Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan?
No, MacMic Group do not agree with the proposed approach. It is proposed that the SWLP will take the form of a Part 1 Local Plan to deal with the Vision and Strategic Objectives, Growth Strategy and Strategic Policies, followed up by a Part 2 Local Plan setting out detailed policies (in one or more Development Plan Documents) and Area Actions Plans. MacMic Group consider that this approach to plan-making in South Warwickshire is unnecessarily burdensome, and indeed likely to lead to greater uncertainty for stakeholders including local communities over a longer period of time. Whilst the production of a Part 1 Local Plan would initially support a more streamlined process to adoption, overall the time implications of producing a Part 1 Local Plan followed up by a Part 2 Local Plan are likely to be far more significant than the production of a single all-encompassing Local Plan. The implication of this is the potential for housing and employment growth in South Warwickshire to be inhibited, particularly as the SWLP is proposing to include the majority of strategic and non-strategic site allocations in the Part 2 Local Plan with only certain strategic site allocations and broad locations to be identified in the Part 1 Local Plan. This may result in the respective Councils not being able to demonstrate a positive Five Year Housing Land Supply position, and less sustainable sites than would otherwise be deemed appropriate for allocation may have to be looked upon favourably. MacMic Group raise specific concerns with how the SWLP is proposing to deal with Green Belt release, with suggestion in Tables 16 and 17 of the Issues and Options document that Green Belt boundaries will be amended in the Part 1 plan but non-strategic allocations saved for Part 2. This could lead to land being released from the Green Belt in Part 1, but non-strategic sites not allocated and thus not supported for development in principle until the Part 2 plan is adopted. This would be impractical given the basis for Green Belt release would be to allow sites currently in the Green Belt to come forward for development. Dealing with Green Belt release and non-strategic allocations in a single all-encompassing Local Plan would also support delivery of residential development in the early part of the SWLP period. As such, MacMic Group suggest that the Local Plan process being adopted by the SWLP is reconsidered, and a single all-encompassing Local Plan be produced from the outset.
We strongly disagree with the approach of starting with a high-level, strategic part 1 Local Plan. Although the Plan could be split, we strongly believe the Part 1 Plan should include Development Strategy, Strategic Policies and Specific Site Allocations. The only aspect that we would agree could be split out to a Part 2 are the Detailed Development Management Policies.
No, Jaguar Land Rover request that policies related to the Core Opportunity Area and Major Investment Sites (their retention and expansion) be included within the list of policies to be included in the Part 1 plan. This is important to provide certainty for Jaguar Land Rover in moving forward, and reflects their strategic importance to the area.
- As per our response to the Scoping Consultation we disagree with the approach of a two-part SWLP, starting with a high-level, strategic part 1 Local Plan. While such an approach may be deemed desirable in terms of speeding up the adoption process of a part 1 Plan, such an approach will result in an absence of important policies that are needed to deliver the vision, objectives and priorities in the area whether they are in Plan 1 or not. A single Plan with a comprehensive set of policies that were all prepared at the same time, will in our opinion lead to a more robust, deliverable and successful plan. - By splitting the Allocations out from the Development Strategy, it will most likely lead to disengagement amongst most people and would not provide any clarity to communities and landowners. - Furthermore, splitting the Allocations from the Strategy will also result in more speculative, unplanned development coming forward given that both Stratford District Council’s Core Strategy and Warwick District Council’s Local Plan are both over 5 years old.
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We are paying for this council. So there should be an option to say NO ! And when we say no it should be NO.
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The plan so far does not take enough note of NDPs, which were developed at great cost and enormous effort on behalf of communities. They should be given considerable weight when looking at developing policy which will impact NDP communities. The idea that they must be re-written, if ignored for the purposes of SWLP is preposterous and an insult to those that worked so hard to produce such documents in response to HMG and LA encouragement.
18. No, Jaguar Land Rover request that policies related to the Core Opportunity Area and Major Investment Sites (their retention and expansion) be included within the list of policies to be included in the Part 1 plan. This is important to provide certainty for Jaguar Land Rover in moving forward, and reflects their strategic importance to the area.
61. No, MacMic Group do not agree with the proposed approach. 62. It is proposed that the SWLP will take the form of a Part 1 Local Plan to deal with the Vision and Strategic Objectives, Growth Strategy and Strategic Policies, followed up by a Part 2 Local Plan setting out detailed policies (in one or more Development Plan Documents) and Area Actions Plans. MacMic Group consider that this approach to plan-making in South Warwickshire is unnecessarily burdensome, and indeed likely to lead to greater uncertainty for stakeholders including local communities over a longer period of time. 63. Whilst the production of a Part 1 Local Plan would initially support a more streamlined process to adoption, overall the time implications of producing a Part 1 Local Plan followed up by a Part 2 Local Plan are likely to be far more significant than the production of a single all-encompassing Local Plan. 64. The implication of this is the potential for housing and employment growth in South Warwickshire to be inhibited, particularly as the SWLP is proposing to include the majority of strategic and non-strategic site allocations in the Part 2 Local Plan with only certain strategic site allocations and broad locations to be identified in the Part 1 Local Plan. This may result in the respective Councils not being able to demonstrate a positive Five Year Housing Land Supply position, and less sustainable sites than would otherwise be deemed appropriate for allocation may have to be looked upon favourably. 65. MacMic Group raise specific concerns with how the SWLP is proposing to deal with Green Belt release, with suggestion in Tables 16 and 17 of the Issues and Options document that Green Belt boundaries will be amended in the Part 1 plan but non-strategic allocations saved for Part 2. This could lead to land being released from the Green Belt in Part 1, but non-strategic sites not allocated and thus not supported for development in principle until the Part 2 plan is adopted. This would be impractical given the basis for Green Belt release would be to allow sites currently in the Green Belt to come forward for development. Dealing with Green Belt release and non-strategic allocations in a single all-encompassing Local Plan would also support delivery of residential development in the early part of the SWLP period. 66. As such, MacMic Group suggest that the Local Plan process being adopted by the SWLP is reconsidered, and a single all-encompassing Local Plan be produced from the outset.
The Part 1 Plan seeks to cover a very broad range of issues and topics, some of which (as identified through the representations above) are considered to introduce matters which go beyond current national requirements and / or are not yet fully understood (such as “wildbelts”). The logic for following a 2-part Local Plan production process, which necessitates the allocation of fewer sites within the SWLP area in the Part 1 Plan, is also questionable. The NPPF10 requires Local Planning Authorities (LPAs) to plan for, and allocate, sufficient sites to deliver the strategic priorities of the area. BDWH considers that it would be more efficient for the South Warwickshire LPAs to achieve this via progressing a single Local Plan. This would ensure that there is suitable confidence that the infrastructure to deliver all of the housing supply is available and has been suitably planned for. It is not considered to be either necessary or efficient for the emerging Local Plan to be split into two parts. It should also be noted that the Government is seeking to speed up the Plan-making process (as evidenced by some of the proposals being mooted through the Levelling Up and Regeneration Bill) and this does not align with the sort of two-part approach being sought by the South Warwickshire authorities. It is therefore considered that the production of a single Local Plan would be the simplest and most transparent option for enabling the South Warwickshire authorities to provide certainty and demonstrate at the earliest opportunity that it has an up-to-date deliverable Development Plan that can achieve the NPPF site allocation and land supply requirements, backed up with a robust plan for the delivery of infrastructure. 10 National Planning Policy Framework (2021). Paragraph 23.
3.44 The document as drafted does not currently make any reference to the safeguarded land previously identified in the adopted WDC Local Plan. However, the table at chapter 12 confirms that Policy DS21 “Safeguarded Land” will be addressed in the Part 1 plan due to it being considered a strategic policy for the SWLP. 3.45 The safeguarded sites should be the first to come forward to deliver much needed housing development, as they have already been determined to be suitable for development and subsequently removed from the Green Belt. Therefore, the safeguarded land at Westwood Heath Road should receive an allocation to enable the Site to deliver new homes in the early stages of the plan period
3.80 Yes, Taylor Wimpey generally supports the proposed broad content of the Part 1 plan. However, further supporting evidence is required at this stage as set out in the above representations, with greater guidance also required around the definition of strategic sites. The most sustainable and larger scales sites should be considered as the focus for this, particularly Land north of Leamington, promoted by Taylor Wimpey under these representations.
2.93. No. The Respondent has significant concerns regarding the preparation of a two-part plan. The Respondent’s main concern with regards to a two-tier system is the inevitable delay in plan-making that will occur as result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. 2.94. The current two-tier approach in Stratford-on-Avon District Council is a prime example of where significant delays in the preparation of second tier policy documents have occurred. In proposing a two-tier SWLP, the authorities are in danger of repeating the same mistakes of the Stratford on Avon Local Plan and putting in place a Plan that will genuinely not be reviewed every five years as required by national guidance. 2.95. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect any updated evidence needs. This is a particular concern given the projected end date of the plan. 2.96. While it is noted that the intention is to “allow for a flexible, robust and long-lasting framework” this can be difficult to achieve in practice and will need to be given very careful consideration when policies are drafted. 2.97. The South Worcestershire Development Plan has demonstrated that it is entirely possible for authorities to work together to produce a complex development plan covering all aspects of managing growth across three or four LPAs without recourse to a divisive and time-consuming two-tier approach. 2.98. On this basis, it is considered that a comprehensive local plan should be prepared that includes a full complement of allocations and development management policies; with Area Action Plans, Neighbourhood Plans, Design Codes and Design Briefs/Masterplans prepared in a timely, albeit subsequent, timeframe.
We agree with the proposed broad content of the Part 1 plan, which would deal with the vision, strategic objectives, growth strategy and strategic policies. This approach, would in our view could expedite the plan making process, provide clarity and certainty for developers and allow a focus on the strategic priorities. However, we do continue to have reservations as indicated to our response to the scoping consultation, repeated below. In splitting the Local Plan out as envisaged, it is important that the part 1 Local Plan progresses on its own LDS programme/timetable and advances to adoption as expediently as is reasonably possible. It would not be appropriate for the part 1 Local Plan to be delayed to tie in with an LDS programme in relation to other elements of the Development Plan. It is also important that the part 1 Local Plan is the subject of its own examination – by way of example, in North Essex the three Councils submitted both their part 1 and part 2 Local Plans concurrently, and because the part 1 Local Plan was significantly delayed at examination stage (and significantly altered through the examination) it caused a follow-on significant delay to the part 2 Local Plan without the Councils being able to make any changes to part 2 plan content. It is also the case that deferring all allocations to later parts of the Development Plan relies upon those later parts being found sound. Were that not to be the case, the result would be a defined development strategy and housing and other development needs but no delivery mechanism absent of any positive allocations to implement the part 1 requirements. This is precisely the trap South Kesteven fell in to with their Development Plan – the Core Strategy identified a development strategy heavily reliant on Grantham (with over 50% of the entire plan period housing to be delivered at Grantham) and allocations deferred to an AAP. The AAP was found unsound at examination, and with no ability to deliver housing at Grantham the Council were faced with unplanned housing applications to determine.
Issue P1: Part 1 and Part 2 plans We agree with the proposed broad content of the Part 1 plan, which would deal with the vision, strategic objectives, growth strategy and strategic policies. This approach, would in our view could expedite the plan making process, provide clarity and certainty for developers and allow a focus on the strategic priorities. However, we do continue to have reservations as indicated to our response to the scoping consultation, repeated below. In splitting the Local Plan out as envisaged, it is important that the part 1 Local Plan progresses on its own LDS programme/timetable and advances to adoption as expediently as is reasonably possible. It would not be appropriate for the part 1 Local Plan to be delayed to tie in with an LDS programme in relation to other elements of the Development Plan. It is also important that the part 1 Local Plan is the subject of its own examination – by way of example, in North Essex the three Councils submitted both their part 1 and part 2 Local Plans concurrently, and because the part 1 Local Plan was significantly delayed at examination stage (and significantly altered through the examination) it caused a follow-on significant delay to the part 2 Local Plan without the Councils being able to make any changes to part 2 plan content. It is also the case that deferring all allocations to later parts of the Development Plan relies upon those later parts being found sound. Were that not to be the case, the result would be a defined development strategy and housing and other development needs but no delivery mechanism absent of any positive allocations to implement the part 1 requirements. This is precisely the trap South Kesteven fell in to with their Development Plan – the Core Strategy identified a development strategy heavily reliant on Grantham (with over 50% of the entire plan period housing to be delivered at Grantham) and allocations deferred to an AAP. The AAP was found unsound at examination, and with no ability to deliver housing at Grantham the Council were faced with unplanned housing applications to determine.
The NPPF requires Local Planning Authorities (LPAs) to plan for, and allocate sufficient sites to deliver the strategic priorities of the area (National Planning Policy Framework (2021) paragraph 23). Crest Nicholson considers that the most efficient way for the South Warwickshire LPAs to achieve this is to progress a single local plan, as opposed to a two part plan. This would ensure that there is suitable confidence that the infrastructure to deliver all housing supply is available and has been suitably planned for. It is not considered to be either necessary or efficient for the emerging Local Plan to be split into two parts. It should also be noted that the proposals being mooted through the Levelling Up and Regeneration Bill seek to speed up the Plan-making process and do not align with the sort of two-part approach being sought by the South Warwickshire authorities. The production of a single Local Plan would therefore be the simplest and most transparent option for enabling the South Warwickshire authorities to provide certainty and demonstrate at the earliest opportunity that it has an up-to-date deliverable Development Plan that can achieve the NPPF allocation and land supply requirements, backed up with a robust plan for the delivery of infrastructure.
Agree that sites should be allocated in the Part 1 SWLP to meet both strategic and short term housing needs. It is unclear when the Councils intend to produce / adopt the Part 2 plans. Given the significant housing shortfall arising from the Greater Birmingham HMA, the SWLP needs to make sure there is a sufficient number of sites allocated in the SWLP to meet needs for the next 5 – 10 years. Waiting for the Part 2 plans to be adopted is likely to cause delays in meeting the significant housing needs of the District and wider HMAs.
A Two Part Plan We have some concerns with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and allocate the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach is problematic as it will delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). The Local Plan Part 2 will need to be prepared to be in general conformity with the SWLP Part 1. It is unlikely that the Part 2 Plan will be adopted for at least two to three years following the adoption of the SWLP Part 1 even if their preparation overlaps. Indeed, the Stratford-on-Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not adopted. This means that no localised allocations will be in place until late 2027 at the earliest, given past planning performance it is likely to be much later than this. As a significant proportion of the housing allocations will not be in place for a number of years, this has the potential to significantly harm housing delivery. Preparing a two part plan will delay the delivery of much needed market and affordable housing and non strategic employment sites during first part of the plan period. This will make home ownership more challenging, has potential to increase house prices and worsen affordability and hinder affordable housing delivery. It could also stifle economic growth. This will directly conflict with the Draft Plan’s Strategic Objective of delivering homes that meets the needs of all the plan areas communities (SO 4) and developing Job Opportunities (SO 3). It could also result in a 5 year housing land supply shortfall and increase the number of speculative planning applications. The Plan Period We support the preparation of a plan that will run to 2050. Having an extended plan period will allow for the SWLP to properly respond to long term issues, and support the allocations of larger, strategic sites that will deliver over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies to respond to the fact that the local economy and housing needs are likely to change significantly during the course of the period 2050. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that in addition to the existing evidence base studies additional technical studies will be commissioned to inform the SWLP as required. One of the identified potential additional studies is a Green Belt study. We have no objection to the preparation of a Green Belt study. There are, however, a number of development opportunities available to the Council that are outside of the Green Belt. Suitable and sustainable non Green Belt development options should be prioritised ahead of Green Belt land release. For example, Spitfire control land at Stratford Agricultural Park to the immediate east of the Long Marston Airfield (LMA) new settlement. As detailed in our Call for Site submission, this site provides an opportunity to expand LMA, providing housing and supporting infrastructure to support LMAs services and facilities helping increase its self-containment. It is readily deliverable and in the control of a developer.
We have some concerns with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and allocate the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach is problematic as it will delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). The Local Plan Part 2 will need to be prepared to be in general conformity with the SWLP Part 1. It is unlikely that the Part 2 Plan will be adopted for at least two to three years following the adoption of the SWLP Part 1 even if their preparation periods overlaps. Indeed, the Stratford-on-Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not adopted. The preparation of a two part Plan means that no small or medium scale allocations will be in place until late 2027 at the earliest, and given past planning performance it is likely to be much later than this. Preparing a two part plan will delay the delivery of much needed market and affordable housing and non strategic employment sites during first part of the plan period. This will make home ownership more challenging, has the potential to increase house prices and worsen affordability and hinder affordable housing delivery. It could also stifle economic growth. This will directly conflict with the Draft Plan’s Strategic Objectives of delivering homes that meets the needs of all the plan areas communities (SO 4) and developing Job Opportunities (SO 3). It could also result in a 5 year housing land supply shortfall and increase the number of speculative planning applications. The Plan Period We support the preparation of a plan that will run to 2050. Having an extended plan period will allow for the SWLP to properly respond to long term issues and support the allocations of larger, strategic sites that will deliver over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies to respond to the fact that the local economy and housing needs are likely to change significantly during the course of the period to 2050. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that in addition to the existing evidence base studies additional technical studies will be commissioned to inform the SWLP as required. One of the identified potential additional studies is a Green Belt study. We have no objection to the preparation of a Green Belt study. There are, however, a number of development opportunities available to the Council that are outside of the Green Belt. Suitable and sustainable non Green Belt development options should be prioritised ahead of Green Belt land release. For example, Vistry control land to the east of Southam. Southam is one of the largest and most sustainable settlements in the Plan area is not constrained by the Green Belt. As detailed in our Call for Site submission, this site provides an opportunity to expand Southam, providing housing and supporting infrastructure such as a primary school. This is particularly important, as we understand that primary school capacity in Southam is limited. The site is readily deliverable and in the control of a developer. It can be brought forward for development promptly if it is allocated in the SWLP.
The Plan Period We support the preparation of a plan that will run to 2050. Having an extended plan period will allow for the SWLP to properly respond to long term issues and support the allocations of larger, strategic sites that will deliver over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies to respond to the fact that the local economy and market requirements are likely to change significantly during the course of the period 2050. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that in addition to the existing evidence base studies additional technical studies will be commissioned to inform the SWLP as required. One of the identified potential additional studies is a Green Belt study. Approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are surrounded by or located within the Green Belt. The South of Coventry Area (SWLP page 68) that is being considered as an allocation for an economic growth hub, is within the Green Belt. The emerging plan should remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is, therefore, essential in order to understand the sensitivity of the Green Belt for development so this matter can be considered alongside other evidence based documents to help establish the most appropriate locations for allocations.
General Observations 2.2. Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stra tford-on-Avon District Council and Warwick District Council up to 2050. Paragraph 22 of the National Planning Policy Framework (NPPF) requires that all strategic policies should have a minimum timeframe of 15 years from point of adoption. While the SWLP is compliant with Paragraph 22 there is concern that a plan period to 2050 may be too ambitious in so far as it may be difficult for the plan to adapt to change. A further concern is that in establishing a 25-year plan period, the SWLP will make decisions that are so long term that it could compromise meeting the development needs of the area. By way of example, the SWLP could allocate a site which would genuinely take 20 years to deliver as a key part of its development strategy and given the magnitude of such sites could lead to smaller sites, in deliverable locations, not coming forward to meet housing needs in the intervening period. 2.3. Section 1.4 of the Consultation Document confirms that it remains the Council’s intention to prepare a two-part plan. The Respondent’s main concern regarding a two-tier system is the inevitable delay in plan-making that will occur as a result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans, there will also be no flexibility in this second-tier documents to make changes to the development strategy to reflect updated evidence needs. This is a particular concern given the projected end date of the plan being some 25 years hence. 2.4. The suggested timetable for the SWLP’s preparation is also considered to be highly ambitious. Given that most Local Plans take more than a year to be Examined by the Secretary of State it is considered very unlikely that Part 1 will be adopted before 2027 and potentially beyond if there is slippage between the public consultation stages indicated in Figure 2 (Page 16) of the Consultation Document.
2.90. No. The Respondent has significant concerns regarding the preparation of a two-part plan. The Respondent’s main concern with regards to a two-tier system is the inevitable delay in plan-making that will occur as result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. 2.91. The current two-tier approach in Stratford-on-Avon District Council is a prime example of where significant delays in the preparation of second tier policy documents have occurred. In proposing a two-tier SWLP, the authorities are in danger of repeating the same mistakes of the Stratford on Avon Local Plan and putting in place a Plan that will genuinely not be reviewed every five years as required by national guidance. 2.92. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect any updated evidence needs. This is a particular concern given the projected end date of the plan. 2.93. While it is noted that the intention is to “allow for a flexible, robust and long-lasting framework” this can be difficult to achieve in practice and will need to be given very careful consideration when policies are drafted. 2.94. The South Worcestershire Development Plan has demonstrated that it is entirely possible for authorities to work together to produce a complex development plan covering all aspects of managing growth across three or four LPAs without recourse to a divisive and time-consuming two-tier approach. 2.95. On this basis, it is considered that a comprehensive local plan should be prepared that includes a full complement of allocations and development management policies; with Area Action Plans, Neighbourhood Plans, Design Codes and Design Briefs/Masterplans prepared in a timely, albeit subsequent, timeframe.