Issue and Options 2023

selected

selected

selected

selected

Infrastructure requirements should be set out as fully as possible in the Part 1 Plan. The success of the Plan will depend in no small part on its ability to enable strategic growth, and in terms of the employment and housing requirements it seeks to achieve. If those aspirations are not to be frustrated then certainty is required in terms of the infrastructure needed to support it, and the relationship between that and the infrastructure that might be required later to support non-strategic / Part 2 development. Clarity is required at the outset so that strategic development can be brought forward with confidence and in an informed manner, whilst also ensuring that later non-strategic development can be delivered seamlessly and without being over or under burdened by infrastructure requirements. In circumstances where a zoned approach to CIL is possible in a single levy the benefit of having separate levies is perhaps marginal. However, it would more easily allow for differences in local conditions, which vary greatly within and between the two Districts, to be reflected in the approach to charging, and for the approach to charging to adapt more swiftly as circumstances change.

selected

selected

selected

selected

selected

The Issues and Options Consultation does not offer a specific opportunity to comment on issues around brownfield land. However, the Urban Capacity Study speaks to this issue and is considered in the section of the Issues and Options relating to the use of brownfield land and so these comments (which relate to brownfield development rather than the Urban Capacity Study per se) are presented here. The Issues and Options should promote a strategy which encourages the development of brownfield land. However, it is important that the focus is not too narrowly placed on brownfield sites. One of the most significant opportunities presented by the joint approach between the two Authorities is the ability to realise the potential offered by the M40 as a strategic route bisecting the Plan area and linking Birmingham and London. This has been under utilised to date but should now be embraced as an asset enabling growth with strong economic and social credentials that can also be carried out in an environmentally sensitive manner. The character of the M40 corridor is such that this will inevitably require greenfield development but that should be supported as part of a balanced approach to sustainable growth alongside making the most of brownfield opportunities. One such opportunity to realise the potential of the M40 corridor is land north west of Junction 15 which was promoted through the Call for Sites (response form and site location drawing reference 6484-16 were submitted). As indicated on the interactive map it was given the reference number 44 by the Councils and extends to about 60ha. It is extremely well suited to meeting the strategic industrial and logistics requirement in this part of the Plan area. On a related matter, the Issues and Options Consultation similarly does not offer a specific opportunity to comment on issues connected with the Green Belt. This is understandable in circumstances where the technical work around Green Belt review has not yet been undertaken, and so the Issues and Options are blind to this matter. The Issues and Options give a clear indication that such work will be undertaken, and this is essential. It is of particular relevance to the opportunity offered for development in the M40 corridor, which passes through the Green Belt. The Exceptional Circumstances required to remove land from the Green Belt are capable of being demonstrated by the need to meet development requirements, and the requirement for large scale industrial and logistics development in locations well related to the M40 and its junctions invites careful consideration of where such changes to the Green Belt might best be made. It is considered that the technical work around considering Green Belt release should be pursued as a priority, with the opportunity provided first for consultation on its scope and method, and later for comment on its findings.

Inappropriate strategy

Inappropriate strategy

Appropriate strategy

Appropriate strategy

Inappropriate strategy

The Spatial Growth Options are illustrated indicatively on the accompanying diagrams, and it is clear the symbols for growth are not to be understood as reflecting any decisions around the precise distribution of development. It will be important when more detailed site selection takes place to have careful regard to pursuing the selected Growth Option fully and effectively and optimising opportunities. One example in this regard is the provision of strategic industrial and logistics development along the M40 corridor where there are more extensive opportunities for growth than shown schematically on the Option diagrams. One such opportunity in this regard which should be supported is land north west of Junction 15 which was promoted through the Call for Sites (response form and site location drawing reference 6484-16 were submitted). As indicated on the interactive map it was given the reference number 44 by the Councils and extends to about 60ha. It is extremely well suited to meeting the strategic industrial and logistics requirement in this part of the Plan area.

No

The HEDNA adopts an approach which triangulates different forecasting techniques. This immediately gives rise to a note of caution. Each forecasting technique is based on a particular rationale, with a logical basis for how results are to be generated. Moving to some position between techniques means that the outcome does not reflect any particular rationale or have a robust methodological integrity. The HEDNA includes assumptions which are not justified. For example, reference is made (paragraph 9.32) to sensitivity modelling with a 30% reduction in office needs to reflect home working. There is of course evidence of increased demand for home working reflected in a reduced requirement for office space, but the selection of 30% is not explained. It might be informed by data of the kind presented in Figure 9.1, but that would rely on a comparison between rates of working from home pre-pandemic (which would already be “baked in” to floorspace requirements) and those experienced and expected post pandemic. That exercise appears not to have been completed; it is certainly not reported. Equally, the use of an arbitrary division between non-strategic and strategic provision at 9,000 sq m is not justified in the report. This figure has been used in other settings and is referred to in the HEDNA as a “recognised definition” but its continued use without a clear explanation of why this value is selected and the implications of segmenting the market in this way in the analysis is inappropriate. At the very least it implies a division in the market that is not reflected in the real world, and that should be acknowledged or there is a risk of HEDNA results being misapplied when they are translated into policy and allocations. The reliance placed on past trends of floorspace and completions growth is flawed. Past growth does not reflect future need – it reflects what a planning constrained market was able to deliver in the past. Relying on it will act to perpetuate past failures fully to meet the requirement for employment land. Moreover, whilst some flexibility (a 5 year margin) is allowed for in calculating strategic warehousing need this is to support a choice of sites and allow for unforeseen delays, not to make up for past under delivery. An allowance must be included to make good pent up, unsatisfied, demand. Such pent up or “suppressed” demand that might have accrued over an extended period should be fully accounted for in any analysis of the requirement for employment land that is to be relied on in the emerging Plan. This should include land for industrial as well as logistics activity. It is often the case that employment land supply fails to keep up with demand, and economic growth, investment and job creation that would have taken place were this not the case is frustrated, delayed or lost. As such, there are real-world consequences in failing to grapple with the point. Where a shortfall arises and accrues it should be made good through planned for provision. Pent up demand may be accounted for in conventional studies by making a nominal allowance for flexibility in the stated requirement (although that does not appear to be the case here) and expressing that requirement as a minimum. However, such an approach does not properly, directly or accurately engage with and measure the issue. That “flexibility” or margin is additionally included to make an allowance for other considerations such as delays in delivery, or a buffer to account for uncertainties in forecasting. However, the extent to which the flexibility allowance in the HEDNA accounts sufficiently and accurately for these multiple purposes is not known, and it appears to make no attempt to account for suppressed demand. The uncertainty in this regard should be reduced by assessing properly suppressed demand and accounting for it in policy decisions in the emerging Plan. This issue was explored in the January 2022 publication by the British Property Federation (BPF) of “Levelling Up – The Logic of Logistics”, a report considering the benefits of the industrial and logistics sector. The BPF Report comments on the modern-day growth drivers which are often not properly taken into account in estimating future demand, and also the extent to which future requirements are underestimated because the sector has been supply constrained for the majority of the last decade. To understand and address this imbalance Savills and St Modwen have developed a new methodology built upon the principle of “suppressed demand” that accounts for demand that has been lost due to supply shortages. The calculation of suppressed demand can then be added as an uplift to projections to give a more accurate picture of likely demand into the future rather than relying on assumed allowances around flexibility. The methodology is NPPG-compliant. It builds on past trends but with an adjustment for historic supply shortages (evident for example in particularly low vacancy rates) and the subsequent loss in take-up. This suppressed demand is added to the historic demand trend, and a further adjustment made for e-commerce growth. A calculation might first be made at FEMA level, and then apportioned to constituent districts to arrive at an estimate of the total industrial and logistics requirement for the area or conducted directly in relation to a specific authority. The amount of land to plan for should have regard to this requirement but will also depend on factors such as developable land capacity, qualitative considerations, and cooperation discussions between authorities. Such an exercise needs to be completed for South Warwickshire. The results from the HEDNA do not accommodate this issue and cannot be relied upon. Notwithstanding these shortcomings, the commentary in the HEDNA about the greater potential for South Warwickshire to accommodate strategic B8 growth, including in the M40 corridor, is supported. Expanding the distribution of such development in this manner, rather than solely replicating past patterns, is appropriate.

selected

selected

selected

selected