Issue and Options 2023
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New searchWilliam Davis consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and William Davis consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Furthermore, it is stated that unmet need ‘could’ be met, which should be revised to state that unmet needs ‘will’ be met where appropriate and agreed. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
General Observations 2.2. Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stratford-on-Avon District Council and Warwick District Council up to 2050. Paragraph 22 of the National Planning Policy Framework (NPPF) requires that all strategic policies should have a minimum timeframe of 15 years from point of adoption. While the SWLP is compliant with Paragraph 22 there is concern that a plan period to 2050 may be too ambitious in so far as it may be difficult for the plan to adapt to change. A further concern is that in establishing a 25-year plan period, the SWLP will make decisions that are so long term that it could compromise meeting the development needs of the area. By way of example, the SWLP could allocate a site which would genuinely take 20 years to deliver as a key part of its development strategy and given the magnitude of such sites could lead to smaller sites, in deliverable locations, not coming forward to meet housing needs in the intervening period. 2.3. Section 1.4 of the Consultation Document confirms that it remains the Council’s intention to prepare a two-part plan. The Respondent’s main concern regarding a two-tier system is the inevitable delay in plan-making that will occur as a result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans, there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect updated evidence needs. This is a particular concern given the projected end date of the plan being some 25 years hence. 2.4. The suggested timetable for the SWLP’s preparation is also considered to be highly ambitious. Given that most Local Plans take more than a year to be Examined by the Secretary of State it is considered very unlikely that Part 1 will be adopted before 2027 and potentially beyond if there is slippage between the public consultation stages indicated in Figure 2 (Page 16) of the Consultation Document. Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2: If no, please indicate why: 2.6. The Respondent is in general agreement with the vision and strategic objectives set out in the Consultation Document but considers that the delivery of market and affordable housing to meet housing needs, including unmet need arising from neighbouring authorities, should be given greater emphasis in the Council’s Vision for the Local Plan (V1). 2.7. The respondent would also suggest the following amendment: “The vision is to meet South Warwickshire’s sustainable development needs to 2050, including new market and affordable homes, while responding to the climate emergency. Where appropriate and agreed, this should include unmet need from neighbouring authorities. The plan will provide homes and jobs, to boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time. Five overarching principles will determine how this development is delivered:” 2.8. With regards to V3: Strategic Objectives, the role that all current settlements can play in meeting housing needs should be recognised. 2.9. Furthermore, in recognition that it may not be possible to fully off-set carbon emissions in all cases (see comments made later in this Statement), the Council should consider updating the strategic objective of “Contributing towards Net Zero Carbon targets” to refer to “Minimising net carbon emissions arising from new development as far as practicable” (or similar).
2.10. The Respondent wishes to express their concern at this stage regarding the content of the Sustainability Appraisal (SA) in so far that it is unclear how the SA comes to the conclusions that it does in terms of the performance of the identified small settlements against the identified SA objectives. Generally, the document lacks transparency in this regard and there would appear to be inconsistency in the approach to some settlements. 2.11. Turning to Hampton Magna specifically, it is unclear how a settlement that started life in the 1960/70s and contains only a handful of listed buildings and no Conservation Area can be identified as performing the same as settlements with much greater cultural significance (i.e. Bidford, Wootton Wawen, and Wellesbourne). In the Respondent’s view there are clear advantages in locating growth at Hampton Magna compared to these settlements. 2.12. Furthermore, while Hampton Magna resides in the Green Belt (which is a functional policy protection to protect against urban sprawl) it is not located within an area that has been identified as having any particular landscape value i.e., it does not fall within an area designated as a Special Landscape Area or Area of Outstanding Natural Beauty (AONB). While there is potential for coalescence this is not necessarily likely (SA, Paragraph 5.6.4) particularly if an allocation were to be made to the west of village. It is therefore unclear why Hampton Magna has scored as poorly as it has in respect of objectives SA4 and SA5. 2.13. With regard to objective SA12: Education, it would appear that while the SA considers proximity to primary, secondary and further education it does not consider whether there is capacity. With regards to Hampton Magna, it is understood that there is spare capacity of over 100 pupils at Budbrooke Primary School. This means that additional pupils could be accommodated with relative ease and assist in securing the long-term future of the school. 2.14. In short, while it is appreciated that the SA is intended to be a high-level appraisal, in its current form, it does not go far enough in the assessment of settlements to be of any real value in understanding the relative performance of each. Regarding Hampton Magna specifically, the SA does not fully reflect the benefits of growth at the village in respect of its lack of landscape impact, lack of heritage impact, accessibility or school capacity relative to other settlements.
Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development 2.15. The Respondent considers Option I2a as being most appropriate to ensure a consistent approach across the plan area and avoid disconnect between the SWLP and current extant Local Plan policies. 2.16. While the Respondent would not object to the utilisation of a combination of S106 Planning Obligations and Community Infrastructure Levy (CIL) as per the current system, any policy must reflect the provisions of the CIL Regulations 2010 (as amended) and particularly Regulation 122, which requires S106 obligations to be fairly and reasonable related in scale and kind to development. Q-I3: Please select the option which is most appropriate for South Warwickshire Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan 2.17. The Respondent considers that a single CIL for the whole of South Warwickshire is most appropriate since it will provide greater certainty to developers. While the Consultation Document indicates that separate levies could better respond to different conditions in different areas of South Warwickshire (i.e., the Stratford-on-Avon and Warwick Districts), in the Respondent’s view, this can equally be achieved through the implementation of different charging zones where these are justified. 2.18. The Consultation Document confirms that an Infrastructure Delivery Strategy (IDS) will be prepared which will set out the key pieces of new infrastructure needed to deliver the Councils’ growth strategy and how such infrastructure will be delivered. The Respondent is supportive of this action and considers the preparation of an IDS to be an essential component of the evidence base. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 2.20. Completion of a robust and comprehensive Plan Viability Assessment will be essential to ensure that the SWLP is viable and deliverable in a timely manner. The Respondent considers that both an IDS and Viability Assessment should be prepared at an early stage and used to inform a preferred strategy. Any such documents should be made available for comment as part of the Preferred Options Public Consultation.
2.19. Yes. The Respondent considers it sensible to include a policy that safeguards land that will facilitate the delivery of key infrastructure projects where this is justified. The Respondent recognises that safeguarding would be difficult to achieve post adoption of the SWLP and is best considered at an early stage of the plan preparation process to ensure that the growth strategy is capable of being delivered.
Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy 2.21. While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Please select all options which are appropriate for South Warwickshire Option 2c. Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. 2.22. Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. 2.23. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. 2.24. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. 2.25. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down.
