Issue and Options 2023
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New searchIssue V1: Vision for the Local Plan Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? 2.1 Catesby Estates broadly supports in principle the Vision set out within Chapter 3 which stipulates ‘The Vision is to meet South Warwickshire’s sustainable development needs to 2050, while responding to the climate emergency. Where appropriate and agreed, this could include unmet need from neighbouring authorities. The Plan will provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.’ 2.2 In particular, Catesby Estates supports the identification of the potential to meet unmet need from neighbouring authorities. However, it is crucial the scale and distribution of this need should be agreed through the plan making process. This Vision should accordingly evolve and become more specific, once the detail surrounding the unmet need is established. 2.3 In addition, clarity should also be provided in respect of what is meant by ‘Warwickshire’s sustainable development needs’ which is currently absent. 2.4 Similarly, the Strategic Objectives laid out to address the Vision are also broadly supported, however further detail is requested. 2.5 Catesby Estates supports Strategic Objective 2 (Providing infrastructure in the right place, at the right time) whereby infrastructure is required to support growth in new homes, in order to fully support the communities within South Warwickshire, and contribute towards achieving sustainable development. However, the Objective states infrastructure will be secured through new development, but additional evidence is required to demonstrate what infrastructure is needed where, and how and when it is funded and delivered. 2.6 Strategic Objective 4 (Delivering homes that meets the needs of all our communities) acknowledges the need for further housing within South Warwickshire, and that a variety of house types, mixes and tenures are required to fulfil wider needs, also contributing towards sustainable development. Whilst this concept is supported by Catesby Estates, reference should also be made to meeting the unmet needs of neighbouring authorities, in order to align with and support the delivery of the Vision. 2.7 Strategic Objective 5 (Contributing towards Net Zero Carbon Targets ) seeks to ensure that new development does not cause a net increase in carbon emissions. It proceeds to state that every opportunity should be taken to reduce existing carbon emissions and mitigate against climate harms. We support the objective but as we note later, it is key that the Local Plan is supported by viability evidence to demonstrate this can be delivered alongside all other policy requirements. 2.8 The Strategic Objectives should also clearly set out how they will meet South Warwickshire’s sustainable development needs, in conjunction with contributing to meeting unmet needs of neighbouring authorities and be clear as to what these needs are.
Issue I2: Infrastructure Requirements and delivery and Issue I3: Community Infrastructure Levy QI-2: 3.1 Option I2a states that Part 1 of the Local Plan would set out detail for all scales, types and location for development equally across South Warwickshire, whilst Option I2b would only focus on the strategic infrastructure relating specifically to the growth strategy. 3.2 However, the scope of the Plan as stated on Page 2 of the Consultation Document is that the Part 1 document would set out the overall strategy for the pattern, scale and design quality of places within South Warwickshire. This includes the provision of housing, employment and infrastructure at the strategic level. 3.3 Subsequent Part 2 Plans would then ‘set out detailed policies for specific areas, neighbourhoods or types of development. This could include allocating sites and the provision of infrastructure at a local level, establishing design principles and setting out other more detailed planning policies’. 3.4 In this context, Option I2b is most appropriate, as the Part 1 Plan cannot pre -determine the infrastructure provision that may be required following the identification of sites through Part 2 Plans. To do so would otherwise be pre-emptive of the location and scale of growth to be provided through Part 2 Plans. 3.5 The Councils should nonetheless be clear that infrastructure identified within the Part 1 Plan should be funded through a combination of developer contributions from strategic sites, combined with other sources of external funding. Strategic infrastructure provision should not be reliant upon funding from sites brought forward under Part 2 Plan; again, as to do so would otherwise be pre- emptive of the location and scale of growth to be provided through Part 2 Plans. Moreover, any viability assessment undertaken in support of the Part 1 Plan cannot accurately assess the viability of Part 2 sites, given their full infrastructure requirements cannot be known. QI-3: 3.6 The establishment of a CIL charging schedule (Issue I3) is also directly related to Issue I2: Infrastructure Requirements and delivery. In this regard, we consider that the approach should be informed by a robust viability assessment. We note the government’s recent consultation outlining the Infrastructure Levy, which should be considered once further detail is published.
3.7 Land at South of Main Street, Tiddington is not dependent on any infrastructure that would require safeguarding.
3.8 Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments will be undertaken as the Local Plan progresses to ensure that what is put forward as a preferred development strategy is both deliverable and viable.’ 3.9 Catesby Estates strongly emphasises that the required viability work should be undertaken as a priority, ahead of and to inform the next stages of the Part 1 Local Plan. Matters relevant to viability and deliverability should be considered at the earliest stages of plan -making, to ensure that any allocations identified are viable and deliverable, including identifying infrastructure requirements.
Issue S1 (Green and Blue Corridors) Q-S1: 3.10 Catesby Estates supports the concept in the Consultation Document that the SWLP will take a proactive approach and seek to identify its own ‘Green Corridors’ across the plan area in advance of the Local Nature Recovery Strategy, in line with Option S1a. The Consultation Document suggests that this would allow Strategic Green and Blue Corridors to ‘inform the growth strategy.’ Whilst this is agreed, determining Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced should ensure that the corridors and growth strategy do not conflict with one another. Furthermore, these corridors within the Local Plan also ensures that they are appropriately consulted upon against the statutory tests for plan-making. 3.11 Catesby Estates reserves the right to comment upon any Strategic Green and Blue Corridors identified within future iterations of the Plan. Any such corridors should be based on proportionate evidence, including around delivery. Q-S3.2 3.15 Given the clear deficiency in the supply of brownfield land identified above in response to Question S3.1, Catesby Estates considers Option S3.c should be followed. This is not to say that we do not support the redevelopment of brownfield land, but even on the basis of the theoretical exercise, brownfield land will not supply even half of the housing requirement and so the focus should be on identifying the right sites in the most sustainable locations, importantly those which are deliverable and can meet the ful l policy requirements including affordable housing. Issue S4 (Growth of Existing Settlements) Q-S4.1 3.16 Growth at existing settlements is crucial to ensure their long-term sustainability, vitality and viability of local services such as shops, public houses and sports clubs. This includes settlements of all sizes, ensuring that growth is proportionate to the scale of the existing settlement, whilst also considering its accessibility to other nearby service centres, for higher order services and employment opportunities. Issue S5: The potential for new settlement (s) Q-S5.2 3.21 Catesby Estates recognises the benefits of delivering new settlements as part of an overall growth strategy. However, we also acknowledge the implications this may have for delivery and the importance of a mixture of sites to ensure flexibility of supply, particularly within the early years of the Plan. Growth at existing settlements, including both main towns and large villages, to allow for coherent and balanced development to occur throughout the Districts. Q-S8.1 For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small -scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.34 Limit of 10 dwellings per site / A higher limit is appropriate / A lower limit is appropriate 3.35 Notwithstanding that Tiddington should be a part of the Growth Strategy as set out above, Catesby Estates does not support a threshold approach as this would serve to restrict windfall growth which may otherwise be sustainable and necessary to meet local and wider needs. In this regard, we consider each development should be considered on its own merits. Q-S9 Please select the option which is most appropriate for South Warwickshire 3.36 Option S9a – Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. 3.37 Option S9b – Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.38 Catesby Estates does not support either of these approaches. The purpose of the Part 1 Plan is stated as to set out the overall strategy for the pattern and scale of growth, which will include allocating sites for development. Some of these sites will be adjacent to existing settlements and it would accordingly be prudent to amend existing settlement boundaries to accommodate these allocations (otherwise they would be considered to be ‘open countryside’ in planning terms). 3.39 Any further allocations made through Part 2 Plans would then provide a similar opportunity to make further modifications to settlement boundaries as necessary at that stage. Issue S10: Any other development strategy issues Q-S10 Please add any comments you wish to make about the development distribution strategy for South Warwickshire. 3.41 Catesby Estates wishes to reiterate that a balanced approach should be achieved when looking at the development distribution strategy for South Warwickshire. It is apparent that n ot all of South Warwickshire’s housing need, (in addition to unmet needs of neighbouring authorities), can be met within existing urban areas. Therefore, there is clear need to develop greenfield sites outside of these areas, as well as a need to distribute growth to ensure the vitality of settlements such as Tiddington. 3.42 Nonetheless, in terms of the distribution of this growth, not one individual factor as set out within the Options should be undertaken as an isolated approach. A joint up approach, taking into account infrastructure including public transport access and availability, employment locations, facilities and census information should be considered, but overall a wider balanced approach should be considered. 3.43 Therefore, a wider balanced approach should be proceeded with, to ensure a variety of development comes forward. This would allow the greatest flexibility of supply throughout the plan period.
3.12 The Study sets out that its purpose is to provide evidence that helps to reduce the need for development outside of South Warwickshire’s 23 existing urban areas as far as justifiably possible. Section 4.6 of the Study identifies that there is a total baseline housing supply for the 2025 -2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. Catesby Estates questions the robustness of this figure. The Study acknowledges it is a theoretical exercise without any reference to the application of policy or any other evidence base, including infrastructure requirements, deliverability etc. Paragraph 2.2.2 states that the: “Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice.” 3.13 Notwithstanding this, the Study compares this potential ‘supply’ against a housing need for South Warwickshire of 30,750 dwellings across the Plan Period. This figure is incorrect. The Consultation Document and HEDNA seeks to establish a ‘trend -based’ alternative to the Standard Method, which result in annual housing need of 868 dwellings per annum (Stratford) and 811 dwellings per annum (Warwick), totalling 1,679 dwellings per annum. Multiplied across a 25 -year Plan Period, this need is in fact 41,975 dwellings. This figure is importantly also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. 3.14 The identified potential ‘supply’, inclusive of sites within existing urban areas, is therefore less than half of the overall housing need required during the Plan Period. The Study acknowledges that brownfield land cannot be solely relied upon. We would encourage a more robust assessment of the sites to ensure the potential contribution to supply is established.
3.17 The Settlement Analysis has been undertaken on the basis of a 20-minute neighbourhood principle, using the existing settlements identified as part of the May 2021 consultation. In addition, the Analysis further states that a small number of additional settlements have been further identified and assessed. As a result, it is unclear as to why a review of all settlements has not occurred, or how the settlements that have been analysed were identified as appropriate to add to the analysis. No evidence or justification to demonstrate their position as a settlement is presented. 3.18 Furthermore, the analysis states that this was not run alongside the Call for Sites Submissions, therefore Catesby Estates requests that a further review is undertaken to assess alternative settlements, alongside the Call for Sites Submissions to ensure it is fully reflective of the wider position. 3.19 In addition, Stratford’s Core Strategy sets out a number of Local Service Villages ; Tiddington is an identified Category 1 Local Service Village, scoring beyond 10 when assessed by the Council. Bishop’s Itchington, Harbury, Long Itchington and Quinton are also identified Category 1 Local Service Villages. However, the Settlement Analysis includes a number of those identified Local Service Villages within the Core Strategy, specifically Long Itchington, and other Category 2 Local Service Villages such as Salford Priors, Wilmcote and Wootton Wawen, but Tiddington is excluded from the Settlement Analysis, regardless of its existing position as a Category 1 Service Village. Therefore, the Settlement Analysis is not consistent with the approach of the existing Core Strategy and the exclusion of Tiddington is not justified. 3.20 The Analysis does also set out that there is potential for additional settlements to be assessed using the methodology set out in this document, if the spatial strategy to necessitate it. This needs to happen now to ensure the spatial strategy delivers sustainable development across the whole plan area. See extract from our Vision Document below showing the local services and facilities.
