Issue and Options 2023
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Issue C7: Adapting to higher temperatures Q-C7: Please select the option which is most appropriate for South Warwickshire Option C7a – include a policy that requires new developments and changes to existing buildings to incorporate measures to adapt to higher temperatures. Option C7b – Do not include a policy that requires new developments and changes to existing buildings to incorporate measures to adapt to higher temperatures. Option C7c – None of these. 5.8 Catesby Estates submits that the Councils should not include a requirement for development to accommodate measures to adapt to higher temperatures (Option C7c). Instead, this issue should be left to Building Regulations. Issue C8: Adapting to flood and drought events Q-C8: Please select the option which is most appropriate for South Warwickshire Option C8a – Include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flo od and drought events Option C8b – Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to floor and drought events Options C8c – None of these 5.9 Option C8b should be followed, where a policy is not included that goes beyond Building Regulations. 5.10 At present, Stratford’s Core Strategy has Policy relating to SUDs, stating that all development proposals to control and discharge 100% of runoff into SUDs , which is consistent with Policy FW2 of Warwick’s Local Plan. Whilst Stratford doesn’t currently have a policy requirement with regards water consumption, there is reference to minimising water consumption, and Warwick’s Local Plan stipulates specific requirements for water efficiency standards of 110 litres per person, per day for residential developments. 5.11 Furthermore, whilst the above presents a number of Options, wording identified within Issue C8 states that consideration could be given to decreasing the requirement to 100 litres or lower per person, per day which isn’t included within the Options. 5.12 As a result, as the two local authorities have current policies in relation to SUDs provision, and Warwick has water efficiency requirements, it would be appropriate and consistent to pursue this within the South Warwickshire Local Plan. However, any specific water efficiency requirements should be tested via evidence and viability assessments completed, to ensure the Policy is realistic, achievable and deliverable. Issue C9: Mitigating Biodiversity loss Q-C9.1: Please select the option which is most appropriate for South Warwickshire Option C9.1a – Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Option C9.1b – Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Option C9.1c – None of these 5.13 The Environmental Act 2021 sets out a requirement for developments to achieve a Biodiversity Net Gain of 10%. Consequently, there is no need for a separate policy to incorporate measures to increase biodiversity, as all developments will be subject to this statutory requirement, from November 2023. Therefore, Catesby Estates believes that Option C9.1b is the most appropriate Option. However, if the Council want to introduce a separate policy, that requires a greater figure than this, they must demonstrate evidence to show this is needed and that it has been viability tested, to ensure the policy is clearly written and is deliverable, achieving sustainable development, opposed to creating a barrier to development. 5.14 Furthermore, the Council should consider and include mitigation options within their policy, making reference to off-site delivery, if there is no other feasible or viable option on site, where it allows developers to pay a financial offsetting payment.
5.15 As Issue C12 highlights, flood risk is considered a strategic planning matter and will therefore be addressed within Part 1 of the Plan. At present, there is not sufficient evidence to understand what sort or level of work is required.
6.1 Design is not a strategic issue and should therefore be addressed within the respective Part 2 Plans. 6.2 The topics for a strategic design policy should be based upon those identified within Paragraph 130 of the NPPF. The principles set out are acceptable as worded, however further clarity should be made to provide greater detail of the requirements of each topic. Therefore, the principle of the topics are acceptable, however the detail associated with each topic needs to be considered and engaged upon further.
Issue D2: Design Codes and design guides Q-D2: please select all options which are appropriate for South Warwickshire Option D2a – Develop a South Warwickshire Design Guide Option D2b – Develop design guides and/or design codes for specific places (eg existing settlements or groups of settlements, or an area in the case of a new settlement) where the spatial strategy identifies significant change Option D2c – Develop design guides/codes for strategic development sites/locations Option D2d – None of these 6.3 Catesby Estates considers Option D2c most appropriate and notes that these are likely to be the larger and more strategic sites, such as any new settlements. It is not appropriate to have a Design Guide across South Warwickshire as the area is too vast, and has a range of characteristics, therefore would not be representative or achieve suitable design across a variety of landscapes. Therefore, each Site should be assessed on its’ own merits. Issue D3: Designing adaptable, diverse and flexible places Q-D3: Please select all options which are appropriate for South Warwickshire Option D3a – Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. Option D3b – Include a policy which specifies a minimum density requirement across South Warwickshire, whilst emphasising that the minimum may be exceeded. This minimum could for example be set at a similar level to the existing policy in Warwick District. Option D3c – Identify appropriate density ranges for different locations/areas across South Warwickshire are specify these ranges in policy. These ranges could be based upon the prevailing characteristics of existing places. Option D3d – Identify appropriate density ranges for different locations/areas across South Warwickshire based upon accessibility and potential accessibility of these places. Options D3e – None of these. 6.4 Catesby Estates supports Option D3b where policy should specify a minimum density requirement across South Warwickshire. However, the Policy needs to be fully tested and evidence to understand the minimum housing density and requires caveats to enable different densities to be achieved, such as where housing need requires a greater number of one bedroom flats, or 4 bedroom houses which would impact upon density. 6.5 Furthermore, potential site constraints may also impact upon density, consequently, policy needs to be worded identifying the minimum density to be achieved, unless an alternative can otherwise be demonstrated as suitable. 6.6 However, in the current evidence base, it is difficult to fully establish and understand the housing need in relation to house types4 without further sufficient evidence, therefore it is difficult to decipher a suitable housing density. 6.7 It is crucial however that developers continue to maximise their densities across land, without having a negative detrimental visual impact, however should focus on the efficient use of land, in order to contribute towards achieving and delivering the much needed housing numbers. 6.8 One point of clarification is in relation to the density suggestion, as Option D3b states that an example could be set at a similar level to that of the existing policy at Warwick, being 30dph, whereas the Sustainability Appraisal, produced as part of the evidence base has based upon the assessment upon 35dph, thus an inconsistency between the two approaches. 4 PPG: Paragraph 005 Reference ID: 66-005-20190722 (How can density be measured for planning purposes?)
