Issue and Options 2023

At the outset we should state that we think it is remarkable that, with such a long and complex document and at such a comparatively early stage in the process, there is not a proper executive summary of the key issues with page references to the main document. We confine our remarks to that part of South Warwickshire in Stratford District. Our submission relates mainly to Chapter 4 of the document and the questions therein. In particular, we reject the inclusion of a site at Wood End (Revised A1) as one of the possible locations for a major new settlement. The main reason for rejecting it is the fact that Wood End is in Green Belt. 1). Green Belt The Planning Inspector who examined the last Stratford Local Plan told the council in no uncertain terms that it should only consider building on Green Belt when it had excluded other options. The Core Strategy eventually had to be re-written to favour Long Marston and Lighthorne Heath - both existing sites with residential and business opportunities. It seems that lesson has not been learnt. Yet again planners in both Stratford and Warwick seem to have gone for the “soft” option of including sites in Green Belt. They have decided a “blind” approach as far as Green Belt is concerned is appropriate. We do not. This despite the assurance given by the Prime Minister to the House of Commons on 27 July 2022: “Green belt land is extremely precious in the UK. We’ve seen too many examples of local councils circumventing the views of residents by taking land out of the green belt for development, but I will put a stop to it.” The Tanworth-in-Arden Local Development Plan 2022 and the Stratford District 2011 Local Plan agree with the para 137 of the NPPF: “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” The recently adopted Tanworth Neighbourhood Development Plan, which covers Wood End, goes further: 1.16. “Overwhelmingly, the evidence from questionnaires and discussion highlighted the importance to the local community of being in or near open countryside protected by the Green Belt……….” This document chooses not to regard Green Belt as an unsurmountable obstacle. The avoidance of urban sprawl and “very exceptional circumstances” are barely mentioned. Green Belt only features as one of a number of “considerations” to be taken into account at a later stage. Clearly, Warwick District has its heart already set on a Green Belt review and, according to a report in the Stratford Herald on 11 January 2023, Stratford District seems to be being swept along in its wake. It would be a welcome change if planners could regard Green Belt/The Avoidance of Urban Sprawl as something to be cherished at the start of their deliberations. A last resort when all other options have been exhausted. In our opinion, and in the opinion of many voters in Stratford on Avon, Green Belt should be regarded as an asset and not as a burden to be got round - or an annoying inconvenience to be overcome. Planners may be blind to Green Belt, but, most definitely, residents are not. 2) Damned Statistics Our Association regards the use of so-called statistics in this document as nothing short of dishonest. To make the assertions that: “37% of respondents supported the principle of new settlements, whilst 27% were against. The remainder were indifferent.” “54% of respondents supported the exploration of growth opportunities in the Green Belt, with 31% against and the remaining 15% commenting without giving an overall view.” “In the Scoping and Call for Sites consultation in 2021 there was a majority support for undertaking a review of Green Belt boundaries” This was a self-selecting sample of the kind usually regarded as worthless by polling professionals. If you ask a group consisting mainly of landowners and potential developers if they are in favour of building on the Green Belt don’tbe surprised by the result. The only surprise is that the percentage was not greater. If the emerging Local Plan is going to quote public opinion to justify its case measure it properly and fairly. Even then the results can only be a guide. 3) The Missing Options Our Association totally accepts the need for housing to 2050 and the challenge of doing so sustainably. It also thinks that promoting the use of railways rather than cars is to be preferred. In passing, we note that government has recently refused finance for the campaign to restore heavy rail along the Stratford Greenway to join up with Long Marston and Honeybourne. It is strange this document makes no mention of the desirability of this or other similar rail projects. Figure 12 shows the Stratford - Long Marston and Fenny Compton - Kineton lines as possible railway corridors but only Long Marston is recognized as having potential for expansion. We have already submitted comments on the South Warwickshire Economic Development Strategy. That document refuses to offer suggestions for possible sustainable areas of fresh growth – preferring to leave this, and the Green Belt issue, to this plan. Rather than spreading housing down the existing rail corridors in Green Belt, a forward- thinking document like this should, in our opinion, look for more ambitious projects. Obviously, these will require money from central government. We commend two suggestions which aim to build on the results of the existing Stratford Local Plan: 1) Further expansion at Gaydon. The existing industrial and residential developments at Gaydon/Lighthorne, astride the existing M40, would seem to provide a modern location for further expansion using roads, existing and new, as the Planning Inspector at the previous Stratford Core Strategy recognized. There would be the long-term opportunity to create a new six mile railway spur from the Kineton branch of the Snow Hill to Oxford/Marylebone line with a modest re-alignment of the existing junction to allow northward travel. Chiltern financed such a project to Oxford with great success. Even more environmentally sustainable than road development it might attract the kind of government finance that has previously proved elusive and would avoid putting more pressure on the M40. It might even prove attractive to Jaguar Land Rover. 2) Staying with rail opportunities in the area. Long Marston, with its mix of industrial and residential developments, badly needs a boost. The existing proposals seem to have stalled. For a very modest outlay the re-establishment of the six mile link north to Stratford and Birmingham and south to Honeybourne and the Cotswold Line to London and Worcester would give a boost to existing industries and encourage developers. It would take pressure off roads in the area. The re-laying of part of the Borders Railway in Scotland and the Northumberland Line provides an indication of the economic and tourism benefits that can be achieved by restoring lost rail services. We would urge that a full business case be undertaken to establish the benefit to cost ratio and projected cost per mile for both projects as part of the next stage of the plan. In conclusion, major expansion at the existing new settlements at Long Marston and Gaydon, exploiting the proximity of possible rail connections and existing commercial and residential developments, would mean there was no need to undertake a Green Belt Review in Stratford District for the foreseeable future. Wood End should therefore be deemed an unsuitable site for a new settlement. Co-operation between the two Councils should not mean that “one size fits all”. Throughout the document there are options to allow each District to adopt different solutions to common problems. If Warwick District wishes to undertake a Green Belt Review because of its specific needs that should not mean that Stratford District has to follow. Q-S8.2: A lower limit is appropriate

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Q-I3: Separate Levies could have the potential to better respond to different conditions in different areas of South Warwickshire, with the potential that reviews could be undertaken more easily to react to changing circumstances.

Yes

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Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b: In this option, the policy would apply across the whole of the South Warwickshire area. Design codes could still be drawn up for individual character areas, but it would also be prudent to have a more generic intensification design code that applied everywhere else. It may be difficult for this more generic design code to direct the most appropriate forms of intensification across a wide range of localities and architectural styles.

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Yes

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