Issue and Options 2023

1 Introduction 1.1. Context Gladman welcome the opportunity to comment on the South Warwickshire Local Plan Issues and Options consultation and request to be updated on future consultations and the progress of the Local Plan. Gladman Developments Ltd specialise in the promotion of strategic land for residential development and associated community infrastructure and have considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public. Gladman has been involved throughout the plan preparation process of the South Warwickshire Local Plan and previously submitted representations and a Portfolio of Sites to the Scoping Consultation undertaken in June 2021. Gladman Developments have multiple land interests in South Warwickshire within the Stratford-on- Avon District. These include land north of Evesham Road, Shottery; land off Shoulderway Lane, Shipston-on-Stour; land off Southam Road, Long Itchington; land south of Loxley Road, Stratford-on-Avon; and Temple End, Harbury. Gladman are also promoting land at Wellesbourne Airfield, which is addressed in a separate accompanying submission. Gladman looks forward to engaging further with the Council as the plan preparation process progresses. The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is: • Positively Prepared – The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. • Justified – the plan should be an appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base. • Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and • Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework. The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan preparation. As demonstrated through the outcome of the 2020 Sevenoaks District Council Local Plan examination and subsequent Judicial Review, if a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend nonadoption of the Plan. Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the Planning Practice Guidance (PPG) it is clear that it is intended to produce effective policies on cross-boundary strategic matters. In this regard, the Councils must be able to demonstrate that they have engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross-boundary strategic issues, and the requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question of effective cooperation. The revised Framework introduced a number of significant changes to how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SoCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. Planning guidance sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SoCG), throughout the plan making process1 . The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for 1 PPG Reference ID: 61-001-20180913 strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with such as unmet housing needs. The South Warwickshire Local Plan will need to consider how it will deal with the issue of unmet needs arising from Coventry, and Greater Birmingham and the Black Country. In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives. The Councils should ensure that the results of the SA process clearly justify their policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the South Warwickshire Local Plan’s decision-making and scoring should be robust, justified, and transparent. The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for housing and other development can be produced. Requiring plans to set out a vision and a framework for future development and seek to address the strategic priorities for the area. Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered ‘sound’. The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social, and environmental priorities and to help shape the development of local communities for future generations. In particular, Paragraph 16 of the Framework (2021) states that Plans should: “a) Be prepared with the objective of contributing to the achievement of sustainable development; b) Be prepared positively, in a way that is aspirational but deliverable; c) Be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees; d) Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals; e) Be accessible through the use of digital tools to assist public involvement and policy presentation; and f) Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).” To support the Government’s continued objective of significantly boosting the supply of homes, it is important that the South Warwickshire Local Plan provides a sufficient amount and variety of land that can be brought forward, without delay, to meet housing needs. In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs assessment defined using the standard method, unless there are exceptional circumstances to justify an alternative approach. Once the minimum number of homes that are required is identified, the strategic planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 67 sets out specific guidance that local planning authorities should consider when identifying and meeting their housing needs. Annex 2 of the Framework (2021) defines the terms “deliverable” and “developable”. Once a local planning authority has identified its housing needs, these needs should be met as a minimum, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so. This includes considering the application of policies such as those relating to Green Belt and giving consideration as to whether or not these provide a strong reason for restricting the overall scale, type and distribution of development (paragraph 11b)i.). Where it is found that full delivery of housing needs cannot be achieved (owing to conflict with specific policies of the NPPF), Local Authorities are required to engage with their neighbours to ensure that identified housing needs can be met in full (see Paragraph 35 of the NPPF 2021). The July 2021 revision to the NPPF provides greater focus on the environment, design quality and place-making alongside providing additional guidance in relation to flooding setting out a Flood Risk Vulnerability Classification at Annex 3, the importance of Tree-lined streets and amendments to Article 4 directions. Additionally, Local Plans which have not yet progressed to Regulation 19 stage should ensure that where strategic developments such as new settlements or significant extensions are required, they are set within a vision that looks ahead at least 30 years (See paragraph 22). The amendments coincide with the publication of the National Design Guide and National Model Design Code, a toolkit which helps local communities to shape local design needs and provide guidance for creating environmentally responsive, sustainable, and distinctive places with a consistent and high-quality standard of design. The Planning Practice Guidance (PPG) was first published by the Government to provide clarity on how specific elements of the NPPF should be interpreted. The PPG has been updated to reflect the changes introduced by the revised NPPF to national planning policy. The most significant changes to the PPG relate to defining housing need, housing supply and housing delivery performance. In December 2022, Secretary of State for Levelling Up, Housing and Communities, Michael Gove unveiled a raft of proposed planning reforms as part of the Levelling Up and Regeneration Bill. A consultation on proposed reforms to the NPPF, views on an approach to preparing National Development Management Policies alongside developing policies to support levelling up, is open between 22 December 2022 and 02 March 2023. The proposals include revisions to how housing figures should be derived, address issues in the operation of housing delivery and supply tests and several other elements. However, the Government has reiterated its commitment to delivering 300,000 homes a year, with the changes focussed on increasing housing delivery. The consultation document highlights that reforms to the plan-making system are intended to be introduced in late 2024 and the Government have highlighted that plan-makers will have until 30 June 2025 to submit Local Plans for independent examination under the existing legal framework. The South Warwickshire Local Plan should seek to continue the development and preparation of the emerging Local Plan in line with the proposed transitional arrangements. However, given the proposed changes are subject to consultation and potential further revisions, the Councils should be aware of the consultation outcome and possible changes to the NPPF in Spring 2023. 4 Issues and Options Consultation 4.1. Background The Stratford-on-Avon Core Strategy was formally adopted in July 2016 and the Warwick Local Plan was adopted in September 2017. These documents set out the long-term strategic vision, objectives and planning policies to guide development over their respective plan periods. Despite no formal merger of the two Councils, Stratford-on-Avon and Warwick District Councils are working together to produce a new South Warwickshire Local Plan to cover their combined geographic area. Stratford-on-Avon and Warwick District Councils are currently undertaking an Issues and Options Consultation and Call for Sites, for a period of 8 weeks between Monday 9 January - Monday 6 March 2023. The Issues and Options consultation provides a second opportunity for residents and stakeholders to have their say on the emerging Local Plan and will include different options for selecting preferences to several planning policy issues and the policy options to address them. It also sets out broad options for consideration on where to best accommodate new development in the future. Gladman support the Council’s timescales relating to the new Local Plan as set out in the Local Development Scheme published in December 2022. The sections that follow below include specific comments from Gladman covering a range of the topics and questions that have been posed.

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Gladman support the vision which seeks to boost and diversify the local economy by meeting South Warwickshire development needs by ensuring the provision of appropriate infrastructure, in suitable locations, at the right time. Gladman consider that as the spatial strategy is yet to be determined, the Councils should be cautious of an extended plan period to 2050. The NPPF requires that plans look ahead a minimum of fifteen years from adoption and that Local Plans are reviewed every five years, therefore there are concerns that this extended approach leaves the Councils with few alternatives to respond to changing circumstances. If the Councils opt to continue with the extended plan period when the preferred spatial strategy is chosen, it is recommended that policies are suitably worded, and that a review mechanism is included in the Local Plan to ensure that the Plan can respond to any change in circumstances that may occur over the plan period.

2.2. Sustainability Appraisal In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives. The Councils should ensure that the results of the SA process clearly justify their policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the South Warwickshire Local Plan’s decision-making and scoring should be robust, justified, and transparent

Gladman support the delivery of infrastructure on through development but do not consider it appropriate to determine the exact mechanism prior to the spatial strategy being determined. A dispersed spatial strategy may not require site specific infrastructure delivery to be determined at this stage, whereas a strategy that focuses on large scale sites will need to ensure that the necessary infrastructure can be delivered on side and remain viable. Regardless of the option chosen to proceed with, any policy should be suitably worded with clear trigger points for substantial infrastructure on large sites and a suitable degree of flexibility to ensure continued viability. All infrastructure requirements should be clearly evidenced in terms of need and viability.

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Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, growth of existing settlements should be part of the overall strategy. This will allow development to occur in sustainable locations and facilitate the continued viability and vitality of settlements. Growth at existing settlements typically results in a dispersed spatial strategy which allocates sites in a range of locations and sizes, increasing competition and delivery. Whilst not opposed to new settlements and large strategic allocations, these typically take longer to deliver owing to their complexity and therefore should not be considered in isolation. As shown in the previously submitted Portfolio of Sites, Gladman are promoting a suite of sustainable sites in suitable locations at existing settlements.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire with regard to brownfield development. Gladman consider that Option S3.2a is the most suitable approach to brownfield development. Gladman support the delivery of brownfield development, but the Councils should be mindful that these sites are not without complication. They can typically incur high development costs and therefore are not always viable. This can in turn impact affordable housing provision and the provision of other community benefits that greenfield sites can typically deliver without significant issue. Q-S5.2: Do you think new settlements should be part of the overall strategy? As previously stated, Gladman are not against the allocation of new settlements, however they should not be used as the sole method of delivery due to the known complications and delays sites of this scale can incur. Rather, a new settlement should be considered as part of a dispersed spatial strategy that allocates a range of sites. Q-S9: Please select the option which is most suitable for South Warwickshire with regard to settlement boundaries. Gladman consider it would be premature to define the settlement boundaries without considering allocations for residential development in settlements, adjacent to the existing boundaries. Irrespective of when the settlement boundaries are considered, be it in Part 1 or Part 2 of the plan, the policy should contain a mechanism to ensure the development beyond the settlement boundary can come forward should other allocations not deliver as expected and the supply drop. This will allow the Plan to respond effectively to changes in circumstance throughout the plan period and ensure that much needed market and affordable housing can be provided. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire. Fundamentally, Gladman consider that the spatial strategy needs to be balanced and supported by a clear settlement hierarchy. A balanced approach will increase choice and competition for housebuilders and buyers and increase the likelihood of the housing requirement being delivered within the plan period. It also allows a range of settlements to benefit from the benefits of development, such as affordable housing, community benefits and S106 contributions.

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Q-S5.3/ Q-S5.4: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? If not, what approach would you take? Gladman support the decision to ensure that strategic growth is directed to wellconnected places and/or locations that have the potential to enhance interconnectivity between places. Gladman support the overarching rationale to ensure that strategic growth is directed towards the most connected locations by active and sustainable travel methods, especially where growth is peripheral to the existing settlement. The Councils should also be mindful that there are increasing modes of climate friendly travel options, beyond the traditional train and bus services. The rise of electric vehicles and mobility hubs mean that sustainable travel options do not need to be limited to public transport and can be delivered as part of development schemes to boost the overall sustainability of an area.

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Q-H1.1: The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire whilst the new trend-based projections point to a need for 4,906 dwellings annually across the sub-region. This is lower than the 5,554 per annum Standard Method figure due to the recognised issues with population data which have informed previous projections for Coventry. Based on the trend based approach, Stratford would plan for 868 dwellings per annum (against a LHN of 564 dwellings per annum) and Warwick would plan for 811 dwellings per annum (against a LHN of 675 dwellings per annum). The overall housing figure would result in 1,679 dwellings per annum being provided across South Warwickshire. Gladman support the choice of the Councils to consider a trend-based projection housing need and accommodate a proportion of unmet need from Greater Birmingham and the Black Country, and Coventry alongside the 2014-based projection. This approach would also support the delivery of much needed affordable housing in South Warwickshire. Stratford-upon-Avon has an affordable housing need of 129 dwellings per annum and Warwick a need of 258 dwellings per annum. The higher trend based requirement for the individual Councils presents a greater chance for this affordable housing need to be met. Q-H3: Please select all options which are appropriate for South Warwickshire with minimum space standards. Gladman support Option H3b as it is based on locally derived evidence. Any policy drafted that requires all new dwellings to be built to the nationally described space standards (NDSS) should note that the PPG is clear that “where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies.” Gladman also consider Option H3c a suitable option. This recognises that Building Regulations M4(2) and M4(3) are optional, and the PPG provides additional guidance on the use of these optional standards. Gladman encourage the Council to ensure that this policy is robust in its justification by accounting for the factors within the PPG. Gladman would welcome the flexibility in any requirement where viability is an issue but note that the baseline requirement should be set so that this is not necessary. Q-H5: Please select all options which are appropriate for South Warwickshire with regard to self-build and custom housing. Gladman consider that Option H5b presents the most suitable approach to custom and self-build housing. However, Gladman recommend that the policy wording includes a mechanism for the plots to be delivered as traditional market housing should there be no interest in the plots following 12 months of marketing.