Issue and Options 2023

Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire. 3.24 As set out earlier in these representations, Rainier are concerned that the consultation document is too narrowly focused on the delivery of solely residential development, with insufficient consideration for how employment growth across South Warwickshire will be delivered; this concern is also reflected within the growth options presented above. 3.25 For example, Growth Option 3 is labelled ‘Economy’, however this Option is focussed on the delivery of homes ‘in close proximity to employment’; rather than seeking to direct employment and economic growth to the most sustainable and suitable locations, which are usually focussed close to existing motorway junctions and the wider strategic highways network. 3.26 As established within the NPPF (Paragraph 20), strategic policies should set out an overall strategy for the pattern, scale, and design quality of places, making sufficient provision for employment, housing, retail, leisure, and other commercial development. Rainier are concerned that the Plan does not currently consider each of these elements to be delivered alongside each other, and ultimately there has been too much focus in respect of housing. 3.27 It is therefore recommended that the growth options above are updated, to reflect how all development needs within South Warwickshire can be met, in accordance with an updated Vision for the Plan which recognises the importance of employment growth to support the overarching strategy for the Plan.

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Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 3.28 The HEDNA1, published in November 2022, represents the most up to date assessment of South Warwickshire’s employment land requirements, concluding an overall need for 248.1ha of employment land in Stratford-on-Avon District and 97.2ha in Warwick District over the period to 2050 2. 3.29 The largest proportion of this overall need is attributable to general industrial (including non-strategic B8) which accounts for 240.9ha and 81.4ha of the requirement respectively across each District. The employment land requirement for offices is much lower at 7.2ha in Stratford-on-Avon and 15.8ha in Warwick District 3. 3.30 These requirements exclude land for strategic B8 warehousing, the need for which has been assessed separately in the HEDNA at a sub-regional level, equating to a requirement for some 709ha of land across Coventry and Warwickshire over the period to 2050 4. 3.31 The HEDNA assesses quantitative needs using a variety of methods consistent with PPG, concluding that a labour demand approach based on baseline forecasts produced by Cambridge Econometrics (CE) is the most representative scenario for assessing office needs. In view of the limitations of this approach for assessing industrial land needs, projections based on an annualised average of past completions over the period from 2011/12 to 2019/20 are used to establish employment land requirements for local industrial and non-strategic warehousing uses. 3.32 Rainier broadly support the approach to assessing needs adopted in the HEDNA but has concerns regarding the employment land requirements established for South Warwickshire, in particular Warwick District, where it is felt the Authorities should be planning for a higher overall requirement. 3.33 Furthermore, whilst the methods used are broadly consistent with PPG, as a subregional study the HEDNA does not robustly consider trends at a sub-area level or the balance between supply and demand which will be key factors in influencing the land requirement and locations where employment growth should be directed. 3.34 These omissions, which represent important steps in forming a complete view of future employment needs for the emerging Local Plan in line with PPG, are explored in more detail in response to Q-E1.2 below. Q-E1.2: If your answer to E-1.1 is No, what would be a more appropriate approach to calculating future needs for this Local Plan? 3.35 Rainier support the use of a labour demand approach for assessing future office needs in South Warwickshire but would highlight – as recognised at para 9.7 of the HEDNA – that these take account of expected economic performance moving forward relative to past trends 5. 3.36 It is evident that potential above trend job creation in sectors likely to occupy office and R&D space (for example by interventions or targeted investments at known Major Investment Sites identified under Issue E7 and in the Draft Economic Strategy for South Warwickshire) is unlikely to be reflected with no adjustments seemingly made to account for this. In a departure from best practice, the baseline CE forecast has also not been compared to another forecast to test its representativeness. Such an exercise might indicate different rates of growth from which a preferred forecast and scenario could be derived which best reflects the economic opportunities presented in South Warwickshire and growth potential of high value sectors being targeted by the authorities. 3.37 Rainier would also highlight that unlike the other Coventry and Warwickshire authorities where a 2-year margin for flexibility has been added to the land requirement, no buffer has been added to the office requirements for Stratford-on- Avon or Warwick, this seemingly ‘due to data issues’. The HEDNA therefore recommends the authorities to ‘treat figures a minima, but this should be informed by detailed consideration of the office stock and trends in losses’ 6. 3.38 The above limitations are perhaps reflective of complexities of undertaking this exercise across multiple local authorities, but nonetheless do cast a degree doubt over whether the office land requirement in Table 8 of the Issue and Options Consultation document is ambitious enough and representative of Warwick District’s growth potential, noting the ambitions to growth the economy in the draft Economic Strategy as well as Warwick/Leamington’s cited status as one of the main office markets in Coventry and Warwickshire 7. Indeed, owing to this status Warwick/Leamington is a location where it is expected that future office supply will be focussed 8. 3.39 In terms of assessed industrial land requirements, Rainier also broadly support the HEDNA’s use of past completion trends but would note that projected requirements for Warwick are comparatively low compared to the other Coventry and Warwickshire authorities, including Stratford-on-Avon in the South Warwickshire context. The HEDNA rightly identifies that this distribution has been influenced by land availability, however in the context of recent demand, the cited growth potential of low carbon transport cluster and the areas role in the heart of the Midland’s engine, Rainer consider that the Authorities should be planning for a higher requirement, particularly in Warwick District. 3.40 It is of note the HEDNA’s conclusion that circa 81.4ha of employment land would be needed between 2021 and 2050 is currently based on the recorded take-up between 2011/12 and 2019/20. This has then been multiplied over the plan period to 2050, before a margin for flexibility, equivalent to a further five years, is then added. Whilst a detailed breakdown of annual take up is not presented in the HEDNA, interrogation of Warwick District’s latest Annual Monitoring Report (AMR)9 shows a comparatively low level of employment land being delivered between 2011/12 and 2015/16, averaging 2.2ha per annum. In more recent years this has increased and between 2016/17 and 2020/21 averaged 3.9ha per annum over 5 years. Evidently, if employment land in Warwick continues to be taken up at the rate seen over the last five years, then some 132.6ha of industrial land could be needed in the District over the plan period when consistently applying a five year buffer like the HEDNA. 3.41 It is Rainier’s view that the quantitative requirements presented in the HEDNA should be treated as a minimum and consideration given to a higher requirement for Warwick District to avoid unduly constraining the market. Other limitations 3.42 As outlined above, the HEDNA does not consider the balance between supply and demand in line with PPG, resulting in gaps in the evidence needed to form a complete view of future employment needs and policies in the emerging Local Plan. This is important in the context of the draft Economic Strategy for South Warwickshire, which seeks to ensure an adequate supply of employment land and affordable employment premises in the right locations through the SWLP 10. These objectives having seemingly been set in response to identified opportunities for significant growth and investment but also the perceived threat that the existing supply of employment land and space “may not be suitable for business needs” 11. 3.43 To address these gaps it is recommended, in line with PPG for assessing economic needs, that the analysis in the HEDNA is supplemented with a sub-area analysis of market demand 12 to gain a deeper understanding of whether there are specific requirements in the local market which affect the types of land or premises needed 13. 3.44 The HEDNA already recognises the potential greater role of South Warwickshire in accommodating strategic B8 warehousing, including along key corridors along the M40 and A4614, however further consideration of location and premises requirements across other sectors being targeted by the Authorities is also recommended to help inform potential locations for employment growth. Such an analysis is also important for assessing the balance between and demand to identify whether there is a mismatch between quantitative and qualitative supply of and demand for employment sites. This will enable an understanding of which market segments are over-supplied to be derived and those which are undersupplied 15 1 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022 2 Stratford-on-Avon District Council & Warwick District Council (2023) Stage 2: Issues and Options Consultation – January 2023, Table 8. 3 Ibid. 4 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, Table 10.19 5 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 9.7 6 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 11.15 7 Ibid. para 3.9 8 Ibid, para 3.41 9 Warwick District Council (2021) Annual Monitoring Report 2020/21 10 Ibid. p22 11 Ibid. p19 12 Paragraph: 026 Reference ID: 2a-026-20190220 13 Paragraph: 032 Reference ID: 2a-032-20190722 14 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 11.25 15 Paragraph: 029 Reference ID: 2a-02920190220

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Q-E3: Please select the option which is most appropriate for South Warwickshire 3.45 Rainier is supportive of the emerging Local Plan’s objectives of diversifying the economy to help prevent out-commuting and retain residents within South Warwickshire. A policy which expands on SDC’s current existing policy (Option E3a) setting the principles for economic activity, how much employment provision needs to be provided across each district and where this activity will be focussed (i.e. employment growth locations) is considered to be the most appropriate approach for South Warwickshire in the emerging Local Plan. 3.46 Importantly, the plan should ensure that there is sufficient and appropriate employment land provision available to meet the existing and future needs across all employment sectors in locations where industry want to invest. 3.47 Whilst being informed by assessed needs by sector, there is a risk that having separate policies for individual sectors could be viewed as a limit on the amount of land and floorspace to be delivered, in turn acting as a constraint to growth and the Authorities’ ability to respond flexibly to changing market conditions and unforeseen needs over the Plan period. Q-E6: Please select the option which is most appropriate for South Warwickshire 3.48 Rainer would support the inclusion of a policy which protects South Warwickshire’s economic assets on the basis that any such policy is also accompanied by policies which ensure that there is sufficient and appropriate employment land provision available to meet the existing and future needs across all employment sectors in locations where industry want to invest. Q-E7.1 Please select the option which is most appropriate for South Warwickshire 3.49 Rainier support the inclusion of a policy directing employment to the Core Opportunity Area as a means of encouraging inward investment in the most accessible parts of South Warwickshire. South Warwickshire’s strategic gateway location on the M40 and accessibility to London, the Chiltern Mainline and Birmingham, has already made the area an attractive location to invest and grow a business and capitalising on this will be important for achieving a number of objectives set out within the draft Economic Strategy for South Warwickshire. 3.50 South Warwickshire also exhibits a concentration of skilled residents with approximately 49% of the population have attained high level NVQ4+ qualifications 16. Currently, however, workplace earnings fall below resident-based earning indicating that the areas higher skilled worker are commuting outside of the area for work. Placing new employment development close to labour and consumer markets in the Core Opportunity Area would evidently help to reduce the need to travel and encourage more sustainable patterns growth. 3.51 For these reasons it is considered that Warwick, as one of the main urban areas, should remain focal point for future employment growth in the Core Opportunity area. This reflects wider economic objectives and the potential to attract and accommodate investment in higher value sectors offering employment commensurate to the skills of the workforce and high proportion (58%) of residents living in Warwick and Leamington who already working in the top 3 occupational groups (Managers, directors and senior officials; Professional occupations, Associate Professional & Technical occupations) 17. 3.52 Rainier consider that opportunities to build on existing clusters of employment to the south west of Warwick, an area identified in earlier consultations as a potential ‘Growth Hub’ location, should continue to be explored. This is a highly sustainable and proven employment location with potential to accommodate a mix of employment close to labour supply in Warwick, but also other parts of South Warwickshire owing to the accessibility provided by the A46 and M40. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 3.53 It is of note that the Draft Economic Strategy has set a short-term vision that by “by 2028, Stratford-on-Avon and Warwick District Councils will have contributed to creating a larger, stronger, greener and more inclusive economy” 18. Rainier consider that all potential locations for growth within the Core Opportunity Area need to be considered to achieve this vision. 3.54 Paragraph 8 of the Framework requires employment land of the right type in the right locations to be provided to support growth and innovation. When assessing economic land availability PPG also highlights that employment site suitability, availability and achievability should be guided by market signals, including consideration of the appropriateness and likely market attractiveness for the type of development proposed 19. 3.55 As confirmed in PPG for assessing economic need Authorities should also have regard to trends at a sub-area level and the distinct property market that exist not just between but also within local authority areas 20. 3.56 Analysis of office and industrial property transactions over the past five years reveals demand for employment land and floorspace in locations outside of the major investment sites. 3.57 The HEDNA also reports strong demand relative to supply of both office and industrial floorspace across South Warwickshire. In the industrial market, for example, vacancy rates point to a continued need for the delivery of new industrial floorspace 22, with limited industrial supply remaining in Warwick/Leamington. The principal availability was reported as being the remaining plots at Spa Park and Tournament Fields 23, although in the case of the latter it is understood that a Reserved Matters application 24 for the final vacant development plot was approved in November 2022, adding further weight to the attractiveness and suitability of south west Warwick as a location where the need for additional employment land should be met. 3.58 Only focussing economic growth at the Major Investment Sites would fail to recognise these market dynamics, potential unmet business needs and the suitability and deliverability of other sustainable locations for employment growth. Consideration should therefore be given to other employment growth locations without prematurely discounting sites because they are not already allocated or located at Major Investment Sites. QE8.1: Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP 3.59 Rainier are supportive of this approach in principle, subject to the authorities also undertaking a up to assessment of the ongoing suitability and deliverability of the identified allocations and allocating additional land to meet any identified shortfall. 3.60 Rainier would highlight the following in respect of the existing allocations being relied upon in Warwick District: • Site allocation E1 ‘Land at Thickthorn, Kenilworth’ comprises 8ha of employment land which was the subject of a planning application approved in outline in December 202125. The permission permits the intended B2 and Class E floorspace and therefore has a reasonable prospect of being delivered for its intended employment use. 3.61 It is of note that Warwick District Local Plan 2011-2029 also allocates, at Policy DS16, a Sub-Regional Employment site on the southern edge of Coventry. This site comprises 235ha of which 6.5ha has been allocated to meet employment land in Warwick with the remaining 228.5ha being developed to meet the employment needs of the wider sub-region of Coventry and Warwickshire. In responding primarily to sub-regional needs, the site cannot be relied upon in the emerging SWLP to meet the locally assessed needs. 3.62 The implied employment land supply from existing allocations in Warwick (26.2ha) when added to land with permission (12.71ha) and other land identified as available (23.93ha) reported in the latest Annual Monitoring Report26 (AMR) equates to 62.84ha. Whilst this position is likely to have evolved since the 2020/21 AMR was published, the available evidence suggests that, even where existing allocation are carried over, they will not be sufficient to meet the identified need for 97.2ha in Warwick District. In total some 34.36ha of additional employment land needs to be allocated to meet this quantitative shortfall. 3.63 Employment land supply is Stratford-on-Avon will also be insufficient, with Table 38 of the Council’s latest AMR27 confirming a remaining employment land supply of 179.1ha, comprising 45.7ha with outline permission and 133.4ha from allocated sites without permission. Again, comparing this to the assessed need for 248.1ha would again result in a shortfall of land, with at least 69ha of additional land being required to 2050. This would increase to 169ha where land safeguards for the expansion of JLR is excluded from the available supply. 3.64 It follows that there will be a shortfall of land across South Warwickshire to 2050. Additional allocations will therefore be needed to ensure that sufficient employment land of a suitable quality is available over the plan period to meet identified needs. It is Rainier’s strong view that consideration should be given to new employment opportunities in south west Warwick to meet this need. 16 ONS via Nomis (2021) Annual Population Survey (T19) 17 ONS via Nomis (2021) 2021 Census (TS063 – Occupation) 18 Stratford-on-Avon District Council and Warwick District Council (2023) An Economic Development Strategy for Stratford-on-Avon and Warwick Districts to 2028 – Draft for Consultation (February 2023), p20 19 Paragraph: 018 Reference ID: 3-018-20190722 20 Paragraph: 028 Reference ID: 2a-028-20190220 21 CoStar and Turley Analysis, 2022 22 Iceni Project Limited (2022) Coventry and Warwickshire Housing and Economic Development Needs Assessment, Final Report, November 2022, para 3.64 23 Ibid. para 3.82 24 Application reference W22/1017 25 Application Ref W/20/2020 26 Warwick District Council (2021) Annual Monitoring Report 2020/21 27 Stratford-on-Avon District Council (2022) Annual Monitoring Report 2021/22

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2. Chapter 3: Vision and Strategic Objectives – South Warwickshire in 2050 Issue Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why 2.1. As set out in response to the Scoping and Call for Sites consultation, Rainier supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Rainier supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered, do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle, and it is acknowledged that national policy is pursuing ‘beauty’ in planning however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported, and it is recognised that the SA is at an early stage however the SA only considers a limited number of settlements and excludes some settlements that should be considered as sustainable locations for growth, such as Welford-on-Avon. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives. Further comments are made below and in following sections regarding the SA with specific reference to Welford-on-Avon and the Site [Land North of Milcote Road].

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