Issue and Options 2023
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New searchWe have some concerns with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and allocate the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach is problematic as it will delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). The Local Plan Part 2 will need to be prepared to be in general conformity with the SWLP Part 1. It is unlikely that the Part 2 Plan will be adopted for at least two to three years following the adoption of the SWLP Part 1 even if their preparation periods overlaps. Indeed, the Stratford-on-Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not adopted. The preparation of a two part Plan means that no small or medium scale allocations will be in place until late 2027 at the earliest, and given past planning performance it is likely to be much later than this. Preparing a two part plan will delay the delivery of much needed market and affordable housing and non strategic employment sites during first part of the plan period. This will make home ownership more challenging, has the potential to increase house prices and worsen affordability and hinder affordable housing delivery. It could also stifle economic growth. This will directly conflict with the Draft Plan’s Strategic Objectives of delivering homes that meets the needs of all the plan areas communities (SO 4) and developing Job Opportunities (SO 3). It could also result in a 5 year housing land supply shortfall and increase the number of speculative planning applications. The Plan Period We support the preparation of a plan that will run to 2050. Having an extended plan period will allow for the SWLP to properly respond to long term issues and support the allocations of larger, strategic sites that will deliver over an extended period of time. The SWLP will need to have a flexible and adaptive Vision and set of policies to respond to the fact that the local economy and housing needs are likely to change significantly during the course of the period to 2050. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that in addition to the existing evidence base studies additional technical studies will be commissioned to inform the SWLP as required. One of the identified potential additional studies is a Green Belt study. We have no objection to the preparation of a Green Belt study. There are, however, a number of development opportunities available to the Council that are outside of the Green Belt. Suitable and sustainable non Green Belt development options should be prioritised ahead of Green Belt land release. For example, Vistry control land to the east of Southam. Southam is one of the largest and most sustainable settlements in the Plan area is not constrained by the Green Belt. As detailed in our Call for Site submission, this site provides an opportunity to expand Southam, providing housing and supporting infrastructure such as a primary school. This is particularly important, as we understand that primary school capacity in Southam is limited. The site is readily deliverable and in the control of a developer. It can be brought forward for development promptly if it is allocated in the SWLP.
The Vision Vistry support the Vision outlined in the Draft Plan. The objectives of providing homes and jobs to support the needs of South Warwickshire and neighbouring authorities is fully supported. We agree that this should be done in a sustainable way, responding to the climate emergency, and the five overarching objectives will help ensure that development is delivered in the right locations provided that they are reflected through SWLP’s policies and allocations. The Strategic Objective We support and have comments on a number of the Strategic Objectives identified by the Draft Plan. • Providing infrastructure in the right place at the right time – New housing and employment allocations often require new infrastructure to support their development. There is the opportunity to include allocations in the SWLP that will deliver infrastructure that supports not just the proposed development, but also delivers onsite facilities that can benefit the local area as a whole. For example, Vistry are promoting the residential led development of a site to the east of Southam. Land for a two form entry primary school forms part of the proposal. There is a lack of primary school capacity in Southam that this development will help address. The development will also improve existing footpaths and road crossings and facilitate access to the countryside through its generous green space offer. • Developing opportunities for jobs – We fully support this objective. Making residential allocations in locations that have easy access to employment opportunities by sustainable transport modes should be a preferred approach in planning to support economic development. Furthermore, an increased proportion of people now work from home. Residential and mixed use sites that can provide facilities to help supporting people working from home should be supported. • Delivering homes that meet the needs of all our communities – It is imperative that residential allocations of different sizes are made across the plan area to meet the housing needs of South Warwickshire and any unmet needs arising from neighbouring authorities. A range of housing allocations are required, from small scale sites that can deliver development promptly, to larger sites that can deliver significant amounts of housing over a longer period of time that will naturally have longer lead in times. Allocations should be focused at sustainable locations, or locations that can be made sustainable through the introduction of new services and facilities as part of the development. • Contributing towards a net zero carbon target – Development opportunities that can provide significant amounts of green infrastructure and have access to services and facilities by sustainable means, should be preferred locations for an allocation to help deliver this objective. • Connecting people to places – We actively support the objective of increasing and improving access by sustainable and active travel modes. Allocations that are located within walking distance of services and facilities should be preferred. Vistry’s land interest at Southam is within walking distance of Southam town centre, and has easy access via existing footpath connections. • Protecting and enhancing environmental assets – We support the objective of protecting and enhancing environmental assets. The SWLP should look to support allocations that can provide significant biodiversity net gain opportunities and high quality green infrastructure that will benefit not only the residents of development, but the environment as a whole.
Vistry Group (“Vistry”) have a series of comments on the Sustainability Appraisal (“SA”) prepared to support the South Warwickshire Local Plan (“SWLP”) Issues and Options consultation draft document. These are set out below on a topic basis in the same order that matters are raised in the SA. Chapter 2 – Topic Specific Methodologies, Impact Scoring Index and Assumptions We support the SA testing the Growth Options against the 13 criteria identified in paragraph 2.21 of the report. These criteria accurately reflect the objectives of the SWLP and the topics identified in Annex 1(f) of the SEA directives. The outcomes of the assessment process should, however, be treated with a degree of caution. The SA is a snapshot in time. It assesses the sustainability of the Growth Options and potential locations for allocation on the basis of the current services and facilities that are available and existing constraints. For example, when assessing the potential locations for development against Matter 11 – Education, regard has been had to existing education provision in the locality. It does not, however, consider how new development could improve local education facilities through the provision of new education infrastructure such as a new school that would be of benefit to the local area generally. Sustainability Appraisals are an iterative process, until the current Call for Sites consultation is completed and responses reviewed the local authorities will not have a clear understanding of what services and facilities are being promoted with the various development opportunities being presented. However, in due course this should be a key consideration for the local authorities in determining the preferred strategy, growth options and allocations within the SWLP. Climate Change Whilst we fully support the assessment of the proposals against climate change objectives, we have concerns with the way in which this has been applied in the SA. Paragraph 2.4.6 of the SA states that the Broad Locations (2,000+ houses) and New Settlements (6,000+ houses) are likely to increase greenhouse gas emissions by more than 1% and adversely affect climate change. Developments of between 50 to 500 dwellings could increase greenhouse gas omissions by more than 0.1% and have a lesser effect on climate change than the larger sites. Whilst this may be the case in principle, it is somewhat misleading and does not reflect the reality of the way in which the SWLP will deliver housing. The SWLP will have a set housing requirement. The greenhouse gas emissions from the construction of these properties will have a total accumulative impact based on the total number of houses built. The total amount of greenhouse gas omitted as part of the construction of these houses will be broadly the same, regardless of whether the houses are provided on a larger number of small sites or a smaller number of large sites. Larger scale developments are unlikely to have a greater impact on greenhouse gas emissions than smaller schemes. Large scale developments are more likely to provide onsite infrastructure, such as schools, places to work, local services and facilities than small scale developments. In terms of the Rail Corridor Growth Option, it will help facilitate sustainable commuting patterns. Smaller schemes of 50 to 500 dwellings are less likely to provide onsite infrastructure or have the benefit of close proximity to a train station. It is, therefore, inappropriate for the climate change appraisal to penalise larger sites in comparison to smaller sites due purely to their size. It is also suggested that development of greenfield sites for housing has a potential to lead to local, long term significant adverse effects in the form of increasing flooding, drought and storm events. This is not necessarily the case. Indeed, it is not uncommon for new development to introduce flood risk and drainage control measures that improve the flood risk and drainage situations locally. New developments must achieve greenfield run off rates and often can be used to address localised problems associated with flood risk. Biodiversity and Geodiversity The impact of development on biodiversity and geodiversity is a clear consideration in the SA process. However, we note that the SA advises that no detailed ecological surveys have been completed at this stage to inform the assessments in the report (paragraph 2.6.14) and detailed ecology surveys and assessments will determine, on a site by site basis, the presence of priority species and priority habitats (paragraph 2.6.12). The SA has, therefore, made assumptions about the sensitivity or otherwise of potential development options from an ecological basis linked to their proximity to identified assets rather than on an evidential basis. The SA’s conclusions reached regarding the ecological sensitivity of the development option needs to be treated with a degree of caution. If more detailed site specific ecological information is available from the Call for Site submissions this should be actively considered in the site selection process. Landscape The SA advises at paragraph 2.7.2 that detailed designs for each development appraisal are uncertain at this stage of the assessment. The landscape assessment is a desk based exercise which has not been verified in the field. Therefore, the nature of potential impacts on the landscape are, to an extent, uncertain. The SA recommended that landscape sensitivity and capacity studies would be helpful later in the plan making process once Preferred Options have been identified. The landscape appraisal selection of the SA should be treated with some caution as the evidence base is not complete. Paragraph 2.7.6 states that large scale residential-led development is likely to adversely impact the countryside and urban area where the various reasonable alternative development locations are located. This is a broad brush conclusion. Whilst development may impact on the landscape, impacts are not automatically negative. Indeed, well designed and high quality landscaping could potentially enhance the landscape character of a development area. Cultural Heritage Paragraph 2.8.3 of the SA confirms that the impacts on heritage assets will largely be determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. At this stage, the risk of substantial harm to the significance of the heritage asset has been assessed based on the nature and significance of, and proximity of sites to, the heritage asset in question. It is also advised that whilst the Heritage and Settlement Sensitivity Assessment is being prepared, this assessment was not available for use at the time of undertaking the SA process. The conclusions of the SA on cultural heritage impact must be treated with caution. Where site specific heritage information has been provided with Call for Sites submissions this should be considered in the site selection process. Environmental Pollution We are concerned with some of the assessment criteria used within the environmental pollution section. Development proposals that are within 200 metres of a railway station are negatively scored. Development proposals located over 200 metres from a railway station have a neutral score. Development proposals which would help to reduce the pressure on railway lines by locating further away have a positive score. The SWLP correctly recognises that there are significant benefits in a Rail Corridor Growth Option and that providing access to a train station reduces the need for people to travel using the private car. The approach of the SA in this regard directly conflicts with the Rail Corridor Growth Option. It is suggested that schemes within 200 metres of a major road may have adverse sustainability credentials due to road related air and noise emissions. It does not automatically follow that because the site is within the 200 metres of a main road that a suitable noise and environmental air quality cannot be achieved. This assessment criteria should be reconsidered. Natural Resources The SA has a flawed approach adopted towards assessing the agricultural land implications of development. Development proposals that include over 20 hectares of Grade 1, 2 or 3 agricultural land score a ‘double negative’. Development proposals that include an area of land of less than 20 hectares of Grade 1, 2 or 3 agricultural land have a ‘single negative’ impact. The SWLP will have to allocate land to deliver a set amount of housing. This will be from a combination of brownfield and greenfield sites. The amount of agricultural land developed in the plan area as a whole is likely to be fixed, as the housing requirement will be fixed. However, the approach of the SA means that it favours the allocation of a large number of smaller sites (less than 20 hectares) rather than a small number of large sites (more than 20 hectares) whilst the total amount of agricultural land developed is likely to be the same. Health Impact The health SA criteria consider the proximity of development to a GP surgery and leisure facilities. Development locations that are closer to GP surgeries and leisure facilities are preferred to those rather than those that are removed. Whilst we support this approach it does not necessarily follow that a site is in close proximity to a doctor’s surgery there will be available spaces for patients. Furthermore, some schemes will be able to provide doctor’s surgery and leisure facilities on site. Similarly, the development options are scored down if they are more than 800 metres from an area of green space, or 600 metres away from a public right of way or cycle path. Development proposals will, in all likelihood, provide onsite green space to meet their needs, and may be able to provide connections to nearby footpaths/cycle paths. Accessibility The SA accessibility assessment criteria for proximity to bus stops and food stores gives a negative sustainability rating to potential development locations that are more than 400 metres from a bus stop and more than 800 metres from a food store. Whilst this is a sensible starting point, large scale developments will, in all likelihood, provide new bus stops and convenience stores. Indeed, we would fully expect the local authority to require larger schemes to include a local centre. Similarly, development options that are located over 800 metres from a primary school have a negative rating. Large scale sites are likely to provide primary schools. Primary school provision to be a key component of any scheme providing 800+ dwellings. Economy The SA assessment criteria for economic opportunities penalises schemes that are more than 5km from a “key employment location” whilst positively scored sites that are within 5km of a key employment location. Large scale residential sites are likely to provide employment opportunities as part of the overall proposals. It is inappropriate for the SA to penalise such sites in the SA when employment land accessibility will be rectified by onsite provision. Evaluation of Broad Locations at the Main Settlements Southam Vistry control land within the north east of Southam search area. The Southam appraisal, includes at paragraph 4.13.1 of the plan, includes a series of inaccuracies regarding the development potential of this area. It is advised that Southam north west is located in close proximity to Thorpe Rough Ancient Woodland, and development here could have adverse impact on the woodland. Whilst this may be the case, the land in Vistry’s control that forms part of this area is significantly smaller than the Southam north east appraisal area. It will not result in development in close proximity to Thorpe Rough Ancient Woodland. There are no ecology constraints to the development of the site. A Phase 1 of the ecology survey report of the site has been undertaken. There are no ecological constraints that cannot be overcome and the site can provide 10% biodiversity net gain. In terms of landscape impact, Vistry’s land interest at Southam have previously been identified as part of a potential Reserve Housing Site in the Preferred Options Site Allocations Plan. Detailed representations have been submitted to the Site Allocations Plan consultation that demonstrated that the site is entirely deliverable from a landscape perspective. This is confirmed in the Vision Statement that accompanies our Call for Sites submission. The Council have previously ruled out all development options to the west of Southam on the basis of landscape impact. Paragraph 4.11.9 of the SA advises that the Broad Locations to the west of Southam would result in the development of high/medium and high sensitivity landscape parcels. This is clearly a significant constraint to development meaning that the land to the east of Southam should be favoured. Furthermore, and significantly, the conclusions table for Southam in the SA does not reflect the assessment work in the SA. It is suggested by the table at paragraph 4.13.1 that Southam south west is “best” for education provision, however, paragraph 4.12.1 advises that Southam north east is the best performing in terms of education provision. If this error is corrected it means that Southam north east scores “best” for four criteria. Southam north west has “one” best result, Southam east has “two” best results and Southam south west has “three” best score. The SA for Southam should have concluded that Southam north east is the most appropriate location for further development.
Part 4 of the Draft Plan identifies a series of existing infrastructure schemes proposed across both plan areas. It is our view that it would be sensible to include a policy in the SWLP to guide the schemes. The policy should confirm the location of the works, which should be identified on the Policy Map, and the extent of the work involved. There should be a clear commitment to their delivery and an explanation as to how they will be funded. It should also be clear if developments are expected to contribute towards schemes as part of their planning obligation package.
Q-I2 – Please select the infrastructure delivery option which is most appropriate for South Warwickshire As referred to earlier in our representations, it is our view that it would be preferable to prepare a single Local Plan rather than a two part plan. Adopting this approach would remove the complications identified on page 30 of the draft Plan regarding the way in which a two part plan could secure appropriate infrastructure provision with new developments. However, if the Council decide to pursue a two part Local Plan we suggest that the policies guiding the development of the strategic allocations identify the infrastructure requirements for the developments. Given the nature of strategic allocations the infrastructure requirements will vary from site to site. We support the recognition that the infrastructure requirements of the development strategy are critical in ensuring that development is truly sustainable. That being the case, as part of the site selection process one of the critical considerations should be the onsite infrastructure that is being proposed to support the development. In this regard, as detailed in our Call for Sites submission, Vistry’s land interest at Southam will provide land for a new two form entry primary school, public footpath and road crossing enhancements and significant areas of public open space. Q-I3 – Please select the CIL option which is most appropriate for South Warwickshire This matter should be kept under review. It is possible that the CIL system will have been replaced by the time the plan is adopted. If the Councils do pursue a CIL its requirements must be considered as part of the plans viability assessment to ensure that the proposed allocations are viable and consequently deliverable. Q-I5 – Please provide any comments you wish to make about infrastructure, viability and deliverability We support the recognition that the development strategy needs to be deliverable, viable and that there needs to be confidence that the sites and locations that are allocated for development will come forward as expected. We note that all development proposals will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment and Infrastructure Delivery Strategy that are being prepared alongside a Viability Assessment to ensure that the proposals that are put forward are viable. We fully support this approach. It should be informed by the information provided with the Call for Sites submissions. Vestry’s land interest at Southam is viable, deliverable, and it is expected it will provide a ‘full’ S.106 package.
We support the preparation of the South Warwickshire Urban Capacity Study. It is a useful document to help understand the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements will be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. Certain brownfield sites may not be suitable for residential development on viability grounds, or unable to support a “full” S.106 package with reduced contributions towards affordable housing amongst other matters. This could be exacerbated by the introduction of NDSS policy and the other provisions of the emerging plan. That being the case, whilst we support the plan making the best use of previously developed land within the existing settlements as a possible location for residential development, these sites must be treated with caution. There is currently insufficient information available to establish the role these sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance accordingly.
The land to the North East of Southam, that includes the land in Vistry’s control, has Connectivity Grade ‘D’ in the settlement analysis. This is as the A423 is a ‘hostile environment’ for no vehicular traffic. As detailed in our call for sites submission Vistry’s development proposals at Southam include the creation of a new roundabout access on to the A423, the principle of which has been agreed with WCC Highways. New pedestrian and cycle paths will be created at the access and the existing public footpath will be improved. The Settlement Analysis fails to recognise the opportunities the site provides by creating sustainable access to Southam town centre. The Settlement Analysis identifies land north east of Southam has having access to 5 local facilities within 800m. It is the joint best scoring site in Southam. The provision of land for a school on site and the significant amounts of open space will further bolster its suitability credentials.
