Issue and Options 2023

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Q-C7: 1 Caddick Land 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. Q-C8: Option C8b should be followed, where a policy is not included that goes beyond Building Regulations. 5.13 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. 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. 5.14 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. Q-C9.1: 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, as of November 2023. Therefore, Caddick Land 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. This will ensure the policy is clearly written and is deliverable, achieving sustainable development, opposed to creating a barrier to development. 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, and allowing developers to pay a financial offsetting payment.

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Q-C10.1: Option C10.1c should be followed, whereby none of the above options are suitable. Caddick Land is supportive of measures to tackle climate change, but clarity should be provided as to what is actually required through a Climate Change Risk Assessment. It is not clear at present and therefore a evidenced decision is not possible on the most appropriate option to address climate change, based on the information and wording available. As a result, the Councils should conduct further research to inform their evidence base, prior to deciding whether a Policy is required and to what extent.

Q-C11: Option C11a has the potential to be the most appropriate policy, however this is subject to its specific wording. At present, the existing policies concerning water management state the term ‘good’, however there is no definition of ‘good’ and the term remain s subjective, therefore unclear and has potential to be unachievable. Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire 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 properly judge what sort or level of Policy is required. Until the additional evidence is undertaken, it is not appropriate to comment on water management or flood risk. However, Caddick Land reiterates that as per validation requirements, all major applications require a Flood Risk Assessment to assess a site, and mitigate against any potential problems. 5.19 Furthermore, the wording within Issue C12 infers that the Part 2 work will be based upon the strategy, however the work undertaken should inform the strategy, therefore all work undertaken should underpin any proposed policy. 5.20 In addition, whilst the Level 1 Strategic Flood Risk Assessment states that it can be used to inform the Local Plan on the location of future development and the preparation of sustainable policies, there is not sufficient evidence to fully decipher this, and this report should only be considered as a factor towards the wider review of sites suitable for development. As per Paragraph 0077 (Reference ID: 7-007-20220825), Diagram 1 outlines that following the completion of a Level 1 Strategic Flood Risk Assessment, the authority then identify where development can be located in areas with a low risk of flooding and assess alterative development options using the Sustainability Appraisal, considering flood risk and other planning objectives. Following this exercise, the Council can then apply the Sequential Test to identify appropriate allocation sites and development, which can then require a Level 2 Strategic Flood Risk Assessment. As a result, a greater amount of work and evidence is required to inform the Local Plan, as the Council have not yet reviewed the availability of sites, to identify those in areas of low risk flooding and those no t. 5.21 In addition, the SFRA summarises that there are urban areas of Stratford upon Avon and Warwick that are at risk of fluvial and surface water flooding. As a result, the Councils need to take this into account when reviewing their available urban sites. This may require greater areas of Green Belt land to be released, if urban areas are at greater susceptibility to flooding. At present, two reports have been produced to cover Stratford and Warwick separately. In the future, it would be more useful and appropriate to look at South Warwickshire as an entity, with supporting joint evidence. In addition, Appendix D within both reports identifies Flood Alert and Flood Warning Areas, and it would be more appropriate to have accompanying maps of these areas to identify clearly those locations. At present, it is unclear.

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Q-D1.1: 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 t opic. Therefore, the principle of the topics are acceptable, however the detail associated with each topic needs to be considered and engaged upon further.

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Q-D2: Caddick Land 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. Q-D3: Caddick Land 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 decipher the minimum housing density and requires caveats to enable differen t 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. 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. 6.5 However, in the current evidence base, it is difficult to fully establish and understand the housing need in relation to house types8 without further sufficient evidence, therefore it is difficult to decipher a suitable housing density. 6.6 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. 6.7 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.

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Q-D4.1: Caddick Land agrees that this is an appropriate range of topics, however it is important that the topics achieve the overarching objective of promoting social interaction, as per paragraph 92 of the NPPF. However, the minimisation of conflict between user s, as per Paragraph 112 of the NPPF, should also be included within the range of topics. It should also be included and noted that the design of streets should be reflective of current national guidance, including the National Design Guide and National Model Design Code.