Issue and Options 2023

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Minerals WCC note that minerals policy for the South Warwickshire area is contained within the Warwickshire Minerals Local Plan 2018-2032, adopted in July 2022. Question B7 asks “Do you agree that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP?”. Whilst WCC recognises that unnecessary duplication of policies should be avoided, we support the SWLP giving appropriate prominence to the need for mineral safeguarding. Site allocations should be informed by mineral safeguarding, and site-specific policies within the SWLP should highlight the need for any further mineral safeguarding that may eb required at planning application stage.

South Warwickshire Local Plan: Issues and Options consultation Worcestershire County Council (WCC) welcomes the opportunity to comment on the above consultation and looks forward to ongoing engagement between our authorities throughout the development of the South Warwickshire Local Plan, be it through the Duty to Co-operate or any replacement mechanism. WCC will be particularly interested in the potential infrastructure implications of growth options, including new settlements and expansions of existing settlements. Set out below are some specific comments relating to minerals, waste, transport and education.

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Waste Waste policy is found within the Warwickshire Waste Core Strategy Local Plan, adopted in July 2013. Notwithstanding this, the South Warwickshire Local Plan has an important role to play in reducing waste and moving waste up the ‘waste hierarchy’ (prevention; preparing for reuse; recycling; other recovery; disposal). WCC supports the use of whole life-cycle emissions assessments and embodied emissions reduction targets, as this could help to reduce waste. However, we consider that more evidence is required to inform the particular policy options considered under issue C6.

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Transport WCC is the Local Highway Authority for Worcestershire and is responsible for operating and maintaining the county’s local road network, both in respect of its current activities and needs, as well as its long-term operation and integrity. We are interested in the potential traffic and transport implications of development site proposals and/or policies coming forward through the Local Plan process and need to ensure these are fully assessed and understood through the plan-making stage(s). We note that this consultation follows the Scoping and Call for Sites consultation in 2021. It is proposed that the South Warwickshire Local Plan will be developed as two distinct parts. Part 1 will provide the overall strategy for the pattern, scale and design quality of places within South Warwickshire and make sufficient provision for housing, employment, retail and leisure facilities, along with infrastructure. Part 2 will provide more detailed planning policies and detailed policies for specific areas and types of development, which could include allocating sites and the provision of infrastructure at a local level. As such, we understand that this Part 1 consultation seeks views on issues and options primarily relating to the emerging Plan’s strategic vision and objectives, growth strategy and strategic policies. Worcestershire’s highway network adjoins the emerging plan area at the A46 north of Evesham, the A422 between Worcester and Alcester and the B4088 between South Worcestershire and South Warwickshire. Relevant plan-making policy – Transport Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF). The NPPF sets out that plans should be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and statutory consultees (para 16). Strategic policy-making authorities should collaborate to identify the relevant strategic matters which they need to address in their plans. They should also engage with their local communities and relevant bodies including county councils (para 25). Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary (para 26).In order to demonstrate effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these (para 27). Transport issues should be considered from the earliest stages of planmaking and development proposals so that the potential impact of development on transport networks can be addressed (para 104).The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes (para 105).Planning policies should be prepared with the active involvement of highway authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned (para 106). Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use (para 124). In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe (para 111). Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (including transport). Such policies should not undermine the deliverability of the plan (para 34).The transport strategy to support the plan will need to be based on a robust evidence base. As a minimum, in order for the transport evidence base to satisfy the requirements of NPPF, it is necessary to establish: • The transport impacts of the development allocations. • The improvements necessary to ensure that the impacts are not severe. • Any land required for the delivery of the necessary improvements. • The cost of the necessary improvements. • Any other deliverability constraints. The emerging South Warwickshire Local Plan The South Warwickshire Local Plan (SWLP) will plan for housing and jobs growth across the Stratford-upon-Avon District Council and Warwick District Council areas for the period up to 2050. As the SWLP is developed, it is imperative that any necessary improvements to Worcestershire’s transport network required to successfully deliver sustainable growth aspirations in Stratford-upon-Avon and Warwick are identified, as set out in Government policy, taking account of strategic growth emerging through the South Worcestershire Development Plan Review (SWDPR). Given that the SWLP is proposed to be developed in two distinct parts, Worcestershire County Council Highways would welcome further information regarding the intended approach to preparing the necessary transport evidence base and associated infrastructure strategy. The SWLP programme anticipates adoption by the end of 2025 and WCC looks forward to further engagement from the SWLP authorities to help inform the supporting highways and transport evidence base as it is developed. Emerging plan – Part 1 Once Part 1 of the SWLP is fully adopted, it will replace the existing strategic policies of the Stratford-on-Avon District Council Core Strategy and Warwick District Council Local Plan. Vision and objectives The vision and objectives set the framework for the growth strategy and strategic policies to 2050. We welcome the inclusion of an overarching principle within the vision which looks to deliver well-connected places that are accessible and promote active travel. We are also pleased to note that the proposed strategic objectives specifically reference sustainable transport and the timely delivery of infrastructure, particularly: Providing infrastructure in the right place at the right time - Ensuring that the infrastructure needed to support the growth in new homes and jobs is secured through new development, and is provided when people need it; and • Connecting people to places - Increasing and improving access to sustainable and active travel options that connect people to centres, jobs, education, cultural facilities, green spaces and the countryside. The importance of safe, reliable and efficient highway links and transport services is a critical part of realising a number of the other objectives (for example Contributing towards Net Zero Carbon targets and Developing opportunities for jobs). Given the proximity of the SWLP area to Worcestershire and the key highway links connecting to Stratford-upon-Avon, there are potential cross-boundary movements utilising Worcestershire’s transport network, particularly the A46, A44 and A422. It is therefore suggested that a specific objective relating to the safe operation and efficient performance of the transport network would also be appropriate. This would mean that the impact of development on the transport network, together with the deliverability/viability of necessary transport interventions, would be key considerations during the site selection process and development of a preferred strategy. Such an objective would also help the assessment of individual development impacts when considering the nature of the proposed mitigating infrastructure provision through the planning process. Growth strategy WCC Transport notes that South Warwickshire is currently considered to have a dispersed settlement pattern and that the SWLP will seek to maximise the capacity of existing settlements, in combination with other options such as new settlements, to meet its development needs to 2050. The SWLP Part 1 consultation is seeking views in respect of five alternative growth strategy options: • Option 1: Rail Corridors • Option 2: Sustainable Travel (rail and bus corridors) • Option 3: Economy (locating new housing near to existing jobs and potential new job locations) • Option 4: Sustainable travel and economy (hybrid of option 2 and 3) • Option 5: Dispersed (following existing settlement pattern). WCC Transport considers that focussing housing growth and development at sites that are located in proximity to public transport corridors/services and employment opportunities, should offer the best opportunities for reducing the need to travel by private car. WCC Highways notes that strategic growth at Long Marston Airfield and Meon Vale is included in the indicative list of development locations for each of the five options, and that growth at Alcester is included within options 2, 3, 4 and 5. Strategic growth in these locations will be of particular interest to WCC Transport and we would expect that the potential traffic and transport implications of proposed development at Long Marston Airfield/Meon Vale, on the A46 and B4088 within Worcestershire and on rail services and stations in Worcestershire, would be considered as part of the supporting transport assessment/evidence base. WCC Transport notes that there would be a number of challenges for identifying and delivering necessary highways and transport infrastructure with a ‘Dispersed’ development strategy. As the scale of any one allocation would be limited, with development spread across a greater number of locations, there would be less opportunity to achieve the necessary scale of development to give confidence that appropriate mitigation for the local and strategic transport networks could be provided to address the overall cumulative impact of the SWLP. It is considered that the potential size and location of the allocations could be insufficient to both command and hence provide (through provision of funding) the necessary infrastructure to mitigate the cumulative impact of the proposed new development. Furthermore, the provision of more sustainable alternatives to the private car would be challenging due to the limited scale and locations of the dispersed development allocations. In terms of location, employment development often contributes significantly to peak-hour traffic, and hence there can be challenges to accommodating high levels of trip demand, which may only exist for limited periods of the day on the local road network, particularly locally strategic routes such as the A46, A422 and B4088. The attraction to business of locating in highly accessible locations is recognised, and we are aware that for many businesses, close proximity to strategic routes is essential.We note that the Core Opportunity Area identified to meet the Plan’s economic needs includes Long Marston/Meon Vale and the Quinton Rail Technology Centre as well as encompassing Stratford-upon-Avon and Alcester. When considering the location and associated supporting infrastructure for new employment areas, any existing available capacity on locally strategic routes including the A46 and A422 should not be considered as an alternative to providing local improvements to the sustainable modes network (i.e. pedestrian, cycle and bus and rail networks,) serving the proposed development areas. When considering potential site allocations and associated supporting infrastructure for new growth sites in the SWLP area, WCC Highways requests that consideration is given to the planning of adequate transport infrastructure, including any necessary highway capacity improvements in Worcestershire to provide for cross-boundary movements. Strategic policies Chapter 10 ‘A Well-connected South Warwickshire’ primarily outlines the proposed strategic transport policy direction for the emerging Plan. WCC Transport welcomes the inclusion of policy principles that promote the sustainable location of development and facilitate self-containment (20 Minute Neighbourhoods) and that promote active travel and sustainable transport (Sustainable transport accessibility across South Warwickshire). We note that whilst the emerging Plan seeks to prioritise sustainable and active travel, it is acknowledged that people will still need to travel by car, particularly for commuting purposes, and that road-based travel and freight will still be critical for many commercial and employment development sites. WCC Transport considers that it may be beneficial to include specific wording within any overarching/strategic transport policy, which requires new development proposals to assess their impact on the capacity of the transport network and which positively supports proposals that include mitigation against any unacceptable road safety or severe congestion impacts.WCC Transport would also welcome further clarification regarding the proposed approach to identifying infrastructure requirements and associated delivery mechanisms. Chapter 4 suggests that two potential approaches are being considered for the emerging Plan: 1. That the SWLP Part 1 sets out infrastructure requirements for all scales, types and location of development, so that requirements would be established which apply equally across South Warwickshire; or Focus on the strategic infrastructure relating specifically to the growth strategy. In this option, only focussing 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. WCC Transport understands that Part 1 of the SWLP will identify the strategic transport vision and infrastructure plan required to support the delivery of the preferred growth strategy (option 2), with the more detailed allocations and development management policies developed as part of SWLP Part 2 (option 1) aligned to the delivery of the strategic vision/infrastructure plan. Transport evidence base We recognise that the policies contained within SWLP Part 1 are intended to be regarded as ‘strategic’, in that they will provide the framework for more detailed policies for local site allocations, infrastructure provision and development management to be developed in SWLP Part 2. However, we note that the SWLP Part 1 is proposed to provide the broad development locations and quantum of development in those areas, along with the infrastructure necessary to support the successful delivery of the growth strategy. We are concerned that the emerging growth strategy may result in potential cross-boundary impacts on Worcestershire’s highway and transport network. WCC Transport would therefore like to take this opportunity to re-emphasise the importance of a co-operative approach to plan-making. We note that a Transport Assessment is currently being undertaken to inform later stages of the Plan. We would welcome engagement from district councils at the earliest opportunity to better understand the scope and methodology of the Plan’s transport appraisal, and anticipate that this would also take account of the strategic development emerging through the SWDPR. Next steps WCC requests that as the SWLP is progressed, we continue to be engaged by Stratford-upon-Avon District Council and Warwick District Council to help determine any potential impacts on Worcestershire’s transport network and identify any necessary infrastructure improvements to be included within the Infrastructure Delivery Plan. We trust that our response will be helpful and assist you with preparing your Local Plan. We look forward to working with you through the remainder of the plan-making process.

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Education The provision of education facilities should be a major priority when delivering new housing. Ensuring families moving into new housing can access local education places is crucial to ensuring sustainable development, supporting active travel, and building a community early on. The Local Plan should give great consideration to prioritising the early delivery of new school infrastructure where required and should give due consideration to the longterm sustainability of the community