Issue and Options 2023
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2.45 It is agreed that this scenario is more appropriate to reflect the context of specific locations and places. As stated above ‘networks of villages’ can provide local amenities for new residential development. The settlement analysis should therefore be updated to include all settlements in the District, to do so would be in line with Paragraph 79 of the NPPG (2021) which states that: 2.46 ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.’
2.1 Response: It is noted that the SA in the conclusion for the Sustainability Appraisal states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ [emphasis added] 2.2 As the Issue and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and not mitigation has not been considered.
2.5 Response: With regards to the settlement analysis for Stratford-upon-Avon this gives the site an accessibility of ‘C’ i.e., ‘barriers may be overcome, but not easily’, which is defined as connects to: - one brown or red route - potential for connecting existing cul-de-sacs or loops into new red route - active links (e.g., via green / blue infrastructure or other active links) are possible but not easy It is noted therefore that although the are some accessibility sustainability restrictions on the site they could be overcome. 2.6 It is agreed that the Strategy should provide a wide range of employment opportunities in accessible locations. Moreover, the Strategy needs to respond to the needs of businesses. The National Planning Policy Framework (NPPF) at paragraph 8 states that the economic objective for achieving sustainable development requires the planning system to ensure that ‘sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity’. 2.7 The Local Plan should indeed support the growth of new industries/sectors as part of a portfolio approach to supporting economic growth within the Districts. In so far as there is some level of balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. As such, the Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment sites are either not suitable or not available to meet employment requirements. A criteria based policy would be appropriate to establish the need and suitability of additional land to meet employment needs. 2.8 Sustainable locations should be considered, for example adjacent to existing employment locations and adjacent to main towns including Stratford-upon-Avon Council. In so far as the majority of employment opportunities are located within and adjoining the main towns of both Districts, these settlements should be the focus for new employment locations.
2.30 Response: In so far as there is some balance between employment land requirements and housing provision, the public interest is better served by an over-provision of employment land than an under-provision because local development plans are insufficiently agile to release further land in order to accommodate employment needs. The Local Plan should include a policy that allows for additional land to be released for employment purposes in circumstances where it can be demonstrated that existing employment site are either not suitable or not available to meet employment requirements. 2.31 The Local Plan should indeed support the growth of new industries/sectors as part of a portfolio approach to supporting economic growth within the Districts. 2.32 It is evident that some allocations in the current development plan have failed to deliver new employment development. The availability of such sites to contribute to the supply of employment land opportunities should be reviewed. No purpose is served in allocating land for employment development where the land is not then brought forward into development. The effective supply of employment land is then over-estimated, which frustrates new investment and jobs. It would be inappropriate to envisage that existing employment sites are capable of producing new sources of land for investment. The joint Plan must allocate new land for employment development on the urban edge of the main settlements. The land must be suitable and attractive for new inward investment.
