Issue and Options 2023

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Q-B5 Option B5c: None of these St Philips supports the movement towards achieving environmental sustainability and encouraging environmental net gain in regard to new development. However, it is important to note NPPF paragraph 31 which states that “The preparation and review of all policies should be underpinned by relevant and up-todate evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” 2.49 Without the support of evidence and an agreed method, a policy requirement is not considered to be justified and therefore would not be found to be legally compliant in accordance with the NPPF. Although St Philips supports the movement towards achieving an environmental net gain, it is considered that, at this moment in time, a policy requirement would be unjustified. In terms of an agreed method, the Issues and Options document states that: “Should this approach be taken, further work will be required to determine how environmental net gain will work in practice.” 2.50 In consideration, St Philips considers that the environmental net gain concept and the method of application is currently not supported by sufficient evidence. Therefore, a policy requirement would not be justified in this moment in time unless further work is completed. 2.51 Overall, an environmental net gain policy requirement would provide developers with greater flexibility and the freedom to concentrate on the most relevant aspects that can be improved on-site. Importantly, and as already stated, St Philips urges South Warwickshire to compile sufficient evidence to ensure an appropriate method and requirement is adopted. Although an environmental net gain policy would provide greater flexibility, it is imperative that a negative ‘trade-off’ is prevented between ecosystem services. Therefore, until sufficient evidence is gathered, St Philips considers that an environmental net gain policy would be unjustified. Furthermore, a proposed policy approach would have to be assessed within a viability assessment before being adopted.

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We agree that the Vision is essential to set out the main aims which the Plan hopes to deliver. We acknowledge that from the high-level goals identified, the guiding principles provide more clarity on how the goals will be achieved. It will be important, as the vision states, to ensure that proper placemaking to deliver more local visions takes place. The SWLP suggests that this is brought forward by Neighbourhood Development Plans. We note that NDPs are important to reflect the needs and wishes of the local community but believe it is important that some overarching principles for areas are established ahead of these. This is because in some cases, Neighbourhood Plans can face delay or not come forward at all. We support the five overarching principles for development including adapting for climate resilience; well-designed spaces; creating a healthy, safe and inclusive district; being wellconnected; and being environmentally resilient. The ability to deliver ‘homes for all’ will be important in ensuring diversity and to enable a thriving population and it is positive to see that the Local Plan will intend to engage positively with neighbouring authorities. It recognises this by confirming that where appropriate and agreed, unmet need from neighbouring authorities will form part of the consideration for sustainable development.

Q-I3: Please select the option which is most appropriate for South Warwickshire It is considered that both options (considering a South Warwickshire CIL and each district producing its own CIL) are important. Producing a wider CIL will help to assist in identifying and delivering wider strategic infrastructure requirements which span across both districts. There needs to be a joined-up approach to deliver such strategic infrastructure. It will however be important for each district to work to identify more localised requirements of certain areas/ zones to ensure these more accurately reflect site specific circumstances. It is imperative also, in considering any option, that any existing bespoke CIL provisions that have been agreed for specific allocations or projects (e.g. Long Marston Garden Village where CIL rating is zero for residential floorspace) are carried across to ensure that any amended provisions do not prejudice the deliverability of such sites, especially as a number of these schemes plan to deliver their own infrastructure.

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Land has been safeguarded in the Core Strategy in respect of large scale, strategic development that requires specific infrastructure delivery to enable these sites to be brought forward. In the case of the Stratford on Avon (SoA) Core Strategy, strategic growth areas such as Long Marston Airfield (LMA) provide a key form of housing delivery and will continue to do so over the long term, with an aspiration to provide 3,500 dwellings. It is therefore considered appropriate in this case that the safeguarding of land to deliver the Stratfordupon-Avon South Western Relief Road (SWRR) continues, reflecting the designed and planned scheme in this location as one possible solution to managing transport and traffic capacity to the south of Stratford. This will ensure the option to deliver the SWRR is not prejudiced by other development along the route. Whilst it is important that the land identified for the SWRR is safeguarded, Cala strongly considers that the delivery of the SWRR should not impede upon the delivery of interim phases at LMA. LMA is a brownfield site which is already delivering new homes, and therefore the priority of development, and latent highway capacity, in the south of the subregion should be directed and allocated towards LMA where possible. In a similar manner, the route of the former railway line south from Stratford to Long Marston is safeguarded as part of Policy CS.26 in the existing Core Strategy, and this should also be carried forward. This provides a presumption against development that would prejudice the reinstatement of the railway on this route. It provides a significant opportunity to provide a locally important sustainable transport corridor, depending on any scheme advanced. This safeguarding includes a potential new station on the site of Long Marston Garden Village, also safeguarded within policy. Cala is fully committed to the delivery of LMA, which is demonstrated through its planning applications submitted to date and an upcoming planning application in respect of Phase 1bat LMA.

We note that the SWLP team have produced a density guide (January 2023) which illustrates typical housing densities found within the South Warwickshire Area. In respect of the LMA new settlement a density of 23dph is specified, based on an extracted block of development from Phase 1 only. It should be noted that the Long Marston Garden Village Framework Masterplan SPD (Feb 2018) specifies a range of densities according to specific location within the garden village and this ranges from 25-55 dph. The current and forthcoming development at LMA is being designed by Cala and determined by Stratford on Avon District Council on the basis of this document. Its density principles should therefore be carried across into any density guidelines set out within the SWLP.

Issue S3 – Using Brownfield Land for development We support the re-use of brownfield land for new development as an effective use of land. Through the NPPF 2021, the Government confirmed its commitment to delivering new housing on brownfield land. NPPF paragraph 85 sets out that: “The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.” The importance placed on the development of brownfield land was highlighted through the introduction of a £1.8bn brownfield fund in late 2021, and subsequently referred to within the NPPF consultation launched in December 2022 which considers that: “In support of levelling up, the UK government will target the majority of delivery on brownfield sites outside London and the south east. As part of the wider Framework review, we therefore want to make sure that national planning policies are fully supportive of our aim to gently densify our urban centres, especially outside London and the south east.” Long Marston Airfield is classified as Previously Developed Land (PDL) and is a ‘brownfield’ site allocated to be brought forward for development within SoA’s Core Strategy 2011-2031 with an accompanying Framework Masterplan SPD (February 2018) to guide its delivery. It should be seen as a cornerstone of any spatial strategy proposed as part of the SWLP and in the context of national policy, it is imperative it continues to be allocated as a key location for growth, consistent with its existing status in the Core Strategy. Q-S7.2 – For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: The vision for South Warwickshire places particular emphasis on the need for sustainable development and the need to consider active travel and the ability to connect development to public transport. Therefore, whilst Cala does not consider at this stage that there is sufficient evidence to make a judgement on the most appropriate growth option, it is clear that a balance needs to be found between facilitating appropriate growth across South Warwickshire in order to both meet future housing need and respective local employment growth, whilst ensuring that design standards and sustainability maintain a high priority. The Council will need to consider, with its neighbouring authorities, how much of the Greater Birmingham unmet housing need it can accommodate, and how that influences the necessary growth options. The growth options will need to consider the number of homes South Warwickshire will contribute towards, insofar as is reasonable and sustainable, the unmet needs of Greater Birmingham and the overall spatial strategy for doing so. Cala supports the inclusion of LMA within the indicative list of settlements and locations that can facilitate the initial growth options, recognising that LMA is an important strategic site that will deliver a significant quantum of housing across the plan period. It should be retained as an allocation and included as a location for future housing delivery across any and all chosen growth options within the SWLP. Further, any growth option should actively support LMAs delivery (as a key brownfield site and location that will eventually become one of the largest settlements in Stratford District) in respect of its approach to growth in the wider Stratford area.

In setting out its strategy to meet the economic needs of South Warwickshire, careful consideration will need to be given to supporting areas which provide specialist types of employment (i.e. manufacturing and education), and to ensure that the provision of employment opportunities is distributed across all areas of the region. A challenge of successfully implementing the 20 minute neighbourhood concept is acknowledged to be the difficulty in providing an appropriate variety of employment opportunities. In particular, this means providing a suitable variety of employment to enable the local workforce to access their workplace within a 20 minute travel time. In this regard, the opportunity to plan from the outset a new settlement, such as LMA, which incorporates the principles required to successfully deliver a 20 minute neighbourhood should be encouraged over other forms of more piecemeal development. As the HEDNA confirms, Stratford-on-Avon provides an important role in driving economic growth across the sub region, being the 3rd largest economy after Coventry City and Warwick. Stratford-on-Avon has also seen significant housing growth, with notable allocations such as LMA Garden Village, and it is therefore imperative that sufficient growth stimuli are directed towards SoA to continue providing sufficient employment opportunities to match associated housing growth. In this regard, it is important that South Warwickshire provides support for the diversification of economic opportunities at a local level to help prevent out-commuting. This will both support the aim of sustainable development with local residents reducing travel to work by car and also ensure that there is not an outflow of skilled labour from the area. Additionally, there should be an acknowledgement of the shift that has occurred in office based working, with the upward trend of home working and a shift to ‘hybrid working’ where workers spend a larger part of the working week at home. As the HEDNA (2022) confirms, 36% of adults reported working from home at least once in the last 7 days. There will of course be some residents who work much more frequently from home and the design and mix of housing within new development can help to support this.

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The accompanying HEDNA proposes a shift away from a future household needs approach based on the 2014 household projections, towards a trend-based approach. It is recognised that following the release of the 2021 census data that the 2014 projection based forecasts are increasingly dated, but they remain Government’s preferred basis for assessing local housing needs. Further, it is evident from initial comparisons of the projections that the Coventry numbers are far lower than those under the 2014 projections. However, given that it is unclear at this stage where the expected uptick in population has gone (i.e. whether it has simply dispersed across the sub region or resulted in a net outflow of population) we therefore have reservations about whether the HEDNA approach is correct. It will be important to continue to deliver a range of homes and the emerging SWLP will need to take account of planning reforms which are set to be announced in Spring 2023.

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The importance of climate change is such that in July 2019 Warwick and Stratford-on-Avon District Councils declared a climate emergency, and consequently produced a joint Climate Change Action Programme. The climate emergency requires both Councils to become netzero carbon as organisations by 2025, but more importantly seeks to reduce the total emissions in the District as a whole by at least 55% with a view to becoming a net zero District. We agree with the Council’s assertion that the Local Plan has a role to play in reducing the carbon footprint of the district and an overarching support towards achieving net-zero carbon development across the sub region. This will need to form a strong consideration through the choice of the growth options, with development directed towards areas where existing sustainable infrastructure is located. It is imperative that in order for the Local Plan to achieve this, that the Council delivers objectives around good growth which addresses carbon emissions, but does via planning policies that are fully tested for their potential viability implications.

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Q-D2 – Please select all options which are appropriate for South Warwickshire As is set out in the vision for the sub region, there is a focus on the design of new development to create great places, spaces and buildings that are of a high quality and cater for the needs of all users, and which respect the setting of our many settlements (Lichfields emphasis added). The desire for a high-quality public realm, and spaces which cater for the needs of all users in new developments is supported, and it will be important that developments respond to the local character and existing identity of the area. In helping to deliver a high quality public realm, proposals for new development should integrate measures to minimise carbon emissions., Blue and green infrastructure should be encouraged, with accessible transport such as cycling and walking routes delivered to provide future residents with forms of active travel to mitigate a potential reliance on private transport. Cala considers that an effective way to promote this, is through site specific design codes and SPDs, such as that at LMA, which provides guiding principles and enables a fully integrated approach to high quality aesthetic design in respect of homes and buildings, as well as that of green infrastructure, open spaces and play space.