Issue and Options 2023

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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.

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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.

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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

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Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.

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Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.

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Q-P1.3: Do you agree with the selection of policies to be addressed in the Part 1 plan? Yes Q-P1.4: If not, please indicate why 8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.

9.1. Rainier Developments is promoting land east of Birmingham Road for residential development, inclusive of on-site green infrastructure. 9.2. The land comprises to adjacent fields, currently in agricultural use, with the boundary defined by a fence and sporadic trees and hedge planting. The site boundaries are well defined by boundary vegetation. The site is on a road junction, with Birmingham Road to the west and the A46 to the north. To the south is existing residential development, known as Hathaway Gardens, and to the east is agricultural land. In total the site comprises of 3.24ha (please see Site Location Plan enclosed at Appendix 3). 9.3. The site is immediately adjacent to the built-up edge of Stratford-upon-Avon and the area is characterised by existing residential development. Stratford-upon-Avon Parkway Railway Station and the Park & Ride is located to the west, also south of the A46. 9.4. To accompany this representation, a Vision Document has been prepared and is included at Appendix 1 to this representation. 9.5. This Vision Document, including the Illustrative Masterplan, demonstrates the deliverability of the Site and establishes an area capable of accommodating development without any adverse effects, for example in terms of flood risk. Sustainability Appraisal SA 9.6. This site is located in the general area identified as Broad Location: Stratford-upon-Avon Northeast which is the best performing Broad Location associated with Stratford-upon-Avon. This Site is shown as unconstrainted and it is clear that this site would form a logical extension and should form part of this location for growth. 9.7. The assessment of this Stratford-upon-Avon Northeast against the SA objectives is presented at Section B.26 of Appendix B. It is acknowledged that, at this stage, the assessment covers a wide area and the ratings will not be applicable to each part of the Broad Areas. Each SA Objective is considered with specific reference to the site below: 9.8. SA Objective 1 Climate Change: The site would deliver circa 90 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Stratford. 9.9. SA Objective 2 Flood Risk: The site is entirely within Flood Zone 1, land at lowest risk of flooding. There is a small amount of surface water flood risk in the corner adjacent to Bishopton Roundabout which could be addressed… 9.10. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: The site is not designated as or in close proximity of a Special Conservation Area (SAC), Site of Special Scientific Interest (SSSI), National Nature Reserve (NNR), ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space (LGS) or priority habitat. It is noted that the coincidence of the Broad Location with Welcombe Hills Local Nature Reserve (LNR) is identified as a potential negative impact however the site is well separated from the LNR by distance and intervening development. 9.11. SA Objective 4 Landscape: The site is characterised by its proximity to existing residential development and transport infrastructure, notable the A46 trunk road. It is well contained by the existing development and infrastructure and would not breach the established build lines associated with Stratford and therefore would need read as an intrusion on the wider landscape. 9.12. SA Objective 5 Cultural Heritage: The site is not located in proximity to any designated heritage assets or Conservation Areas. 9.13. SA Objective 6 Pollution: The site is located adjacent to the Stratford Air Quality Management Area (AQMA). It is also located adjacent to the A46. It should be noted that mitigation is achievable for air quality impacts, including for example additional tree planting, installation of electric vehicle charging points and increased use of public transport through sustainably located development, such as at this Site. It should also be noted that the Site is not within a Source Protection Zone. 9.14. Objective 7 Natural Resources: The site is shown on Natural England mapping as Grade 3 agricultural land. The Site would only result in a minor loss of agricultural land. The Site is not within a Mineral Safeguarding Area. 9.15. Objective 8 Waste: A development of circa 90 houses would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. 9.16. Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. 9.17. Objective 10 Health: The site benefits from frequent bus services on Birmingham Road which provide access to Stratford Town Centre. This provides sustainable access to Stratford Hospital and GP surgeries located in Stratford. It is noted that the closest A&E department is located at Warwick Hospital. The closest park to the site is Badgers Way Park, located across Birmingham Road to the south. There are various other local green spaces in the area and sustainable travel options to access leisure and recreation facilities in Stratford town centre. The site is not crossed by any public rights of way (PRoW), the closest PRoW is Footpath 334/SB1/1 which connects from Birmingham Road to the south of the site and continues north towards Park Wood. 9.18. Objective 11 Accessibility and 12 Education: The site benefits from existing bus stops on Birmingham Road and frequent local services to Stratford and Solihull. The site is also located in proximity to Stratford Parkway Train Station and Park & Ride facility. This is supported by the Stratford North West connectivity analysis which rates the Site as Grade B (green). There are also various local services and facilities within the local area, including two primary schools within a mile of the site and a secondary school within 1.5 miles of the site. 9.19. Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Stratford-upon-Avon. Summary 9.20. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.21. The Vision Document indicates how a scheme of circa 90 dwellings can be achieved having regard to the site constraints and opportunities. Feb 2023 | COT | P21-1652 32 9.22. The site benefits from a highly sustainable location on the edge of Stratford-upon-Avon and is well placed to meet the housing needs of Stratford and the surrounding area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.23. The Vision Document includes a detailed access plan demonstrating how access could be provided from Birmingham Road. This could include improvements to the existing footpath network on this stretch of road. 9.24. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.25. In view of the above, there are no known constraints which would prevent development of this site. Deliverability 9.26. Rainier have a land interest in the Site and are promoting the site for residential development. The Site has already been submitted as part of the Call for Sites exercise associated with the Scoping Consultation in 2021, and accompanying representations were also submitted. 9.27. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.28. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.29. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.30. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.