Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan?
Items for clarification 1.1 How has the impact of major roads been determined – some sites are not near one but will need to create a major access road to get to them? 1.2 How has access to transport / facilities been determined – several assessments in SA Technical appendices are flagged as positive but are not in reality e.g. bus stops frequency means only Warwick Rd and Kenilworth Rd are any good, and train station is outside parameters. 1.3 How has the lack of regular, reliable trains (especially local) been factored into the SA for Kenilworth? 3 Items for note / update in future documents 3.1 I had difficulty reading several of the documents as the original font used in the pdf documents was too small and pale or an unhelpful colour, especially the pale blue text. In these circumstances, increasing the size percentage does not improve legibility. 3.2 Acronyms and Abbreviations items omitted: CA, and LGS – what do these stand for? 3.3 SA Technical Appendix B – needs a key for the mitigations column 3.4 SA4 page 40 – Chase Lane in Northwest site is 6 miles from Warwick hospital A+E, not 6.6km, which would probably change the assessment. Shouldn’t all distances be is miles as that is standard use for distances on all signposts. 3.5 SA4 page 40 paragraph above table – typo: complimentary should be complementary.
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, 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.
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, 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.
A Two Part Plan Some concerns exist 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 identify 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 could be problematic as it is may 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). Should the Councils decide to produce a 2 part Local Plan then the Part 2 will need to be in conformity with the SWLP. Itis possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. We are concerned this will delay the delivery of much need smaller housing sites. The Plan Period The preparation of a plan that will run to 2050 is sensible. 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 homes over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies that can respond to the fact that the local economy and housing needs are likely to change during the course of the period up to 2050.
The South Warwickshire Local Plan is at a relatively early stage of production. The current consultation is the Issues and Options phase, and includes the publication of a number of options for the future policy direction of the plan set out in a Consultation Document. We have noted that it is now intended to bring forward the SWLP in 2 parts, and only Part 1 is currently progressing through the plan-making process. Part 1 sets out strategic policies, and will not set out detailed site allocations. It is unclear exactly what the scope and content of Part 2 may be, and how it will relate to other plan processes in the plan area such as the Stratford-on-Avon Site Allocations Plan. We have requested clarification of how it is intended that detailed site allocations to cover the plan period up to 2050 will be set out following the adoption of the SWLP Part 1. We have also provided comments on a number of the elements set out in the Consultation Document: a. The assessment of housing needs and the alternative method set out in the HEDNA. We support the alternative method and the level of housing need that the SWLP needs to make provision for. We have noted that the Consultation Document does not set out a housing requirement for the plan, nor has there yet been an agreed assessment of the amount of unmet need to be accommodated from the Birmingham and the Black Country HMA. We will comment on these matters at the next stage of plan making. b. We have commented on the options for the development of a spatial strategy to guide the distribution of development across the plan area. Noting that no strategy is yet proposed, we have noted that taking elements from each of the options presented would be likely to result in a strong spatial strategy that will be able to meet development needs and also sustain settlements of all sizes across the plan area. In particular, elements of the strategy which would enable the creation of networks of sustainable rural settlements, promoting the future sustainability and viability of rural communities, should be balanced against the need to ensure that strategic development is accommodated in locations well related to existing urban areas and transport routes, and/or in new settlements. c. We have commented on detailed policy matters including the policy elements looking at 20-minute neighbourhoods, settlement boundaries and Special Landscape Areas. We have set out the characteristics of Ettington and our client’s land at Rogers Lane, Ettington. The site is available, suitable, economically viable and achievable, and deliverable in the short term. The future development prospects and suitability of this site in accommodating housing development has clearly been recognised by Stratford-on-Avon District Council by virtue of officers previously supporting an application on the subject site for 80 dwellings and the site being included in the SAP previously as a future reserve housing site. We believe that the Council’s assessments show that Ettington has a number of sustainable characteristics which make it suitable for growth in the plan period to 2050, and it can be shown that the main heritage constraints affecting the site can be overcome.
Claverdon has had difficulty assessing the volume and detail of the plan in the timescale. We realise that some difficulties are inevitable but there are in reality only a few key issues in the plan and they are lost in the excessive detail. It would be better if several of the policy areas were dealt with in a separate consultation probably reserved to the individual District authorities in line with the subsidiarity principle. Claverdon considers that the Part 1 plan should be a high level strategic plan which contains the issues which are central to the long term settlement pattern of the sub Region. The plan is also unrealistically long given the rate of social and economic change. There should be intermediate 5 year time periods with milestone and SMART targets. In addition the plan should be backed by a financial analysis of the cost of different options and a risk assessment of affordability of the different approaches. The failure to include a major set of options about the green belt in the consultation indicates a lack of appropriate focus. It essential that the Preferred Option stage is far more focussed and cogent with these intermediate stages and targets.
No answer given
Please refer to detailed response. The vision is too narrowly focused on the main settlements and needs to ensure that a comprehensive vision for the plan area is included for which provides the basis for preparing Local Plan 2s (LP2s) for each district. A comprehensive vision that relates to the plan area as a whole should be one of the key drivers for preparing a Joint Local Plan. The discussion in relation to the spatial strategy in the I&O document is considered too limited in scope and overly focused on the main towns. It is also crucial that the Part 1 Plan provides a coherent strategy for LP2s and updates to Neighbourhood Plans, including infrastructure requirements. The vision and spatial objectives should be clear that the principle of the Green Belt remains, and it will continue to shape new development, especially with regard to its fundamental aim of preventing urban sprawl by keeping land permanently open (NPPF paragraph 137).
2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns.
General Comments 2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns. 3. As a further point of clarity, albeit specific to Stratford on Avon District, some Neighbourhood Plans have responded positively to Policy CS16 of the Core Strategy and have formally identified reserve housing sites (e.g. Wellesbourne). Although the District Council is still proceeding with the preparation of the Site Allocations Plan (SAP), clarity is required that current reserve housing sites allocated in the Development Plan will be taken forward whether into the SAP or this Local Plan. 4. A corollary is that E8.1 raises a specific question about whether “Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP”. The same question should have been asked about reserve housing sites.
General Comments 2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns. 3. As a further point of clarity, albeit specific to Stratford on Avon District, some Neighbourhood Plans have responded positively to Policy CS16 of the Core Strategy and have formally identified reserve housing sites (e.g. Kineton). Although the District Council is still proceeding with the preparation of the Site Allocations Plan (SAP), clarity is required that current reserve housing sites allocated in the Development Plan will be taken forward whether into the SAP or this Local Plan. 4. A corollary is that E8.1 raises a specific question about whether “Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP”. The same question should have been asked about reserve housing sites.
General Comments 2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns.
General Comments 2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns.
The JPC has had difficulty assessing the volume and detail of the plan in the timescale. We realise that some difficulties are inevitable but there are in reality only a few key issues in the plan and they are lost in the excessive detail. It would be better if several of the policy areas were dealt with in a separate consultation probably reserved to the individual District authorities in line with the subsidiarity principle. The JPC considers that the Part 1 plan should be a high level strategic plan which contains the issues which are central to the long term settlement pattern of the sub Region. The plan is also unrealistically long given the rate of social and economic change. There should be intermediate 5 year time periods with milestone and SMART targets. In addition the plan should be backed by a financial analysis of the cost of different options and a risk assessment of affordability of the different approaches. The failure to include a major set of options about the green belt in the consultation indicates a lack of appropriate focus. It essential that the Preferred Option stage is far more focussed and cogent with these intermediate stages and targets.
The Chamber broadly supports the proposed content and structure for the new plan as it is outlined in the consultation. There are some questions about which content and proposed policies sit in Part 1 or Part 2 of the new plan and this will require additional research and evidence to be available in order to produce a firm view on some of the questions and issues raised.
Hill Residential generally support the proposed broad content of the Part 1 plan. 20 The identification of Hatton for a potential new settlement is logical and wholly aligns with the aspirations of the SWLP. The Vision Document at Appendix 1 of these representations demonstrates how Hatton New Community can be delivered to align with the five pillars of the SWLP. Hill Residential welcomes the opportunity to continue to engage with the SWLP process to promote the sustainable, logical and unique opportunity that is presented at Hatton New Settlement.
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.
Section 1.3 of the Issues and Options Consultation Document states: “Once Part 1 is fully adopted, it will replace the existing strategic policies of the Stratford -on-Avon District Council Core Strategy and Warwick District Councils Local Plan.” Paragraph 20 of the NPPF defines strategic policies as: “Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision13 for: a) housing (including affordable housing), employment, retail, leisure and other commercial development; b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat); c) community facilities (such as health, education and cultural in frastructure); and d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.” In respect of non-strategic policies, Paragraph 28 of the NPPF states that they can include “the provision of infrastructure and community facilities at a local level, establishing design principles, conserving and enhancing the natural and historic environment and sett ing out other development management policies.” A significant amount of the issues identified within the Issues and Options consultation are detailed Development Management matters such as design-led issues which are not, by definition, strategic issues. Given the purpose of the Local Plan Part 1 and the NPPF definitions detailed above, it is not considered appropriate for these matters to be considered through the Part 1 process. Rather, they should be reserved for the Local Plan Part 2.
Section 1.3 of the Issues and Options Consultation Document states: “Once Part 1 is fully adopted, it will replace the existing strategic policies of the Stratford -on-Avon District Council Core Strategy and Warwick District Councils Local Plan.” Paragraph 20 of the NPPF defines strategic policies as: “Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision13 for: a) housing (including affordable housing), employment, retail, leisure and other commercial development; b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat); c) community facilities (such as health, education and cultural in frastructure); and d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.” In respect of non-strategic policies, Paragraph 28 of the NPPF states that they can include “the provision of infrastructure and community facilities at a local level, establishing design principles, conserving and enhancing the natural and historic environment and setting out other development management policies.” A significant amount of the issues identified within the Issues and Options consultation are detailed Development Management matters such as design-led issues which are not strategic issues. Given the purpose of the Local Plan Part 1 and the NPPF definitions detailed above, it is not considered appropriate for these matters to be considered through the Part 1 process. Rather, they should be reserved for the Local Plan Part 2.
We are concerned that the plan as currently envisaged will leave many unanswered questions and could rely too heavily on the production of Site Allocation Plans or Neighbourhood Development Plans. The comments we have made above suggest some ways in which the level of uncertainty could be reduced and would urge them to be taken up. The Call for Sites is an important part of the plan making process but would appear destined to leave many site promoters uncertain of their position, potentially for a considerable length of time. This could be addressed, at least in part, by providing greater certainty on the scale and distribution of growth across the plan area and by providing for a strategic level of growth on small sites (i.e. with a capacity of less than 50 dwellings for housing and say less than 10 hectares for employment)
The JPC has had difficulty assessing the volume and detail of the plan in the timescale. We realise that some difficulties are inevitable but there are in reality only a few key issues in the plan and they are lost in the excessive detail. It would be better if several of the policy areas were dealt with in a separate consultation probably reserved to the individual District authorities in line with the subsidiarity principle. The JPC considers that the Part 1 plan should be a high level strategic plan which contains the issues which are central to the long term settlement pattern of the sub Region. The plan is also unrealistically long given the rate of social and economic change. There should be intermediate 5 year time periods with milestone and SMART targets. In addition the plan should be backed by a financial analysis of the cost of different options and a risk assessment of affordability of the different approaches. The failure to include a major set of options about the green belt in the consultation indicates a lack of appropriate focus. It essential that the Preferred Option stage is far more focussed and cogent with these intermediate stages and targets.
Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan? 15. Yes, MSL support the allocation of other sites as necessary for short-term development. These sites should include those proposed to be allocated as reserve sites within the Site Allocations Plan, such as MSL’s site at Hampton Lucy: Policy HAMP.A. The site’s suitability, availability and deliverability has therefore been assessed, and found to be acceptable. The site is to be released for development when required by the District Council. The requirement to allocate sites through the South Warwickshire Local Plan should be the trigger to release the reserve sites within the Site Allocations Plan, and this should be confirmed within the South Warwickshire Local Plan Part 1 Document.
We are concerned that the plan as currently envisaged will leave many unanswered questions and could rely too heavily on the production of Site Allocation Plans or Neighbourhood Development Plans. The comments we have made above suggest some ways in which the level of uncertainty could be reduced and would urge them to be taken up. The Call for Sites is an important part of the plan making process but would appear destined to leave many site promoters uncertain of their position, potentially for a considerable length of time. This could be addressed, at least in part, by providing greater certainty on the scale and distribution of growth across the plan area and by providing for a strategic level of growth on small sites (i.e. with a capacity of less than 50 dwellings for housing and say less than 10 hectares for employment).
Priors Marston Parish Council would like to make the following comments for consideration regarding the SWLP: * All new builds should have PV panels, or alternative environmentally friendly electric generation. * Only allow development where local services are available. No new developments should take place unless there is adequate infrastructure and amenities in place; including, but not exclusively, doctors and medical centers, dentist, schools, facilities for teenagers and young people. * All towns and parishes should have a properly defined and stated housing mix, to ensure that communities can be as inclusive as possible. ( A disproportionately large number of 4 to 5 bedroom properties effectively excludes young people from buying locally, and prohibits elderly people from downsizing and remaining in the local area.) * Adequate public transport to reduce traffic and pollution. * Communal power generation. * High speed, fiber optics throughout the area, and not just in larger conurbations. This would encourage and facilitate working from home. * Ensure that highways are properly maintained and properly funded. Where practicable cycle lanes should be provided. * Traffic calming and speed reduction measures should be introduced in all built up areas.
CONCLUSIONS The Issues and Options document confirms that “The South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet our development needs to 2050”. The SWLP has considered potential growth of their existing settlements. The Connectivity Analysis grades land to the north of Wood End (identified as 1B) as B (on a scale of A-E. This is joint first of the 8 locations assessed. The site submitted as part of these submissions is located a 500m walk (6 minutes) from the existing Wood End Railway Station. This station offers an hourly service between Stratford and Kidderminster. The service towards Kidderminster stops at Birmingham Moor Street and Birmingham Snow Hill, taking only 32 minutes (to Moor Street) and 35 minutes (to Snow Hill). Furthermore, this is a local service and stops at the majority of stations enroute, therefore offering access to other facilities in nearby villages and towns. The Local Facilities Review shows that all areas of Wood End have a very similar level of access to facilities (Healthcare and Places to Meet). Only one location (location 5B) offers access to more than two facilities (Open Space, leisure, recreation – wellbeing). Ladbrook Park Golf Club is an 850m walk (10 minutes) from the site, so whilst being 50m in excess of the 800m threshold, this distance is not significantly more to travel and would be realistically possible for the majority of people. Therefore, leisure and recreation is accessible in close proximity to the site. A large area of Stratford and Warwick is designated as Green Belt. This includes the majority of the area’s railway stations with several lines running through the area covered by Green Belt. The Issues and Options document states acknowledges that “the location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated.” It is considered that a Green Belt review is necessary. It is considered that the South Warwickshire Plan should consider growth opportunities in the Green Belt where they would offer sustainable development (for example railway connections)and agree with the Issues and Options document that locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option. In a time where we are seeking to encourage more sustainable movement patterns and reduce carbon emissions as much as possible, it seems reasonable to locate development in locations which can benefit from public transport. The Scoping and Call for Sites document proposed seven initial options for growth. These have been refined to five options. In our view, Option 1 (Rail Corridors) should be considered essential as they offer a sustainable alternative to car travel. The Beckett Family are promoting land west of The Common, Wood End. The site can accommodate a development for approximately 200 dwellings, a community facility, open space and allotments. Land west of The Common, Wood End is considered a sustainable site for residential development, given the reasons discussed above.
Q-P1.2: 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. 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. 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. 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. 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. 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. General comments: Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stratford-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. 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 the 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. 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.
CONCLUSIONS The Issues and Options document confirms that “The South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet our development needs to 2050”. The SWLP has considered potential growth of their existing settlements. The Landform Analysis shows that there are limited directions for growth in Henley-in-Arden. The Landform Analysis suggests that west of Henley-in-Arden and north of Henley-in-Arden are the only locations which are landform constraint free. The Connectivity Analysis grades land to the west of Henley-in-Arden (identified as 1D) as D (on a scale of A-E. HIA Developments consider that the connectivity analysis has failed to properly assess the existence of an important footpath underneath the railway (via an underpass) which has the potential to provide additional walking and cycling connectivity to land to the west of Henley-in-Arden. This potential has been missed in the analysis. As a consequence, the results of the Connectivity Analysis are flawed. The Local Facilities Review shows that west of Henley-in-Arden is well connected in terms of facilities. The review confirms that within 800m there is access to Retail, economy, employment, places to meet, open space and leisure, health care and education. This ranks equal first in comparison with the other directions for growth. A large area of Stratford and Warwick is designated as Green Belt. The Issues and Options document states acknowledges that “the location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated.” HIA Developments LLP considers that a Green Belt review is necessary. HIA Developments consider that the South Warwickshire Plan should consider growth opportunities in the Green Belt where they would offer sustainable development (for example railway connections) and agree with the Issues and Options document that locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option. In a time where we are seeking to encourage more sustainable movement patterns and reduce carbon emissions as much as possible, it seems reasonable to locate development in locations which can benefit from public transport. The Scoping and Call for Sites document proposed seven initial options for growth. These have been refined to five options. Each of the five spatial options identifies growth at Henley-inArden. HIA Developments are promoting land to the West of Henley-in-Arden. The site can accommodate a development for approximately 110 dwellings. Land to the west of Henley-in-Arden is considered a sustainable site for residential development, given the reasons discussed above.
Lockley Homes would select ‘No’ to Question P1.1 referred to above. Producing two separate Local Plans – Parts 1 and 2 will add significant confusion and a major time delay to the Local Plan making process. This will cause significant uncertainty for housing developers, rural landowners, local businesses, local communities and other key stakeholders. Our concerns about the Council’s proposed Plan-making approach are set out below. Page 174 (Chapter 12) of the SWLP (January 2023) states that: “…The South Warwickshire Local Plan will be divided into two parts. Part 1 would be a single document, while Part 2 could consist of multiple documents. Neighbourhood Development Plans would form part of the wider Development Plan for South Warwickshire, but would not fall within either Part 1 or Part 2….” Lockley Homes strongly objects to the Council’s proposed Local Plan-making approach of producing a Stage 1 and Stage 2 (Parts 1 and 2) of the SWLP. This will just add a significant confusion to the Plan-making process, and will result in a significant time delay to Local Plan delivery across the South Warwickshire Region. At a time when the local economy is facing such considerable economic uncertainty. This does not bode well for the delivery of a certain and clear planning policy framework going forward across the South Warwickshire area. Page 174 of the SWLP (January 2023) states that ‘smaller and non-strategic housing site allocations’ will be brought forward under Part 2 of the Local Plan. In response, Lockley Homes considers that placing small-scale and medium scale housing sites within a Stage 2 SWLP is completely unacceptable situation. This proposed planning policy approach is in direct conflict with paragraphs 60 and 69 of the Revised NPPF (2021). Paragraph 69 of the Revised NPPF places considerable importance on small and medium-sized housing sites and their important contribution towards meeting the housing requirement of an area, and the fact that these sites are often built-out relatively quickly to help meet the urgent housing needs. These important small and medium-sized housing sites should be brought forward as a matter of urgency within the emerging SWLP at the very front of the Local Plan period, in order to help boost the supply of new homes, consistent with paragraph 60 of the Revised NPPF (2021). These types of small housing sites have a key role to play in helping to deliver a much-needed supply of new homes to help tackle long-standing housing shortfalls present across the South Warwickshire Region. Relying on large Strategic Housing Sites to support the front of the Local Plan period (Stage 1/ Part 1) also has considerable risks, given that the local area is currently facing significant economic pressures/ the local area is facing a 300-year-economic-recession-event, and severe volatility in the residential mortgages market due to rising inflation. This approach to Plan making may not therefore be deliverable and would fail deliverability tests set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). This would affect the ‘Soundness’ of the overall proposed Plan-making approach, given that the Local Plan could be challenged against the above NPPF guidance. We suspect that the Councils preparing the emerging SWLP are already aware that they are taking forward an unsound Plan-making approach that tails tests of Soundness in paragraph 35 (indent d) of the Revised NPPF (2021) – given the Plans continual ongoing failure and continued refusal to promote the most sustainable patterns of new housing development within the South Warwickshire Region. This is supported by evidence given the highly obstructive planning policy approach being taken against the Lockley Homes site within the Village of Broom settlement. Which represents a highly sustainable site location for new housing. Moving smaller and medium sized sites to some time in the distant future to be considered within a SWLP Stage 2/ Part 2 Plan version, is therefore helping the Council’s avoid the issue of why the Council’s are still refusing to promote the most sustainable patterns of new housing development coming forward within the South Warwickshire Districts. We find this highly obstructive approach being taken towards Local Plan preparation very concerning. The Council’s Planning Policy Teams stance on these issues is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making.
These representations are made by Pegasus Group, on behalf of a Lone Star Land Ltd, in response to the South Warwickshire Local Plan Issues and Options consultation. The representations have had regard to the published consultation document and questions set out therein, accompanying published evidence and the national and local planning policy context. They provide in-principle support for the Council's spatial approach to their emerging Local Plan and, in particular, support for the identification of large-scale strategic sites and for a positive allocation of land for a new settlement at Deppers Bridge for a residential-led development. Whilst it is acknowledged that both Stratford Upon Avon and Warwick District Council identify there is further work to do on housing numbers, these representations seek to make some detailed comments on that subject. These are intended in a positive manner, and we would welcome the opportunity to make further detailed comments on this matter at the appropriate time. These representations fully support the proposed identification of a new settlement strategy to deliver housing and infrastructure to accommodate growth at scale. Given the quantum of development which will be needed in South Warwickshire, a dispersed growth option which seeks to allocate housing across existing towns and villages, relying on existing infrastructure would quickly overwhelm those settlements and their social infrastructure. A strategy which seeks to rely on large scale strategic sites that provide the opportunity to deliver infrastructure-led development alongside housing growth in new settlements that can contain and consume their own needs, is a more sustainable and effective way of addressing the development requirements of South Warwickshire. This representation considers that land at Deppers Bridge forming site F2 of the new settlement sites within the Issues and Options document demonstrates its suitability as strategic new settlement site to accommodate future growth in South Warwickshire. It provides a sustainable opportunity to deliver growth and to meet future needs and the requirements of the emerging South Warwickshire Local Plan. The identification and delivery of a new settlement at Deppers Bridge would assist in delivering the objectives of the South Warwickshire Local Plan. Lone Star Land Ltd are committed to the delivery of necessary supporting infrastructure. Technical work in a number of disciplines is underway and a full programme of engagement will be undertaken with relevant stakeholders. Emerging work is being undertaken to fully evidence the delivery and feasibility to facilitate the creation of a new railway station at Deppers Bridge which would be one of the many benefits crucial to creating a new sustainable settlement in this location. Lone Star Land welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site to assist in the accurate assessment of the site, this can be provided upon request.