Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Sites of national importance are protected by national planning policy. Duplication of that policy is not strictly necessary in the SWLP. However, L&Q Estates are supportive of a policy which seeks to require the safeguarding of such sites, unless the benefits of the proposal clearly outweigh the need to protect the site. As noted in the Vision Document accompanying these written representations, Land South of Allimore Lane, Alcester contains a non-statutory ecological designation, the Spittle Brook LWS, which has hydrological connectivity to the Severn Estuary Special Areas of Conservation (SAC)/Special Protection Area (SPA)/Ramsar sites via the River Avon. Accordingly, consideration will be given to the implementation of construction safeguards and a suitable drainage strategy to ensure development of the site does not result in adverse effects on these designations. In addition, Bredon Hill SAC is identified within 20km of the site with the potential for recreational pressure to occur but good design and the creation of areas of formal an informal public open space, recreation pressure to the Bredon Hill SAC can be mitigated for. The Site is dominated by agricultural grassland fields and a single large arable field, with a range of diverse native hedgerows, and mature trees, with a veteran crab apple identified in the north-west. A watercourse flows centrally through the site and is bounded by broadleaved woodland. Subject to a sensitively designed masterplan, including provision of a suitable buffer between the watercourse, woodland, and veteran tree from built development, adverse effects on these higher quality habitats can be avoided. The large arable field in the south provides a wide range of opportunities for good quality habitat creation which will provide a large offset for on-site losses and reduce the amount of off-site compensation if required for Biodiversity Net Gain.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing. It is about communities and how they survive. How as a country we feed ourselves? If all the green land is built on then where do we grow crops and raise the live stock?
Issue B1: Areas of Restraint Please select the option which is most appropriate for South Warwickshire Q-B1 Option B1a We consider that Areas of Restraint are an effective policy tool for ensuring development is kept free of identified development parcels. This has been a long-standing policy commitment in Stratford and, for consistency, this should be applied to Warwick too. It would allow for a hierarchical approach, which is embedded in the NPPF, and as such would be consistent with national policy. The precise Areas of Restraint should be the subject of thorough evidence base testing and consulted upon as the SWLP advances. Issue B5: Environmental Net Gain Q-B5 a We consider that the work should be undertaken by the Council to explore and potentially pursue and integrated Environmental Net Gain Policy which will support natures recovery. We are aware of the governments Environmental Improvement Plan 2023 which seeks to halt and reverse the decline in nature – in the reaching of this goal, there should be a reduction in environmental pollution which would include noise, water quality, soil, carbon capture. One policy to deal with these elements seems sensible. As always though, any such policy would need to be evidence tested and thoroughly consulted upon. There would also need to be an awareness of the implications on viability – if overly onerous, the policy could act as a real dis-incentive for developers, who would seek instead, to build outside of South Warwickshire. Q-B8.1 Do you agree that the plan should include a policy avoiding development on best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefits of development? Yes. We recognise the importance of BMV in considering development proposals. However, any such loss of BMV needs to be balanced with the competing – and highly important – need to deliver housing and other development. Any policy which restricts the loss of BMV would be inappropriate, and beyond the scope of the NPPF which would fail the tests of soundness. It is however appropriate to provide a policy which recognises the importance of BMV but allows for its loss where it is outweighed by the need for new development. Issue B9: Protecting Biodiversity and Geodiversity assets Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites? Yes – although SSSIs are protected by national policy. Paragraph 175 states that plans should distinguish between the hierarchy of international, national and locally designated sites, and on this basis such a policy should be included.
Q-B1: Please select the option which is most appropriate for South Warwickshire with regard to Areas of Restraint. Gladman consider that the Areas of Restraint should be removed from the South Warwickshire Local Plan as they have the potential to arbitrarily restrict development. However, should the Councils consider it most suitable to keep and/or introduce Areas of Restraint, the policy wording as adopted in the Stratford-upon-Avon Core Strategy which states that ‘planning permission for a large scale form of development in an Area of Restraint will only be granted where a scheme would have demonstrable community benefits and contribute significantly to meeting an objective of the Core Strategy.’ This flexibility ensures that the policy does not stop suitable and sustainable development sites from coming forward as and when required. Q-B3: Please select the option which is most appropriate for South Warwickshire with regard to Special Landscape Areas. Gladman consider that Option B3c: Discard Special Landscape Areas and bolster general landscape policy. A general landscape policy would ensure that development is not overly restricted on landscape grounds and would allow landscape impacts associated with development to be considered in a planning balance exercise. Q-B4: Please select the option which is most appropriate for South Warwickshire with regard to the AONB. Gladman do not consider Option B4b to amend the current AONB policy to include a buffer to be appropriate and consider Option B4a to be the most appropriate. This will ensure that the Cotswold AONB maintains the current level of protection afforded by national planning policy. Q-B8.1: Any policy concerning the development of best and most versatile (BMV) agricultural land should be consistent with the requirements of the NPPF which makes clear at footnote 53 that where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality.
Q-B4: Option B4a: Maintain the current policy approach, without the use of a buffer The Cotswold AONB is defined and there appears to be little logic the create a buffer effectively leading to an artificial extension that could prejudice otherwise acceptable rural housing or economic growth. Any concerns can be covered through a general landscape protection policy. Option B4b: Amend the current policy and include a buffer around the periphery of the Cotswold AONB to ensure that great weight is given to any impacts development within this buffer zone may have on the National Landscape Not supported. Q-B5: The national approach should be adopted. Q-B6: Wildbelt is inadequately defined. It suggests the allocation of land for nature conservation. This would need clearly worded objectives and scrutiny/examination over the areas identified, as well as thought on how it could be delivered. Q-B9: This should be consistent with national policy
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much, needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
QB1Please select the option which is most appropriate for South Warwickshire: The JPC strongly endorses option B1a and proposals to protect and enhance the historic and environmental quality of the town and the steps to be taken by the partnership to achieve that. This level of proposal, however, appears to JPC to be far too detailed and is an example of excessive scope/detail in this consultation. These are all issues that are being delegated to NPs and there needs to be some reference in the document to encouraging Neighbourhood Plans to undertake this activity and guidance as to appropriate approaches. QB2 Should the Policy on the Vale of Evesham Control Zone be removed, if neighbouring authorities decide not to carry the designation forward? This is a matter for the local councils and their resident. QB4.Please select the option which is most appropriate for South Warwickshire. The JPC believes that in general our environmental quality needs to be protected and maintained and although the ideas are sound this might have a negative impact on areas to the North depending on the scale of the buffer. However, these are issues to be debated with local communities and the relevant statutory agencies involved and the Local Plan part 1 does not seem to be the correct place to have this debate. QB5 Please select the option which is most appropriate for South Warwickshire. The JPC supports option 5a. The core idea is sound, but we have concerns that this might push more development further to the North. QB8.3Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites The JPC supports the proposal, but it still seems doubtful that the duplication is essential at this stage.
Chapter 11 A biodiverse and environmentally resilient South Warwickshire Issue B6: Environmental Net Gain 75. It is the HBF’s opinion that the Council should not deviate from the Government’s requirement for biodiversity net gain as set out in the Environment Act. There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. It is important that BNG does not prevent, delay or reduce housing delivery.
Q-B3 59. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 60. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B4: Please select the option which is most appropriate for South Warwickshire Option B4a: Maintain the current policy approach, without the use of a buffer The Cotswold AONB is defined and there appears to be little logic the create a buffer effectively leading to an artificial extension that could prejudice otherwise acceptable rural housing or economic growth. Any concerns can be covered through a general landscape protection policy. Q-B5: Please select the option which is most appropriate for South Warwickshire The national approach should be adopted. B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? Don't Know Wildbelt is inadequately defined. It suggests the allocation of land for nature conservation. This would need clearly worded objectives and scrutiny/examination over the areas identified, as well as thought on how it could be delivered. Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes. This should be consistent with national policy.
Q- B.5 Please select the option which is most appropriate for South Warwickshire. Option B5a: Explore and pursue an integrated Environmental Net Gain Policy. I am disappointed to see such a low minimum target for proposed biodiversity net gain. Other councils such as Greater Cambridgeshire have been more ambitious requiring 20% Biodiversity net gain. This would be more in keeping with mitigating our environmental state of emergency. Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. Q B8.1 Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? Yes. The country needs to have capacity to feed the nation so such land should be held forthis but each area needs to be assessed on all aspects and a recognition that lower quality farming land should not automatically be pushed into development. Q B 9 Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes. In order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets. BQ. 10. Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Biodiversity There should be 20% Biodiversity Net Gain through new development, currently, only 10% is included in the plan. The Green Infrastructure study used is now 10 years old and needs to be reviewed early-on to inform growth options and to include joined-up wildlife corridors. We would like to see a more detailed assessment of local biodiversity and river habitats in the proposed growth and new settlement locations, especially in the areas adjacent to the river Avon and a number of key ‘Potential Local Wildlife Sites’.
Q-B1: Option B1a seems the sensible approach for a Plan covering the geographic area of the two LPAs. Q-B3: Option B3a seems the sensible approach for a Plan covering the geographic area of the two LPAs. Q-B5: Option B5a would seem to be the best approach for providing clarity.
There should be a 20% biodiversity net gain through new development; at present the plan only includes one of 10%. This shows a lack of ambition. The Green Infrastructure Study needs updating and reviewing if it is to inform growth options. At present there is a lack of detailed assessment of local biodiversity, wildlife and river habitats; especially where growth and new settlement locations are indicated biodiversity assessments should be detailed and local, if a number of of 'Potential Local Wildlife Sites' are not to be lost - for example along the Avon corridor. More detail is needed around the Council's plans for dealing with the acknowledged climate emergency. These plans should have a practical basis, not generalised. Biodiversity can have a very localised significance - for example the number of species dependent on a single mature oak, or a long established hedgerow, or pond. The micro environment is as important as the macro, and at risk from smaller scale plans.
Q-B1: A disjointed approach between the two local authority areas should be avoided wherever possible. Of the options presented therefore, the Respondent would favour removal of existing areas of restraint, with open areas of land that serve to preserve the structure and character of settlements protected through more generic heritage and/or landscape policies. Q-B3: A disjointed approach between the two local authority areas should be avoided wherever possible. Given that Special Landscape Areas are now a somewhat outdated concept the Respondent considers, in the interests of consistency across the plan area, that Special Landscape Areas should be discarded (rather than seek to establish such areas across the whole of South Warwickshire). Q-B4: Creating a buffer around the Cotswold AONB is superfluous to national planning policy that requires development within the setting of AONBs to be sensitively located and designed to avoid or minimise impacts. The Respondent therefore considers Option B4a, which seeks to maintain the current policy approach without use of a buffer to be sufficient in this case. Q-B5: Environmental Net Gain is an entirely new concept with no tried and tested approach to its delivery. It is therefore currently unknown how Environmental Net Gain would work in practice. The Respondent therefore reserves their right to make comment once more detailed information is available. Q-B6: No. Wildbelt is a highly aspirational concept with no statutory or national planning policy basis. Unlike other designations there is no tried and tested method for the identification or delivery of Wildbelt. It is therefore unclear upon what basis the Council would seek to justify such designations particularly in light of the absence of the Local Nature Recovery Strategy (LNRS), which is understood from the Consultation Document to be many years away. The Respondent therefore reserves their right to make comment once more detailed information is made available. Q-B8.1: No. Agricultural Land quality is only one of a number of factors that is taken into account when considering whether a site should be developed or not. While Paragraph 174b of the NPPF recognises the benefits of best and most versatile agricultural land this is expanded on in Footnote 58 on Page 50 of the NPPF which requires consideration of the issue only where ‘significant development’ of agricultural land is demonstrated to be necessary. In such instances, the Footnote considers that poorer quality land should be ‘preferred’ to that of a higher quality. However, this does not mean that it is mandatory to avoid the development of best and most versatile agricultural land. It is therefore highly inadvisable to promote a policy that looks to avoid the development of or seeks the retention of best agricultural land as suggested.
Q-B1: Lockley Homes would select Option B1b referred to above. It is critically important that the LPA’s preparing the emerging SWLP promote the most sustainable patterns of new housing development in order to ensure that the emerging Local Plan Review satisfies the ‘Sustainability’ test of Soundness for Local Plan preparation, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). It is noted that the LPA’s preparing the emerging SWLP have a severe shortage or urban brownfield land (previously developed land sites) to meet their required housing development needs during the shelf life of the new SWLP, extending up until the year 2050. Given that the Plan area is dominated by large expanses of heavily rural open countryside. The Council’s will therefore have to rely on existing sustainably-located green space areas and areas of farmland located within the vicinity of existing village settlements, in order to meet their future development needs (NPPF para 79) – to help deal with the worsening chronic housing shortage present across all parts of the SWLP area. In accordance with guidance in paragraphs 79, 141 (indent a) and 142 of the Revised NPPF (2021), the Council should be supportive of bringing forward areas of low quality, under-utilised green space land for new housing development. Particularly those green space/ under-utilised greenfield sites located outside of the designated Green Belt. This approach has strong support within the above NPPF guidance. On this basis, a one-size-fits-all planning policy green space protection approach is not justified, is not acceptable, and is not a sufficiently robust policy approach to take within the emerging Local Plan Review. It is important that when drafting this open space focused policy area, that highly experienced, specialist and competent green space town planners are used, to help deliver a sufficiently robust, balanced and flexible policy approach, which effectively responds to the requirements of the NPPF. In order to ensure that the development needs of the local area can be met within sustainable site locations, and in order to ensure that villages are allowed to grow and thrive, consistent with guidance in paragraph 79 of the Revised NPPF (2021). Those most sustainable site locations such as the Lockley Homes site should be strongly supported for new housing development by the LPA within the emerging Local Plan Review. It is important that a highly obstructive planning policy approach towards green space protection is not taken, particularly for those low quality and under-utilised green space areas characteristic of the Lockley Homes site. This is critically important given the severe shortage or urban brownfield land sites present across the South Warwickshire Plan area. We have concerns that the Council’s preparing the emerging SWLP consider that it is appropriate to promote new housing development sites within the open Green Belt countryside, and ignore completely sustainable site locations such as the Lockley Homes sites. The scale of potential errors being accommodated into evidence base documents by completely overlooking and missing out sustainable development locations is quite alarming. For the scale of potential errors being incorporated into Local Plan preparation please refer to the large infill site located outside the Green Belt which has been overlooked by the LPA’s in their Plan-preparation work. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the emerging SWLP Review. Both Lockley Homes and their planning consultant Goldfinch Town Planning Services, continue to object to the “incapable” management and leadership approach being taken towards Local Plan-preparation within the emerging SWLP Review (2023). It is important that the ongoing failure to promote the most sustainable patterns of new housing development across the South Warwickshire districts is urgently addressed by the LPA’s Planning Policy Teams within the emerging SWLP Review. Lockley Homes maintains its view that it has a sustainably located site suitable for new housing development located within an existing village settlement boundary. Given the very strong, clear and compelling sustainability credentials of the site as already evidenced in our Representations, we consider that this site (within the Village of Broom settlement boundary) should be prioritised for future development and included without delay as a new housing site allocation on the main Policies Map of the Council’s emerging SWLP. We consider that allocating this site for new housing development in the Council’s emerging SWLP as suggested would result in a more effective, positively prepared and justified plan, in accordance with tests of Soundness set out in paragraph 35 of the Revised NPPF (2021). Q-B5: Lockley Homes would select Option B5c referred to above. Including carbon capture policies and integrating these with Biodiversity Net Gain will place an unreasonable financial burden on the house building development industry at a time when the local economy is suffering from a severe economic recession. Placing an onerous set of policy restrictions on housing developers will have an adverse impact on the future financial viability of development sites coming forward across South Warwickshire. These issues are considered in more detail within this wider Representations Statement (2023). The proposed planning policy approach of combining Biodiversity Net Gain (BNG) with a Carbon Capture Policy, will significantly dilute and weaken the delivery of robust and significant BNG features within new development proposals, therefore conflicting with the BNG focused policy objectives set out within paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). Making the BNG component part of the policy undeliverable, therefore conflicting with ‘deliverability policy tests’ set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). Lockley Homes maintains its view that it has a sustainably located site suitable for new housing development located within an existing village settlement boundary. Given the very strong, clear and compelling sustainability credentials of the site as already evidenced in our Representations, we consider that this site (within the Village of Broom settlement boundary) should be prioritised for future development and included without delay as a new housing site allocation on the main Policies Map of the Council’s emerging SWLP (2023). We are proposing to include a number of on-site biodiversity enhancement features within the site layout if this site came forward through the Council’s emerging SWLP Review. These issues are considered in Appendix C of this Representations Statement (2023). Allocating this site for new housing development would therefore help to meet the policy objectives of Issue B5: ‘Environmental Net Gain.’ This site should therefore be strongly supported by the LPA within the emerging Local Plan Review as a potential new housing site allocation. Q-B6: Lockley Homes would select ‘No’ to Question B6 referred to above. We maintain our view that areas of low-quality green space and areas of intensive farmland should not be designated as Wildbelt designations, if there is no robust, credible and up-to-date ecological survey evidence in place to support such designations. Otherwise the designations could be challenged by the private sector at future Planning Appeals as well as during the Local Plan forthcoming Examination in Public (EIP) Stage. Only those green space locations with sufficiently robust and demonstrable ecological value should be designated and form part of any Wildbelt designations. This approach is supported by guidance reinforced in paragraph 31 of the Revised NPPF (2021) which states that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” It is also noted that huge areas of rural lowland countryside within the Stratford-on-Avon District have already been significantly damaged by years of successive intensive farming practices. Stratford-on-Avon District Council’s Planning Policy Team “appears to have been fully asleep at the steering wheel” while these damaging landscape changes have been taking place across the countryside, where little, or no action has been taken by the Council’s Planning Policy Team, despite the removal of huge sections of hedgerow networks within the rural countryside, the removal of veteran and ancient trees from hedgerow networks, draining of farmland wildlife ponds, etc. The severe impacts of damage caused by intensive farming practices on farmland wildlife habitats is particularly evident within the open farmland landscape located immediately north of the Lockley Homes proposals site, on the northern edge of the Village of Broom settlement. This aspect is supported by robust and defendable photographic evidence in Appendix B of this SWLP Representations Statement (2023). To help deliver net gains for biodiversity and respond positively to guidance within paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021), the Council’s preparing the emerging SWLP Review should be far more pro-active in supporting new housing development proposals coming forward within areas of intensively farmed countryside, particularly where new housing development proposals are delivering Biodiversity Net Gain (BNG) solutions to help support declining wildlife species. Lockley Homes position on this issue is also strongly supported by guidance within the Warwickshire, Coventry and Solihull Local Biodiversity Action Plan (BAP), which is strongly supportive of new housing development proposals which include measures which actively seek to support the recovery of vulnerable populations of Priority Wildlife Species and the recovery of priority wildlife habitats across the South Warwickshire countryside. These issues are explored in considerable detail within Appendix C of this SWLP Representations Statement (2023). Q-B8: Lockley Homes would select ‘No’ to Question B8-1 referred to above. There may be areas of the best and most versatile agricultural land present on the edges of existing rural village settlements within the South Warwickshire countryside. However, greenfield sites within these areas should not necessarily be safeguarded within the SWLP (2023) given that they represent highly sustainable site locations for new housing development. This is particularly the case for areas of ‘greenfield’ land located outside of the designated Green Belt. In accordance with guidance within paragraphs 79, 141 (indent a) and 142 of the Revised NPPF (2021), these types of locations on the edges of existing rural village settlements should be prioritised for new housing development. Areas of low quality and under-utilised green space land such as the Lockley Homes site (which is located outside of the designated Green Belt) within the existing Village of Broom settlement boundary should be particularly prioritised for new housing development, without delay on an urgent basis. Given the very strong, clear and compelling sustainability credentials of the site in question as already evidenced in our Representations (March 2023), we consider that this site should be prioritised for future development and included without delay as new housing site allocation on the main Policies Map of the Council’s emerging South Warwickshire Local Plan (SWLP). These types of medium scale-sized land parcels should not be left for a Stage 2 SWLP to consider in future years, but should be considered as an urgent priority now, and brought forward for new housing within the emerging SWLP (2023). Our position on this issue has a strong level of planning policy support within the above NPPF guidance. In particular, within paragraph 79 of the Revised NPPF (2021) which is perfectly clear that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Further support is provided in paragraph 69 of the Revised NPPF (2021) which attaches considerable planning policy weight to the importance of small and medium sized site land parcels. It states that: “…Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly…” Q-B9: Question B9 - Lockley Homes would select ‘No’ to Question B9 referred to above. It is important that there is a sufficiently robust and defendable platform of ecological evidence to support and justify any site-based nature conservation designations. Use of non-designated sites would not provide a sufficiently robust approach and could potentially be vulnerable to challenge at future Planning Appeals and challenge at the future SWLP Review Examination in Public (EIP) stage. Q-B10: Lockley Homes maintains its view that new housing development sites coming forward within well-integrated infill site locations immediately alongside existing rural village settlements, within areas of intensive farmland should be supported for new housing development within the emerging SWLP for reasons already set out within this Representations Statement (2023). The emerging Local Plan Review should have a much more supportive and pro-active planning policy approach towards supporting new housing development proposals coming forward near to areas of intensive farmland in circumstances where meaningful Biodiversity Net Gain (BNG) features are being delivered within the new housing development site layouts. These aspects are covered in further detail within Appendix C of this Representations Statement (2023).
Q- B.5 Please select the option which is most appropriate for South Warwickshire. Option B5a: Explore and pursue an integrated Environmental Net Gain Policy. I am disappointed to see such a low minimum target for proposed biodiversity net gain. Other councils such as Greater Cambridgeshire have been more ambitious requiring 20% Biodiversity net gain. This would be more in keeping with mitigating our environmental state of emergency Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. Q B 9 Yes. In order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets. BQ. 10. Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
7. Chapter 11: A biodiverse and environmentally resilient South Warwickshire Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
No answer given
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.