Q-E11: Please add any comments you wish to make about delivering South Warwickshire's economic needs
CULTURE The councils should look at an inclusive cultural strategy, which benefits local residents as well as visitors, and develop a model of sustainable tourism. Sustainable tourism has a positive economic and environmental impact on the social fabric of the host communities, on the physical environment and ecological landscape. • South Warwickshire should promote high quality cultural tourism, including encouraging tourists to stay longer and visit other parts of the district with well though policies. • Promote tourism which impacts positively on the host communities and businesses. • Draw up a tourism strategy which benefits local people, small, independent businesses instead of multinational corporations.
QE2 Please select all options which are appropriate for South Warwickshire. This should be addressed in Part 2. Q E 4.1 Please select the option which is most appropriate for South Warwickshire Option This issue should be addressed in Part 2 QE 7.1 Please select the option which is most appropriate for South Warwickshire Claverdon supports Option E7.1a as that provides opportunity for housing growth in areas with infrastructure to meet the needs of the increasing workforce without the necessity of using green belt land or viable farmland. QE 8.1 Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP? Claverdon would need more time to consider this so, it’s a don’t know QE8.3 Do you agree that proposals seeking the loss of a business, commercial or community building or facility should be subject to marketing, viability and alternative use tests? Claverdon supports this proposal as essential to protect assets
Q-E2: E2a. Yes with prioritisation for thiose who are more sustainable, but also E2c which mitigates E2b Q-E3: E3b is too restrictive, this should be left to an open market economy Q-E6: Agree with E6a but has to be a fluid policy on a case by case basis as the economic demands change Q-E9: Very hard one to answer and we may have a clearer view in the next round. Option E9a feels least restrictive at this pointand certainly taking a holsitic view of retail across the district can't be a bad thing. Q-E10: 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 imapct that these developments and associated economic plans will have a direct impact on workforce that feed the tourism sector.
Issue E8 – Atherstone Airfield Industrial Estate Introduction The representations refer to the existing employment site at the Atherstone Airfield Industrial Estate which is the subject of Issue E8 in the current Issues and Options Consultation and is also the subject of Proposal SUA.4 in the adopted Core Strategy for Stratford-on-Avon District Council. The representations seek to; To make more efficient use of land by increasing the net to gross ratio commensurate with normal development industry standards. To remove the policy restrictions in the adopted Core Strategy which generally limit occupation to employers relocating from the Canal Quarter or from elsewhere in the District and which limit the occupiers to particular Use Classes of development. To increase the size of the employment allocation by the inclusion of land east of Shipston Road to provide greater choice and flexibility for potential occupiers to encourage greater investment and economic development in the District, consistent with the need for more employment land as stated in the evidence base. Supporting Text to Proposal SUA.4in the Site Allocations Plan Revised Preferred Options (June 2022) The explanation to the proposal (Paragraph 7.2.1) in the Site Allocations Plan Revised Preferred Options (June 2022) refers to the allocation of the site specifically for the relocation of businesses from the Canal Quarter in Stratford-upon-Avon and for businesses to relocate from elsewhere in the District. The text states that it is apparent that most industrial estates in the District are very well occupied with few vacant units. It adds that; ‘However, since the Core Strategy was adopted, it has become apparent that there is very little interest from businesses in the Canal Quarter to relocate to this site.’ The explanation adds that the location provides an opportunity for businesses in the District to relocate for operational reasons or to expand. It also states that some flexibility for businesses outside the District to move to the site may also be appropriate in order to facilitate implementation for its principal purpose stating that this is line with responding flexibly to changing circumstances as required by the National Planning Policy Framework (NPPF). The explanation (Paragraph 7.2.3) also states that the Inspector who examined the Core Strategy found the site to be well located in relation to Stratford-upon-Avon with direct access on to the A road network and a frequent bus service that runs along Shipston Road. It also states that the Alscot Estate is an established business location with readily available infrastructure. Evidence Base The Coventry and Warwickshire Sub-Regional Employment Market Signals Study (Executive Summary and Main Report) were published in July 2019. The reports form part of the evidence base of the Site Allocations Plan. The broad conclusions set out in Paragraph 9.25 of the Main Report (Page 86) state that; ‘There is clear evidence of existing and future demand for both industrial land and premises in the Coventry and Warwickshire area, above and beyond existing levels of supply.’The opportunity exists to increase the site area of the employment allocation at Atherstone Airfield to contribute to meeting the shortfall in land supply which is set out in the report. Making more efficient use of land Government guidance is clear in the need to make more efficient use of land as set out in the NPPF (Paragraph 124) with which developing the site at a greater net to gross ratio i.e. developing at normal market densities for industrial development with substantial on-site landscaping. The Vision Document and the supporting landscape document prepared by Fpcr also show the commitment to deliver substantial and additional off-site landscaping. An increase in the developable net to gross ratio from 53% to 76% would continue to allow a significant area of land to remain open in character and provide an attractive landscape setting for future employment development. Increasing flexibility for occupiers Relaxing the policy restrictions on potential employment uses and potential occupiers on the site would encourage further economic development in the form of new investment and jobs. The relaxation of policy restrictions is required to enable the viable and fundable delivery of infrastructure necessary to provide serviced employment land available for development. Investment in highway, drainage and utilities infrastructure will be on a speculative basis and unjustified policy restrictions on potential occupiers is likely to increase the risk of such funding not being available. A modest proportion of the employment allocation at Atherstone Airfield Industrial Estate could be safeguarded to provide for the future relocation of existing businesses within the District such as the Canal Quarter for an agreed period. A larger employment allocation to provide more choice for occupiers The District Council accepts that the location is an appropriate one for further employment development. The proposal to extend the size of the employment allocation by 23 hectares would provide additional choice and flexibility for potential occupiers and make best and efficient use of the investment into the infrastructure. This would be consistent with Market Signals Study in the evidence base which refers to the unmet demand for employment land in Coventry and Warwickshire Conclusions The land at Atherstone Airfield Industrial Estate is acknowledged to be a well located employment site. The local plan policy restrictions have hindered the potential for more inward investment and economic development.The existing Core Strategy employment allocation at Atherstone Airfield Industrial Estate should be retained in the preparation of the South Warwickshire Local Plan, subject to a less prescriptive policy approach in relation to occupiers and a more efficient use of land, together with an increase in the size of the employment allocation. A less prescriptive planning policy approach which provides for a more efficient use of land, a more open approach to the types of employment development and allowing occupiers whether from inside or outside the District is more likely to encourage businesses to relocate to, invest in and expand at the site. As a well located employment site, the opportunity exists to increase the size of the employment allocation on land east of Shipston Road which would provide greater choice for potential occupiers and contribute to the unmet need for employment land in the local area. It is recommended that the current employment allocation planning policy context is amended as proposed in this letter and as supported by the accompanying consultation form and Vision Document.
2.7 Economic Policy (E3) 2.7.1 Policy relating to economic growth should ensure that this is aligned with the scale and location of planned housing growth within South Warwickshire, ensuring that a balance between homes and jobs is maintained as far it is practical to do so to help ensure that an significant increase in out-commuting or in-commuting is avoided. 2.8 Protecting Economic Assets (E6a) 2.8.1 A policy protecting economic assets, e.g. Wellesbourne Airfield, Stoneleigh Park and other similar built infrastructure is supported. Another way to ensure that such locations are not at risk from development is allocating sufficient land for housing and employment elsewhere within the plan area. 2.9 Core Employment Area (E7.1) 2.9.1 The Core Employment Area is supported. It will be important to ensure a balance between homes and employment within this area and ensure that a range of housing, including affordable housing is available to help avoid in-commuting from outside of the area. Harbury could have a role to play in helping meet housing need within the Core Employment Area. 2.10 Major Investment Sites (E7.2) 2.10.1 Allocating additional land for employment uses at the major investment sites within the Core Employment Areas is consistent with Paragraph 82 of the NPPF, it will help create the conditions in which business can invest, expand and adapt and is supported. 2.11 Existing Employment Allocations (E8.1) 2.11.1 It is agreed that existing employment allocations, including revisions to Atherstone Airfield, should be carried over into the SWLP. This will help safeguard the sites for employment use. 2.12 Protecting Existing Employment Uses (E8.3) 2.12.1 Proposals seeking the loss of a business, commercial or community building or facility should be subject to marketing, viability and alternative use tests. Such measures will help ensure that employment land and buildings are protected from development pressure for higher value uses. It is also suggested that any requirements for marketing relate to a continuous period (to avoid sites being placed on the market for a few weeks, taken off and then put back on the market).
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
There are many principles in the section on the environment, and the economy, which the JPC endorses. These are in our responses to specific questions. We have two comments about the way the analysis has been carried out. First there is no evidence that the economic proposals will have any benefit in Henley and Beaudesert. All of the specific economic proposals and the Core Opportunity Area are to the South of Stratford and do not reinforce the choice of Henley as a possible area of expansion. This is also a problem in the section on transport improvements. None of the road proposals have significant local impact on the Henley in Arden area despite road and traffic problems being a major local issue. The growth strategy for housing is not being integrated with other essential attributes of the plan. There is a very real likelihood that additional housing will be built in places with no new businesses and vice versa. Q-E2: This issue should be addressed in Part 2 Q-E3: This issue should be addressed in Part 2 Q-E4.1: This issue should be addressed in Part 2 Q-E7.1: The JPC supports option E7.1a This provides opportunity for housing growth in areas with infrastructure to meet the needs of the increasing workforce without the necessity of using green belt land or viable farm land Q-E8.3: The JPC supports this proposal as essential to protect assets Q-E10: Tourism is a critical industry in the whole of South Warwickshire. Henley is a tourist magnet for several reasons. In order to capitalise on the potential fully there could be significant changes in land use in the town and therefore to defer policy making is not in the interests or needs of the town.
Q-E6: Please select the option which is most appropriate for South Warwickshire Option E6a: Include a policy which protects South Warwickshire’s economic assets. Coventry City Council considers that a policy which protects South Warwickshires economic assets would be beneficial in order to ensure the long term protection of key employment and economic drivers, not only in South Warwickshire but across the sub-region. The council would welcome policies which protect sites at University of Warwick, Stoneleigh Park and the UK Battery Innovation Centre. The council also supports wider and more generic employment protect policies around innovation, research and development and maintaining a highly skilled and adaptable workforce. 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. Coventry City Council is broadly supportive of a policy which directs investment to a Core Opportunity Area, as this will focus investment, create hubs for industry and research and development and focus inward investment to strategic locations. In particular we would support such a policy for University of Warwick Area, South of Coventry Area and Stoneleigh Park Area. 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. Whilst Coventry City Council is supportive of economic growth policies at Major Investment Sites, this should be aligned with the need to deliver an appropriate balance of both jobs and homes in order to meet the needs of the housing market area as a whole.
Q-E6: Please select the option which is most appropriate for South Warwickshire: Option E6a: Include a policy which protects South Warwickshire’s economic assets. Warwick Castle is rightly identified as one of several unique economic assets that form the foundation of South Warwickshire’s economy. Insofar as Warwick Castle is concerned, MAOL agrees that the SWLP should provide a policy that seeks to maximise and capitalises on its economic potential. In this context, our client supports a policy that protects the Castle as an “economic asset”. However, and in addition to economic assets being protected, any policy should explicitly provide “support”. This means supporting development that clearly demonstrates economic benefits, accepting of course that other impacts, including on heritage assets, need to be weighed in the planning balance. We have commented separately on the need to for tourism to be recognised a key economic driver. Issue E10: Tourism Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? No. MAOL strongly objects to the suggestion that tourism should not be addressed in the SWLP Part 1. We have explained that South Warwickshire is a key destination for tourists and tourism makes a very significant contribution to the area’s economic prosperity in terms of the jobs that it provides, and the visitor spend that it generates. We have also explained that the Tourism and Recovery Plan should inform the formulation of policy in terms of recognising the importance of tourism, providing support for recovery from the Pandemic and building for the future. The importance of tourism to the economy means that it must inform the strategic growth strategy and be supported by the SWLP Part 1. This could be through references to “supporting tourism” in other strategic objectives on jobs and economic prosperity or as a standalone policy.The Councils suggest that tourism should only be addressed in Part 2 of the SWLP because “it is not felt that tourism plays a spatially strategic role”. Whilst there may be no “spatial” context, tourism is clearly of strategic significance for South Warwickshire’s economy and must, therefore, be supported at a strategic level. Moreover, the rationale for deferring to Part 2 holds no weight because as one would expect, many other non-spatially specific policies are proposed for inclusion in Part 1 - covering issues as wide ranging a supporting the green economy, promoting net zero carbon, water quality and protecting/enhancing heritage assets.
1.0 Background This submission contains both specific comments on the text of the consultation document and general comments and issues the Chamber of Commerce wishes to highlight. As requested where the consultation questions are addressed they are referenced with the appropriate number and by the indicating the relevant Chapter and section of the document. The Coventry and Warwickshire Chamber of Commerce (referred to here as “The Chamber’) welcomes the opportunity to engage with the process leading to a new joint plan for Stratford and Warwick Districts. Business across South Warwickshire and indeed the C&W sub region is heavily dependent on the overall supply of employment land and business premises. A key concern of the Chamber regarding the existing sub regional Coventry and Warwickshire local plan policy frameworks is that they have failed, over their life to date, to provide sufficient new employment land and commercial premises to meet both the needs of existing businesses and provide what is needed to attract new growth and businesses. This new joint plan is therefore vital to producing an adequate range of new employment land opportunities to supplement existing stock and which can meet long term requirements .It is important that new land is allocated to meet a full range of business needs and that the allocation of land is influenced by attention to Market Signals data and the views of industry and business. To assist its input into the process the Chamber has formed an Employment Land Panel drawing on the expertise of its members, advisors and consultants with knowledge and expertise across the Coventry and Warwickshire sub region and the West Midlands. The Employment Land Panel would, in the future, like to engage with the team developing the planning framework on a regular basis. This would help ensure that the voice of business is represented as the overall plan strategy develops. 2.0 General It is central that the South Warwickshire Local Plan produces a policy framework that encourages business growth and development. This should also ensure that it meets needs and requirements across the whole spectrum of the economy and across the whole plan period to 2050.In terms of this latter requirement the plan should be underpinned by a commitment to detailed monitoring of economic performance to ensure a good understanding of the economic performance of the plan and its policies. This would then facilitate changes and alterations to the overall strategy to take account of change identified. Throughout the period to date covered by both the current Warwick and Stratford Local Plan frameworks (approx. 2011-2022) there have been sectoral shortages of employment land and evidence of mismatch between available supply and market requirements .This is evidenced in a number of sub regional and regional studies. The Chamber believes that there are several factors at work here including. -The inadequacy of the overall amount of employment land allocations to meet market demand .In particular there is evidence of shortages of industrial land in areas adjoining key settlements. -Affordability issues whereby new land allocations are, through market mechanisms, not available to some market sectors -A failure to properly understand market dynamics that have led to land generally allocated for employment use ending up being directed to one sector –usually distribution or logistics. -Mismatches between the scale of allocations and the prevailing market needs of particular areas across the new joint plan area. The Chamber welcomes the more strategic approach offered by the new joint plan across the wider area of south Warwickshire. Employment markets tend to operate across local authority boundaries and the wider plan area offers an opportunity to better meet the full range of needs. The draft Plan appears to advocate more disaggregated approach to meeting future employment needs. Therefore the suggested levels of employment land provision to both 2041 and 2050 indicate a separate allocation for B8 (warehousing and distribution) allocations, with Offices and General Industry having their own allocations .The Chamber welcomes this approach, though it would question if this goes far enough in disaggregating proposed supply? . A key weakness of the current adopted plan allocations (for both Stratford and Warwick and indeed across the sub–region)is that ,in the main, they simply allocate land for general employment across all Use Classes. Particularly on the larger allocations this general approach leads to land coming forward for the highest value uses –generally Class B8 (Warehousing and Distribution) where values can approach residential values. This has then created shortages of general industrial land and in particular smaller scale units. These trends, drawbacks and issues are well documented in the report Coventry and Warwickshire Market Signals Study 2019 produced by BBP Regeneration Ltd. This was produced by the CW LEP, WCC and the local authorities across Coventry and Warwickshire and represents a key piece of relatively up to date market evidence and recommendations. The draft Plan document is dominated by housing issues and much of the support evidence reflects this domination. Given the political profile of housing this is not surprising. However, the Chamber considers that the emerging new plan framework provides a major opportunity to give the local /sub regional economy equal prominence .The new plan needs to provide a framework in which the economy can grow and reach its full potential. This will require sufficiently large and more varied employment land allocations in appropriate locations across the plan area .In addition, as noted above, it is essential that there is a commitment to continuously monitoring the performance of the plan in terms of its economic impact. Recent changes in working patterns and the way market forces are creating new demands for new types of commercial space need to be properly accounted for in the new plan framework .As noted there isa strong emphasis throughout this consultation on housing provision .In future stages of the plan process, the Chamber wishes to see more detailed consideration of employment issues and how the new framework will tackle the changing patterns of work and employment. While the Chamber acknowledges that both local authorities produce Annual Monitoring Reports (AMR’s), these are in terms of monitoring the local economy very general and are not consistent in their content. They provide very broad data not sufficient to understand the detailed dynamics of the land and property markets .The emergence of the new joint plan provides an opportunity to address this deficiency and develop useful data sets that will better enable measurement of the local markets.
Issue E2 .A low carbon economy:QE-2 a,b,c The Chamber supports the general sentiments set out in the document on these issues. It supports efforts to cncourage businesses to move to Zero carbon but wishes to understand how resources might be directed to this general objective?However.it also considers that detailed “over prescriptive” policies aimed at particular sectors may not be effective. Indeed it is also important to appreciate that such policy relating to low carbon policy making may, inadvertently, impose additional costs on local businesses. This is particularly true of small businesses that make up the majority of the sub regions enterprises. If policies are to be brought forward to address low carbon initiatives these need to be carefully coasted, be introduced on a phased basis and their likely overall impacts set out in the supporting evidence with reasoned justification. The Chamber would welcome further discussions on this important matter and we would wish to explore what resources are available to assist the shift over to low carbon across a range of sectors in the local economy. As noted small business is generally less well equipped to deal with policies that carry costs burdens. Option E2 (a). There is merit in the overall aspiration here to create employment areas where similar or compatible business can co-locate together. There is a danger that too much prescription may stifle business innovation and entrepreneurial activity. Option E2-b.It is difficult not agree with the general sentiment. However operating such policies at a local level when surrounding areas do not have such requirements risks driving business away to local authority areas without similar requirements. Issue E3. Diversifying the economy. Q-E3 Achieving these aims across the whole economy is seen as important. Across the West Midlands and across the local plan area there are a number of business development organisations and regional /national initiatives aimed at assisting the diversification of local economies. Any policy framework needs to be integrated with the work of these organisations and authorities and the access to resources they might provide. Q E3c .On a matter of detail raised, the Chamber does not favour the use of Section106 provisions to regulate the recruitment of staff ,initially favouring locally recruited workers. There are well-documented widespread labour shortages and disrupted supply chains in some key sectors of the national economy. This is also true of the local economy. The imposition of this type of restriction would hold back immediate progress of new development schemes. There is experience of these policies across Greater London and that they have inadvertedly led to delays and imposed costs on businesses. Issue E4.Sustaining a rural economy. Q-E4.1-4.2 The existing policy framework of the two adopted local plan areas seems appropriate at the strategic level subject to combining these in an appropriate way. The Chamber wholeheartedly supports the continued development and diversification of the rural economy. The general sentiments set out,are difficult to argue with .The Chamber is unsure of what additional measures can be captured in land use planning policies and which do not run a risk of stifling innovation and entrepreneurial activity .Development management policies and the current Use Classes framework allow considerable flexibility in repurposing spaces for new uses .As pointed out ,resources are an important consideration in developing the rural economy and a multi agency approach by the public sector is essential .If land uses policies that encourage cooperation between agencies can be developed that would seem a major benefit. Overall, while there is no harm in general policy that encourage and support more small-scale rural businesses, the Chamber cannot see the benefit or added value in more specific policies without a linkage to resources and particularly financial support. Support for small business is essentially an inter–agency operation and there is no evidence that this has been factored into the text outlined. Issue E5: Lack of Business Accommodation. Q-E5 a&b. This is an issue of central importance to the Chamber. Some currently sectors do suffer from a shortage of suitable premises and accommodation .In part this may be addressed through additional allocations but often there is an issue of affordability. The following key principles need to be adopted • Greater protection of existing business areas and premises so they are not “ lost “ to housing development. • Policies that encourage and facilitate the repurposing of retail units for a wider range of commercial activities. • New allocations for “affordable “ small scale “ activities. • Support the provision of the widest possible range of business units including the upgrade and modernisation of existing stock . The Chamber is not clear, on the basis of the commentary set out here, what benefits accrue from general policies as suggested. There is a good analysis of the problem in the text but the Chamber is not clear what solutions are being advanced to address the difficulties identified? The current policies in the two adopted local plans should be dovetailed and rationalize to produce one set of consistent and clear policies. Issues E6&7.Core Opportunity Area (COA) and Major Investment Sites(MIS) Q-E6a&b ,E7.2 a&b. As listed in the consultation the new plan area should contain a number of important economic assets that should be nurtured and where appropriate expanded over the plan period. Rather than a general policy to “blanket” these assets, the Chamber favours specific and targeted policy individual site frameworks for some but not all these important assets .For example, the Chamber is aware of the benefit created by the policy in the current Stratford Local Plan that seeks to protect and develop Wellesbourne Airfield. This has proved important in the defence of the County’s last remaining hard runway based airfield –an asset that increasingly has considerable future economic development potential. The principle of directing growth to a particular general part of the plan area –the Core Opportunity Area is only likely to be effective if the land use policy framework is aligned and supported by a full range of policy initiatives and fiscal support measures including inward investment, national and regional grant focus and a concentrated focus on the chosen area and sites by all public agencies. This requires “buy –in “beyond the scope of land use policies. The cooperation of Warwickshire C. C. (WCC) and the West Midlands Combined Authority (WMCA) in this initiative is essential. On the basis of the limited information given here, we do not favour prescriptive policies seeking to channel growth towards the Core Opportunity Area. We support the principle of allocating additional land adjacent to the MIS where appropriate (Ref Option E7.2a7b). However this should take place against the background of a thorough overall review of each of the major MIS areas. Issue E9. Supporting our changing town centers. Q-E9a&b By common consent, this issue is a high priority short-term challenge not only across this plan area but also generally across the UK. Here policies encounter strong market forces, which are altering the content, function and operation of town and district centres. There are questions about how much land use planning can alter these market dynamics. The text of the consultation document summarises the challenge and largely the Chamber supports the approach outlined subject to rationalizing and aligning the current policies in the two plan frameworks. We agree that many of the issues are appropriate to detailed planning guidance and would sit comfortably in Part 2 of the new plan .In an addition there are many issues here covered by the application of the Use Classes Order. For example, it might argued that the changes enacted to the Use Classes Order in 2020 and most notably the introduction of new Use Class E has weakened the ability of the land use planning process to control and change town centres and other similar retail concentrations. The weaknesses created by the new broader Use Classes framework needs to be considered and a range of possible measures considered. The new plan should adopt a more “sectoral ‘disaggregated policy approach to town /district centre uses, that moves away from a reliance on a Use Classes Order that is not able to discriminate between sectors and simply favours the change of use of land to that with the highest use value. There are good examples of these weaknesses that have unintentional consequences. a)The shortages of open storage land and spaces has serious consequences for the operation of communities. Over the past seven years these shortages have created steep rises in land values .It is important for land use planning to seek to protect remaining stocks of storage land and premises so that built up areas can function efficiently. This will have an additional benefit that travel (and freight) movements are minimized. However brown field land policy and general allocations for employment land mean that storage space continues to be lost to higher values.It is rarely protected as the asset that it represents . A more sectoral plan framework is required. - b) Similar problems arise with low density commercial land uses uses such as R&D space and indeed some types of new office space .Often these specialist low density uses cannot compete with pressures from other high value uses notably housing and distribution land .The operation of general Use Classes based policies does not protect some key sector employment needs and in particular land required by small scale “start ups”and “niche” specialist scientific businesses. Consideration should be given to further encouragement by appropriate policies to the “repurposing “of town and village centre retail buildings for other employment uses and policies that seek to selectively resist change from retail to residential which is facilitated under the new Use Classes Order (2021). Already in some of the larger towns in Warwick and Stratford Districts there is evidence that market forces have allowed under new class E, some former shopping units to be converted to small business premises such as offices and workshops .If these market trends could be treated more “sectorally’ and aligned with more financial support measures this could improve the stock of employment land being better aligned to changing needs. Issue E10. Tourism. Q-E10 The Chamber fully supports the further growth and expansion of the visitor economy and tourism. The development plan framework must positively support this development. We agree with the broad sentiment of the consultation that the role is “spatially non- strategic” and that Part 2 of the proposed joint plan will be an appropriate place to address most issues of the development . Issue E11.Any other economic issues about SW economic needs. Q-E11 As noted above we believe the monitoring and measurement and, if necessary, the subsequent alteration of the Plan’s economic policies is an essential ingredient of an effective long-term plan for the area. The use of detailed “Market Signals and Intelligence ’ as exemplified in the 2019 SQW Study(referenced above) sets out many appropriate parameters that should be looked. These submissions have pointed out the deficiency in the broad approach to planning for employment land using Use Classes –there are deficiencies in the broad classification of the new Use Classes and they are often too broad and general.as noted, generally the Chamber favours a more detailed “sectoral “approach . A good example would be logistics and distribution .The Chamber sees merit in the approach employed in Leicestershire, whereby rail based distribution is treated separately from road based logistics and distribution. The Chamber favours greater commitment to rail based logistics and distribution. This would accord well with the general objectives in the plan to align policy to decarbonize transport and remove freight from the road network. The Chamber sees merit in establishing an effective monitoring based measure or target, based around developing a “5 year employment land supply test “.This would apply to the plan area .It would draw on parallels from housing policy where this measure has been a long term metric. This initiative would require that the plan has, at all times, a readily available 5 Year Supply of new employment land ready for take up /implementation in the market .In the Chambers view this would represent an easily measurable metric capable of monitoring and equip the area with a range of immediately available land opportunities. The Chamber is aware that the concept of “5 year supply” relating to housing policy may be removed by changes to national planning policy .In this event it recognizes there may be reluctance to introduce the concept for employment land .As an alternative consideration should be given to the introduction of “criteria based” policies to control the provision for specific sectors. Good examples of such policies can be found locally in development plan policies for North Warwickshire (ref Policy LP6, Additional Employment Land In North Warwickshire) and NW Leicestershire (ref EC2 .New Employment Sites in NW Leics ) The Chamber considers these types of policy approaches depend on monitoring and measurement across the plan. This would assist Inward Investment to the area and align well with the work of the Inward Investment and business development agencies that are active across the area
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 Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area Answer: E7.1b: Do not include a policy directing employment to the Core Opportunity Area – which is already highly congested and polluted, in the area of Warwick University, . Focussing in this area, would erase the slim remaining gap between Coventry and Kenilworth.
It is agreed that boosting and diversifying the economy should be a strategic aim of the SWLP which should be underpinned by the Economic Needs Assessment and Strategic Housing and Employment Land Availability Assessment. A key component is ensuring that the right infrastructure is in place to facilitate this and that enough housing is provided in the right location to support businesses, as set out in NPPF paragraph 20. Hatton could provide up 3,000 jobs (new and existing) in a range of technology-based businesses, assisting the SWLP with meeting their overall ambitions to strengthen and diversify the economy. Hatton New Community is at the heart of the ‘Innovation Region’ with great accessibility to the key centres of Warwick/Leamington, Coventry and Birmingham/Solihull. The pandemic has shown that, as well as supporting town centres, local authorities should be flexible to accommodate home-working and remote working from ‘third’ spaces so that we can reduce the need to travel unnecessarily for work. There will be times when access to higher order centres is needed, hence the adjacent Hatton station provides direct rail links to Warwick, Leamington, Birmingham and London. However, the Hatton New Community can provide workspaces and high speed broadband to enable home- and remote working to support healthy lifestyles and provide choice and flexibility.
Q-E7.1: 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. This would require greater justification. It would appear to be a policy mechanism to justify large-scale employment sites in otherwise relatively remote areas. If retained, would there be a requirement to balance new employment and housing growth. 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 new investment is focused outside of the Core Opportunity Area and fails to capitalise on the connectivity that the core opportunity area brings. Without significantly greater justification it might be this would be a more sensible way forward.
CHAPTER 5: DELIVERING SOUTH WARWICKSHIRE’S ECONOMIC NEEDS 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? This emerging Local Plan needs a fundamentally new approach to the provision of employment land requirements, particularly in terms of the Plan period to 2050. Covid brought a substantial increase in the number of people working from home and particularly those who use broadband and the internet and can work from their own homes. The South Warwickshire Local Plan should have properly commissioned a new employment and economic study from independent consultants which should focus on providing focused growth for those employment activities related back to growth in the national economy. Without this independent Study we believe that the approach taken is imbalanced and particularly at a critical time generally after Covid. In addition, this study should also focus on the opportunities to provide employment in a sustainable form along existing road corridors such as the M42 and the A435. Generally economic growth comes from the provision of both large and small new businesses expanding and we made the point above about the benefits of our new Call for Sites on the south-east side of Junction 3 of the M42. ISSUE E2: A LOW CARBON ECONOMY Q – E2: Please select all options which are appropriate for South Warwickshire 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. ISSUE E4: SUSTAINING A RURAL ECONOMY Q – E4.1: Please select the option which is most appropriate for South Warwickshire Bearing in mind our replies on the various issues above relating to the economy, sustainability, sustainable travel and new employment provision to assist rural diversification of the economy. ISSUE E6: PROTECTING SOUTH WARWICKSHIRE’S ECONOMIC ASSETS Q – E6: Please select the option which is most appropriate for South Warwickshire This question is again poorly worded because there are no specific options but where in a sustainable rural location new business opportunities provide themselves, particularly in conjunction with motorway and motorway-related services such as logistics and distribution, then support should be given through this emerging Local Plan for such opportunities.
ISSUE E2: A LOW CARBON ECONOMY Q – E2: Please select all options which are appropriate for South Warwickshire 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. ISSUE E4: SUSTAINING A RURAL ECONOMY Q – E4.1: Please select the option which is most appropriate for South Warwickshire Bearing in mind our replies on the various issues above relating to the economy, sustainability, sustainable travel and new employment provision to assist rural diversification of the economy is important particularly where there is the creation of small, new businesses. ISSUE E6: PROTECTING SOUTH WARWICKSHIRE’S ECONOMIC ASSETS Q – E6: Please select the option which is most appropriate for South Warwickshire This question is again poorly worded because there are no specific options but where in a sustainable rural location new business opportunities provide themselves, particularly in conjunction with motorway and motorway-related services, then support should be given through this emerging Local Plan for such opportunities. ISSUE E8: EXISTING EMPLOYMENT SITES Q – E8 Please select the option which is most appropriate for South Warwickshire There are small existing rural employment sites that really need further consideration and expansion where an appropriate opportunity is available.
QE2: This issue should be addressed in Part 2 Q-E3: This issue should be addressed in Part 2 Q E 4.1: This issue should be addressed in Part 2 QE7.1: The JPC supports option E7.1a. This provides opportunity for housing growth in areas with infrastructure to meet the needs of the increasing workforce without the necessity of using green belt land or viable farm land. QE.10 Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? Tourism is a critical industry in the whole of South Warwickshire. Henley is a tourist magnet for several reasons. In order to capitalise on the potential fully there could be significant changes in land use in the town and therefore to defer policy making is not in the interests or needs of the town.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E4.2: Stansgate 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. Q-E7.1: Stansgate 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. Q-E10: Stansgate considers that a policy promoting and supporting tourism, which is an important element of the local economy, is an essential part of the emerging Local Plan. Stansgate would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
Q-E7.1: Core Opportunity Areas 15. Marriott Estates support option E7.1a and directing employment growth to the Core Opportunity Area. Recognition within any policy that supports this area should be given to Moreton Morrell College.
Q-E2: Please select all options which are appropriate for South Warwickshire We are not convinced such a policy or policies is required. Many of the principles included under Option E2a are likely to be addressed by national policies or other policies in the local plan. The notes as drafted would not, as an example, encourage repatriation of manufacturing. Q-E3: Please select all options which are appropriate for South Warwickshire Option E3a: Include a policy expanding on SDC’s current existing policy. This approach would be preferable to E3b. It should emphasise the importance of providing a choice of opportunities (in terms of both land or buildings) for all types and size of business available throughout the plan period. Option E3c: Include a policy that secures employment strategies through S106. This approach would be supported in appropriate circumstances. Q-E4.1: Please select the option which is most appropriate for South Warwickshire Option E4.1a: Include a policy supporting diversification This approach would be supported. Q-E4.2: Please select the option which is most appropriate for South Warwickshire Option E4.2a: Include a policy supporting small-scale employment opportunities in rural areas We would support this approach which is conducive to helping entrepreneurs who may reside in the more rural parts of the plan area to establish new businesses and encourage existing small businesses to expand. To do the counter could seriously and negatively impact on the future long-term health of Warwickshire’s economy. Q-E5: Please select the option which is most appropriate for South Warwickshire We would strongly support this approach. Holly Farm Business Park is an example of rural diversification providing a home to many small diverse businesses including startups, some of which are ripe to expand into larger accommodation which could be provided onto adjacent land already in the ownership of the business park. Option E5b: Do not include a policy in Part 1. A failure to provide a policy in Part 1 would represent an ‘opportunity lost’. It is important that the local plan is seen to a plan that supports all types and sizes of business and not biased in favour of big business. It should also be remembered that some of the big businesses of the future will be the small businesses and start-ups of today. It is important that home-grown talent is supported with just as much vigor as large-scale footloose activity. Q-E6: Please select the option which is most appropriate for South Warwickshire Option E6a: Include a policy which protects South Warwickshire’s economic assets. We would generally support this approach although the list also includes assets outside the plan area. Perhaps it should be clear what is within the plan area. 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 would require greater justification. It would appear to be a policy mechanism to justify large-scale employment sites in otherwise relatively remote areas. As drawn this area would exclude Holly Farm Business Park and the JLR facility at Fen End when, in reality, they are in much closer proximity to the main population centres. If retained, would there be a requirement to balance new employment and housing growth OR would the scope for employment development be restricted in some way. For example, would the land at Gaydon be limited only to JLR and Aston Martin and, if not, why not? Should land which is held in curtilage be treated differently to ensure other business activity and enterprise is not unduly restricted. Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. Without significantly greater justification it might be this would be a more sensible way forward. 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. This might be an appropriate approach but as highlighted above it is important the plan is not unduly focused on major sites and inward investment. It is unclear if this means additional land allocations over existing commitments. If so, these would need to be justified and balanced against other alternatives. Option E7.2b: Do not include a policy relating to additional economic growth at the major investment sites. This question appears to highlight the focus of the approach in the plan towards the strategic sites. Why would growing local businesses prefer to locate at a strategic site? The rationale for this is unclear as we believe that smaller hubs are more conducive to business growth and creativity. Q-E8.1: Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP? Yes. Existing allocations should be carried forward, as should recognition that successful employment sites, such as Holly Farm Business Park should be allowed to expand. Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? No. Tourism is an important part of the economy. The plan should allow for development of the necessary supporting infrastructure to support its enhancement.
Q-E7.1: Core Opportunity Areas 41. William Davis object to option E7.1a and the exclusion of Studley and the eastern fringe of Redditch from the Core Opportunity Area. This ignores the economic importance of Redditch to this part of South Warwickshire.