Issue and Options 2023

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Q-V3.1 - Do you agree that the Vision and Strategic Objectives are appropriate? Yes, we agree in principle with the Vision and Strategic Objectives set out within the consultation document. We are pleased to see an explicit inclusion of housing within the Vision as this was a concern we raised previously. We support in principle the now 11 objectives (including the addition of an objective related to heritage assets). We would comment in relation to providing new infrastructure through new development; it is vital that the funding is proportionately related to the scale of proposals and that developers aren’t necessarily bearing the burden of overly expensive infrastructure projects. The Council should look to secure other means of funding to pool alongside reasonable developer contributions in the interests of viability. Key to the evolution of the Local Plan is how the 11 objectives are translated in to strategic and non-strategic policies and land allocations. It is inevitable that tensions will arise in applying the ten objectives – for example delivering new housing whilst also protecting and enhancing the most important historic and environmental assets. Choices will inevitably need to be made, and a balance struck. It is vital that housing needs are met in full and that the Council do not attempt to row back from meeting their need in full in the event that general sustainability objective cannot be met; the housing requirements must be met in full in any event.

We make comments specifically on the ‘Stratford-upon-Avon Northeast’ (reference B.26) site assessment within the Sustainability Appraisal (SA) which includes land under our control at Clopton Quarter and is identified as a Broad Location for growth. Whilst we do not disagree with the SA impact key (with a traffic light system) and general approach to the SA, we have significant concerns about the presumptions made in coming to the SA conclusions. The site assessed is larger than that under our control and states it could deliver up to 2,000 units, however much of the land particularly to the east / southeast (outside of our control) has heritage and landscape constraints which means it is unrealistic to assess this larger site for the delivery of 2,000 units. Instead, the land under our control at Clopton Quarter is capable of coming forward for 700 units without any technical constraints and will be able to enhance connections to the public footpaths and wider countryside in a sensitive manner, respecting the = heritage and landscape consdierations further east.. Appendix 2 of this response sets out a true SA assessment of the land under our control and we request that the SA is updated to reflect this new assessment. [see submission attachment - not possible to replicate table without formatting]

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Q-I2 - Please select the option which is most appropriate for South Warwickshire The two options set out within the consultation document are as follows: 1) Option I2a: Set out infrastructure requirements for all scales, types and location of development. If this detail was included within the Part 1 Local Plan then the requirements would be established which apply equally across South Warwickshire. 2) Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy In this option, the focussing only on infrastructure relating to the growth strategy would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. These options are unclear because option 12b proposes to relate infrastructure to the growth strategy, which is the same as option 12a which will set out infrastructure requirements related to all scales, types, and location of development. All scales, types and location of development will be the growth strategy, therefore the options are the same. We will however stress it is important that there is clarity about the infrastructure requirements needed to support the growth strategy, and that the type of infrastructure and route options are decided on as early as possible to provide certainty. For example, in West Northamptonshire the Northern Orbital Route has been committed so far along, but then no progress has been made on the route options for the remainder of the route from Pitsford to Moulton. This has meant that as the work on West Northamptonshire’s Strategic Plan has progressed, growth options have been proposed which would be reliant on the completion of the Northern Orbital route, and there is uncertainty for developers as these sites are promoted about whether or not there will be significantly more infrastructure costs than would otherwise be the case. Historically, as part of our previous submissions to the emerging Local Plan, we have submitted evidence showing how Clopton Quarter is capable of coming forward for residential development and be acceptable in highways terms. In order to mitigate impact on the highway network as a result of the development low intervention measure such as traffic control at Bishopton roundabout would offset the development’s impact as shown by previous reports by ADC Infrastructure. However, we recognise that the growth of Stratford from other sites is likely to require more advanced traffic intervention, and as such, we propose contributions towards upgrading Bishopton roundabout to a ‘hamburger’ roundabout which will be partially traffic signal controlled with a westbound A46 cut through. The roundabout is capable of being delivered within highway land and land controlled by Davidsons, without the use of all of the proposed safeguarded land shown within the emerging Site Allocations Plan. This is considered the best solution to accommodate future growth in the area as a solution that solves the infrastructure constraints currently in Stratford for and beyond the plan period. An early plan showing these proposals is provided at Appendix 3. National Highways have no identified or committed scheme to address the identified need for improvement at the Bishopton roundabout in the next 8-18 years of their RIS2 and RIS3 policies. Therefore, this constraint to highways at the key junction for Stratford has the potential to prove a bottleneck for delivering the required housing growth in the next Local Plan period. The South Warwickshire Plan Officers are therefore encouraged to proactively lead these conversations with National Highways and the site promoters who are capable of delivering these solutions to unlock the Local Plan growth. In terms of direct access from the Clopton Quarter site, we propose installing a new roundabout connecting onto the A46 which will be acceptable in highway terms. Discussions with National Highways are ongoing, with the latest meeting being held in December 2022. The final investigation works looking at matters including layby surveys and recommissioning the Road Safety Audit will be carried out in Spring. This approach resonates with the IM land approval further south on the A46 which also includes direct access from the A46. Q-I3 - Please select the option which is most appropriate for South Warwickshire: 1) Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan. 2) Option I3b: Each District Council to produce its own Levy. Option 13a – a South Warwickshire CIL covering the whole of the District – is most appropriate. This will give developers more certainty about the amount of chargeable CIL that will apply to a development and, as the consultation highlights, different CIL zones can be established within a single levy which would be able to respond to different areas and changing circumstances.

Yes

Within the settlement analysis Stratford has been split into 4 different areas: northwest; northeast; southwest and southeast. Land at Clopton Quarter lies within the southeast area which is identified as a potential Broad Location for growth within the emerging Local Plan and Sustainability Appraisal (SA) (see Appendix 4 for our commentary on this SA). We wholly disagree with the conclusions of Heritage and Settlement Sensitivity Assessment which concludes that from a heritage perspective, development beyond the north-eastern edge of Stratford should be avoided and that development should be restricted to the northwest, east, south and west of Stratford. Clopton Quarter in the northeast is able to come forward for 700 units without causing unacceptable harm in heritage terms given it is a smaller area than the Broad Location for growth considered for 2,000 units. This representation includes a copy of the Vision Document previously submitted to promote Land at Clopton Quarter for residential development. A heritage assessment has been carried out which summarises that Land at Clopton Quarter is able to come forward for 700 units. There are no known below ground, archaeological constraints to the promotion/development of the site and whilst further surveys would be required to support any future planning application the site is assessed to have a low/negligible potential for significant remains of all periods. In respect of non-designated built heritage assets, the HER identifies Clopton Park located immediately adjacent (south-east and north-east) of the site. This landscape comprises a post-medieval former deer park which also incorporates elements of seventeenth and nineteenth century landscape design surrounding Clopton House (Grade II* Listed Building). The allocation of the site would have the potential to affect the heritage significance of Clopton House (Grade II* Listed Building) and the non-designated built heritage assets of Clopton Park, Lower Clopton Farm, Clopton Cottages and Gable Cottage through changes within their settings. This is however, not considered a constraint to the allocation of the site as the potential harm can be mitigated through design and master planning of the development, as demonstrated through our Vision Document Masterplan. This has heavily influenced the design of the initial masterplan. Furthermore, other options around the edge of Stratford, such as the remainder of the Broad Location B.26 and land to the west of Stratford would have greater heritage impacts that Land at Clopton Quarter, for example, harm to the setting of Anne Hathaway’s Cottage. Containing growth to the land under Davidsons control will also prevent encroachment towards Tiddington; the current Broad Location for Growth in this area for up to 2,000 units will result in unacceptable heritage and environmental impacts and will risk a sense of coalescence towards Tiddington, however Land at Clopton Quarter will not result in these impacts and will deliver 700 valuable units to Stratford. In addition to the site being suitable for development in itself, it is also important to highlight that it is the only logical location for further growth at Stratford, and Stratford must take some growth. Land to the west / north west is designated as Green Belt too, however this area has no defensible boundaries and the release of this Green Belt land would result in unrestricted sprawl into the open countryside and it is severed from Stratford-Upon-Avon by the A46, meaning that residents would be separated with no permeability into the town. This location is also further from Stratford than Clopton Quarter, meaning it is a less sustainable option. Whilst the land to the southwest / south / southeast is not designated as Green Belt, these areas bring their own problems in delivering sustainable development in Stratford. Land to the south of the racecourse is designated as Flood Risk Zone 3, and so would not be suitable. Any development towards Long Marston as part of a new settlement and any further development off Banbury Road / the A3400 to the southwest of Stratford would be reliant on the completion of the South West Relief Road. This road was rejected for Housing Infrastructure Fund (HIF) funding and whilst the Cala scheme has contributed £45million towards the road, there is a funding gap of £86million with no clear delivery mechanism. Without this road further development will create chronic traffic problems in the centre of Stratford as the only way to join the A46 would be to use Bridge Street / Bridge Foot. Traffic along this route would be increased to an unacceptable level. Any further development to the west would be further away from the centre of Stratford and would thus be less sustainable. It would also bring unacceptable heritage impact to Anne Hathaway’s Cottage and the surrounding area. Further development to the northwest would also be too detached from Stratford, leading to unsustainable development and an over-reliance on the car. In conclusion, the site is acceptable in heritage terms and is a logical location for growth considering that the other locations around the edge of Stratford are not suitable and will lead to unacceptable highway impacts. We therefore request that Land at Clopton Quarter is considered in isolation, excluding the remainder of the potential Broad Location for growth, as a suitable residential allocation within the South Warwickshire Local Plan.

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Q-S4.1 - Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, the main delivery mechanism for the growth strategy should be growth at existing settlements in order to not rely solely on new settlements. The potential for growth at Stratford is supported as it is already recognised as one of the most sustainable settlements within the consultation papers and within existing policy. Land at Clopton Quarter lies adjacent to Stratford and adjoins the A46. It is a highly sustainable location for new residential growth and will bring a host of benefits including: - A leading example of a 20-minute neighbourhood by virtue of its sustainable location. - 700 units, including affordable housing. - 40% of the site designated as multi-functional green / blue infrastructure (14ha) - Biodiversity net gain and ecological enhancement. - Restoration of the Vale Orchard landscape through new orchard planting with native fruit trees. - A new, mixed use pedestrian gateway into the Welcombe Hills Country Park. - Infrastructure improvements to the highway network. Q-S5.2 - Do you think new settlements should be part of the overall strategy? We remain cautious and advise against the allocation of new settlements to the extent that it would result in an over-reliance on them for the delivery of housing in the short – medium term. Other sites such as land at Clopton Quarter will be able to come forward quicker and would ensure a buffer should any new settlements fail to deliver, as they often do. Realistic delivery rates should be considered. There are numerous examples of where plan have failed because of the inclusion of new settlements (for example, Uttlesford and North Essex), therefore we oppose new settlements. Any development towards Long Marston as part of a new settlement and any further development off Banbury Road / the A3400 to the southwest of Stratford would be reliant on the completion of the Southwest Relief Road. This road was rejected for Housing Infrastructure Fund (HIF) funding and whilst the Cala scheme has contributed £45million towards the road, there is a funding gap of £86million with no clear delivery mechanism. Without this road further development will create chronic traffic problems in the centre of Stratford as the only way to join the A46 would be to use Bridge Street / Bridge Foot. Traffic along this route would be increased to an unacceptable level. Q-S5.3 - In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? We have no objection in principle to rail corridors being the preferred approach to identifying potential locations for growth and Land at Clopton Quarter would fit with this growth strategy. Land at Clopton Quarter to the northeast of Stratford, south of the A46 would suitably fit with a rail-based growth strategy given that it is in close proximity to the Stratford-upon-Avon parkway both by car but more importantly by pedestrian and cycle connections being a 10-minute walk from the centre of the site. Our Vision Document at Appendix 2 shows the creation of pedestrian and cycle routes to the A46 and through to Birmingham Road towards the parkway. Q-S7.2 - For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 1) Option 1: Rail Corridors 2) Option 2: Sustainable Travel 3) Option 3: Economy 4) Option 4: Sustainable Travel and Economy 5) Option 5: Dispersed All growth strategy options include growth at Stratford, therefore in principle we agree that growth should be accommodated at Stratford, however we disagree with the proposed growth location shown in orange to the northwest of Stratford for each option. The orange shading showing the growth location at Stratford for each growth location should include growth at the northeast of Stratford and include Land at Clopton Quarter. The reasons for this are set out earlier in this response at our answer to question Q-S4.2. QS9 - Please select the option which is most appropriate for South Warwickshire: 1) Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. 2) Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. Option S9b is preferred. We welcome a review of settlement boundaries where relevant in order to accommodate the strategic growth at this Part 1 stage and to assist with the smaller scale allocations to come forward within the Part 2 plan.

No

It is recognised that the Statistics Regulator and ONS accept that there have been issues with estimating and projecting the population in Coventry and thus it is the Council’s intention to move away from the Standard Method 2014-based household projections and instead use a trend-based projection which takes account of the initial 2021 Census data releases and applies more up-to-date assumptions about fertility, mortality and household formation rates. We do not consider that an alternative approach has been robustly evidenced and exceptional circumstances for this have not been set out. We caution against deviating from the Standard Method as this approach can only be used in exceptional circumstances, and it will be heavily scrutinised at Examination. A lower figure than the Standard Method must have robust evidence to show the figure is based on realistic assumptions of demographic growth and that there are exceptional local circumstances to justify the approach. This has not been demonstrated. This alternative method results in a reduction in the overall housing need for South Warwickshire from 5,554 dwellings per annum to 4,906 dwellings per annum; a reduction of 648 dwellings. Whilst we understand the reasoning behind applying this lower figure, ideally the 2014 projections should continue to be used. If an alternative method is absolutely necessary, a buffer of at least 10% should be added to the identified local housing need in order to ensure choice and competition in the market and to safeguard against any shortfall in the delivery of housing over the plan period. Therefore, the Local Housing Need should be at least 5,396 dwellings per annum. Whatever the housing need, it cannot fully be met on brownfield and greenfield sites so it will be necessary for Green Belt sites such as Clopton Quarter to be released to meet the housing need. This was clearly demonstrated at a previous workshop with ‘Lego houses’ hosted by the South Warks Local Plan team.

The delivery of affordable housing is, for the most part, via allocated and windfall sites. If the housing requirement is reduced, so too will affordable delivery. And affordability ratios in Warwickshire are substantial. The best way therefore to significantly increase the supply of affordable housing is to allocate greenfield sites, including the release of Green Belt, for 10+ units across the District. Non-brownfield sites have fewer viability and deliverability issues than brownfield sites and are therefore often capable of delivering a policy compliant level of affordable housing, unless site specific constraints such as the need to ground large overhead powerlines indicates otherwise.

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