option E7.1a). We agree that the Core Opportunity Area is a highly accessible and sustainable geographical area for major employment development to occur, where it can attract significant inward investment to drive the South Warwickshire economy. We agree with option Q-E7.2A that the policy should allocate additional employment land within the Core Opportunity Area and consider this should include the Wellesbourne Mountford Airfield Site (with retained airfield). Allocating land for employment uses at the major investment sites would provide certainty for both the Councils and future developers and ultimate end users, as well as increase the potential of meeting the overall employment land needs of South Warwickshire. Any identification in policy of the specific employment uses considered permittable at the major sites must be reflective and relevant to each individual site. The establishment of development principles could provide a useful tool in guiding the preparation and implementation of proposals at the investment sites. It is important, however, that these principles are viewed and expressed as guiding criteria for development and not absolute requirements.

We are concerned that the plan hasn’t considered local habitats and biodiversity in enough detail in their growth strategies, with a number of chosen growth areas directly adjacent to the important River Avon and River Leam and their tributaries. As well as a number of key Local Wildlife Sites. The Councils also urgently need to assess their ‘Potential Local Wildlife Sites’ to give them more weight, especially in the south as these should have full LWS status, and should be informing the growth strategy early on. The Wildlife Trust understands that growth needs to happen, and growth can still happen alongside nature preservation and recovery. The Growth options shouldn’t just look at housing, further sites and areas need to be allocated for nature recovery in order to meet the needed targets of 30% of land in nature recovery by 2030. We are particularly concerned that the ‘Dispersal option’ includes a number of large settlement actually in the Area of Outstanding Natural Beauty (AONB), this isn’t considered a legally sound Option in line with the Sustainability Appraisal. The NPPF states ANOB should only be considered in exceptional circumstance and Para 76. States ‘the scale and extent of development within all these designated areas should be limited’. WWT is also concerned that NOT reviewing the green belt hasn’t been considered as a clear option, in line with Sustainability Appraisals requirements. This key designation retains open areas for wildlife, stops settlements joining and works with designations outside of S Warks. We are concerned that a number of important Local Wildlife Sites and Potential LWSs are located in the proposed growth areas, including a number of key SSSIs and the Nature Improvement Area and the following: Leamington- Warwick Racecourse Nursery Wood and Newbold Comyn LWS’s and the Grand Union Canal LWS. Southam- Long Itchington quarry, Bishops Hill and Bishops Bowl LWS, Ufton Hill Farm Fields PLWS NE- Thickthorn wood stoneypark wood NW- Hays wood River Alne, Coughton Park LWS South- River Stowe LWS West - River Arrow, Springs, Three Oakhill, The Belts Wood and Old Pack Woo LWS SW- Long Marston Disused Airfield and Doctors Farm LWS SE- DM Kineton, Bomb crater pool North- Henley Meadows LWS Dispersed method -includes Oversley Wood LWS amongst others All these known sites are key natural capital assets and should not be used for development. In addition new sites of habitat creation areas should be allocated to address the current low level of biodiversity. Regarding Flood risk, the Councils will need to carry out a detailed Flood risk assessment and land in the flood plain shouldn’t even be considered as a suitable ‘Options’ in line with the Sustainability Appraisal requirements.

2.35 Response: The consultation document notes that ‘Tourism makes up a significant chunk of the area's economy, and it will be important to support this where possible’ and that ‘One particular issue in relation to tourism is the lack of affordable accommodation, which prevents larger tour groups staying overnight, resulting in many 'day trippers'. Day trippers are known to spend less within the town, with those staying overnight spending on average £400 in comparison to £40. This issue also extends to the provision of accommodation for conferences and other business uses.’ 2.36 It is considered that tourism is an important issue that the Local plan will need to address and plays a spatially strategic role, and should therefore be addressed in part 1 of the South Warwickshire Local Plan. 2.37 Some allocation 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 the allocating of land for employment development where the land is not then brought forward into development. The SWLP must allocate new land for employment, including tourism and leisure uses (such as hotels) on the urban edge of the main settlements, the land must be suitable and attractive for new inward investment.

DLPDS would support option E7.1a and directing employment growth to the Core Opportunity Area, which includes Abbey Park. It is important that any allocations reflect demand for employment uses. The marketing initiative undertaken for the consented office development at Abbey Park suggests that there is low demand for standalone office developments at this location.

Option E2c: Wellesbourne Matters supports a policy which looks to identify sites or development zones which are targeted at businesses wishing to be innovative towards a low carbon economy. Businesses and R&D facilities working on electric power-trains and alternative fuels within aviation are exactly the type of businesses that should be encouraged to relocate or start up in the district. Having access to an airfield with suitable hard runways alongside modern offices, workshops and hangars would be essential in order to attract participants in this fast-growing industry sector. With regard to question Q-E5 Option E5a: Wellesbourne Matters supports a policy which encourages a range of business units of differing sizes. The current lack of provision for small and start-up businesses in and around Wellesbourne would be mitigated by allocating small areas of land at Wellesbourne Mountford airfield for appropriate employment development for this sector. Option E6a: Wellesbourne matters support a policy which protects South Warwickshire’s economic assets. Once an economic asset is gone, it is often difficult and extremely expensive to get it back again. Wellesbourne Mountford airfield for example was built at vast expense to the public purse and still continues to function 80 years later. To build a new airfield of this quality today would be quite difficult so it is better to protect and benefit from what is already in place. With regard to question Q-E8.3: Wellesbourne Matters agrees that proposals seeking the loss of a business, commercial or community building or facility should be subject to marketing, viability and alternative use tests. With regard to question Q-E8.4: Wellesbourne matters consider that an appropriate test for a proposed loss of any building or facility would be to determine if any difficulties might arise concerning the ‘replaceability’ of the building or facility at some other location within the district. If a building or facility is found to be irreplaceable then that should factor strongly in any decision to lose the building or facility in the first place. With regard to question Q-E10: Wellesbourne matters do not agree that Tourism should only be addressed in Part 2 of the South Warwickshire Local Plan. One aspect of tourism that has a significant effect on the spatial planning of an area is the ability for tourists to continue to arrive by air. With regard to question Q-E11: Wellesbourne Matters supports a policy framework that addresses South Warwickshire’s economic needs by encouraging greater participation in the expanding aviation service and support industries.