Issue and Options 2023
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New searchQ-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why Lone Star Land Ltd supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in July 2016 and September 2017 respectively. The Vision and Strategic Objectives will set the foundation for the development of policies that will shape the growth and future of South Warwickshire and basing them on a sound set of objectives will ensure that both Councils are able to deliver aspirations across the full range of services which they provide in a comprehensive and coherent manner. A sound set of Objectives will allow the Local Plan to fulfil the requirements of NPPF paragraph 20 by providing for, inter alia: housing development plus appropriate infrastructure and the conservation and enhancement of the environment in an effective manner. Concurrently, it will also ensure that planning combines with the Councils other delivery partners to deliver the Vision and Strategic Objectives outlined within the plan. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those difference must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the South Warwickshire Local Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Lone Star Land Ltd supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie into the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. The Vision places significant emphasis on responding to the ‘climate emergency’. This principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions, but it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs within the plan period.
Issue I1: Sustainability Appraisal Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. To support the Issue and Options consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA: source: Table 2.1, Sustainability Appraisal, November 2022 The site assessments undertaken within Appendix D of the SA assess a general area rather than specific parcels which have been promoted. It is acknowledged that these areas will evolve into more defined spatial areas through the plan making process which will allow for more detailed assessments of the sites to take place. Lone Star Land Ltd support the SA Framework which has evolved from the thirteen SA objectives and its associated decision-making criteria. It is considered that the objectives address all relevant subject areas which need to be covered within the South Warwickshire Local Plan. It is considered that the overall scoring and assessment within the SA should provide further clarity and consistency in respect of the overall assessment and proposed mitigation matters to address these issues. For example, New Settlement site F2 has scored the lowest (Major Adverse Impact) for landscape sensitivity, but has not for landscape character, moreover the site is not under any landscape designations. The SA acknowledges that the impact of a new settlement in this area could be mitigated through design and masterplanning intentions for the New Settlement Locations. This could be considered through the assumption that a principle for 40% of greenspace provision within these locations will be followed and therefore could be mitigated. Furthermore, the SA considers that this level of greenspace provision should help to provide good scope for design solutions that deliver design led mitigation that can avoid and reduce impacts on changing character and views. Therefore, it is unclear why future mitigation measures and provisions to address these potential issues have not been taken into consideration within its wider assessment. Table 2.15 of the SA provides a summary of the mitigation hierarchy used which provides limited consideration and acknowledgement of potential mitigation methods through either design or through infrastructure provision need to be addressed. Within Chapter 6 (The 7 New Settlement Locations) of the SA it is noted within Figure 6.1 theProposed New Settlement Site F2 is labelled as Deppers Hill. However, within the Issues and Options Document the site is labelled as Deppers Bridge. Therefore, it is advised that the labelling of Proposed New Settlement Site F2 is amended to Deppers Bridge for consistency with the Issues and Options document and supporting evidence going forward in the evolving plan making process.
Q-I2: Please select the option which is most appropriate for South Warwickshire: Option I2a: Set out infrastructure requirements for all scales, types, and location of development Option I2b: Focus on strategic infrastructure relating specifically to the growth strategy It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for utilise both approaches in respect of infrastructure to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: Option I3a: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan Option I3b: Each District to produce its own Levy It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Issue I5: Viability and Deliverability Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage. As intimated at NPPF para 58. Lone Star Land are in the process of collating a robust evidence base to demonstrate a sufficient level of confidence that land at Deppers Bridge within site F2 can come forward and deliver all that is required of them in terms of necessary infrastructure provision for a New Settlement. This includes the provision of a railway station on the existing Chiltern Line, a link road, diverting traffic around Bishops Itchington, an enhanced sustainable route to Southam and provide the necessary social, health and education infrastructure (in the form of new primary and secondary schools) within the site. It is acknowledged that the Council will be publishing an Infrastructure Delivery Strategy and associated viability assessments which will be undertaken as the Local Plan progresses to ensure that what is put forward as a preferred development strategy is both deliverable and viable. It is important that key stakeholders (such as Transportation and Health) are fully engaged in the production of that evidence base, with a clear indication of agreed costs to be borne by each of the major allocations, as part of delivering the wider IDP objectives.
Growth at existing settlements across the South Warwickshire Local Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. In order to meet the requirements for growth over the plan period the South Warwickshire Local Plan will need to demonstrate a balance of growth within existing settlements whilst also taking into account the wider constraints of the district area and the need for the provision of infrastructure that larger scale sites may be able to assist in addressing more appropriately. There is greater opportunity to provide and deliver strategic infrastructure within larger scale sites, for example within new settlements, which development within existing settlementsand smaller scale developments cannot feasibly provide.
Within the Issues and Options document Table 5 show the estimated emissions for new settlements and the associated growth options. Growth Option 4 - Sustainable Travel & Economy which includes site F2, performs better in terms of reduced carbon emissions overall. Lone Star Land Ltd consider that further work will need to be undertaken in respect of emissions modelling for New Settlements. It is unclear how the estimated emissions both cumulatively and annual in 2050 lack any variation in emission estimations between the proposed new settlement site locations and their growth option scenarios. The provision of a new railway station and associated infrastructure which site F2 has the scope to accommodate, alongside the delivery of a comprehensive and coherent network of internal routes for pedestrians and cyclists together with new walking/ cycling infrastructure. This would encourage future residents and users to utilise a wider range and more sustainable forms of transport, reducing the need to travel to meet daily needs, seeking to reduce transport-related emissions and would support the concept of 20-minute neighbourhoods. Paragraph 105 of the NPPF states that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health.
This approach is supported, the Joint Local Plan seeks to reduce the need to travel to meet daily needs in order to reduce emissions and the overall impact on climate change. The modelling within Table 5 of the Local Plan demonstrates that Growth Option 4 (Sustainable Travel & Economy) would have an estimated lower cumulative level of emissions in and a lower level of annual emissions. Lone Star Land Ltd support utilisation of railway corridors for future development and growth with the provision of new infrastructure to facilitate development in sustainable locations and enable greater usage of sustainable modes of transport in South Warwickshire.
It is apparent that growth will have an impact on emissions. Growth in areas which have the provision to accommodate sustainable transport infrastructure would assist in reduction of car journeys undertaken by residents and users, would therefore have the potential to have impact in reducing emission levels. The SA acknowledges that pollution manifests cumulatively rather than at the project scale and in this respect all Growth Options will have a bearing on diffuse pollution associated with development. Air quality is likely to improve from any option that promotes sustainable transport such as Options 1 and 2. Reducing the need to travel by locating employment close to residential areas may also assist in this regard.
Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes - The Joint Local Plan should consider potential new settlement locations as part of a broad strategy of growth across the Plan area. New settlements can assist in the delivery strategic infrastructure which have a positive have a social, economic and environmental impact. Option F2 provides the opportunity for a new settlement in an area broadly to the southwest of Southam and within proximity of the settlements of Harbury and Bishops Itchington. Land at Deppers Bridge (see Site Concept Plan at Appendix 1) could deliver development in this area that would assist in the delivery of key infrastructure within the site creating a New Settlement. This includes the provision of a railway station on the existing Chiltern Line, a link road, diverting traffic around Bishops Itchington and provide the necessary social, health and education infrastructure (in the form of new primary and secondary schools) within the site.New settlements provide the opportunity to deliver infrastructure at scale, provide new services and facilities and in doing so help to create more sustainable communities. They can do this in a way which is not achievable through reliance solely on a strategy of dispersal, where the necessary critical mass of population and funding can be secured to support such strategic level investment. Additionally, the provision of new transport infrastructure, such as a railway station, may also lead to an enhancement of the levels of sustainable access to key services and facilities for hinterland rural communities. Rural villages and settlements, where there is a lack of walking, cycling and public transport connections and where small or medium-scale growth is unlikely to improve provision of key services and facilities or transport infrastructure, it might not be appropriate, for sustainability reasons, to consider growth through the Local Plan. This is of particular relevance to the plan area of South Warwickshire which has historically comprised of dispersed rural settlements. Moreover, in the SA considerations of proposed new settlement areas the F2 location performs the same as all other current options, with the exception of flood risk and landscape matters which it is acknowledged within the SA these issues could be mitigated. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire. The 5 no. spatial options for growth set out in the Issues and Options document have been refined from the 7 no, presented in the 2021 Scoping and Call for Sites consultation. The Councils’ Topis Paper ‘Evolving the Spatial Growth Options – the Story so Far’ notes that no one option presented at the previous stages of the Plan was overwhelmingly preferred. Of the options now presented in the Issues and Options, apart from Option 5: Dispersed, the other four options perform broadly similarly to each other in the SA (Table 7.1) suggesting no one option may have significantly more or less impact than any of the others when considered against the SA Framework. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. However, as the emerging evidence demonstrates, in order to provide necessary levels of infrastructure within the two districts, there will be a need for a new settlement to assist in the delivery of housing and strategic infrastructure within the plan period. The Plan area has a current pattern of development that varies across its two administrative areas. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a significant proportion of development. By necessity, the future development strategy for the plan area will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. Commentary on Options By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66-year supply of housing. Land from other sources, such as through the allocation of new settlements, will therefore be required and it is important that all options are considered in taking the Plan forward. The Strategy may need to facilitate a combination of the 5 no. options presented, where different growth options should be tested as part of the ongoing Local Plan preparation and SA process to ensure all reasonable alternatives are considered. This will require a careful consideration of all of the options, including growth at existing main settlements, some growth at new settlement locations/s on the rail lines, growth at smaller existing settlements, proximity to services and jobs, and availability of infrastructure or opportunities for infrastructure delivery. Q-S9: Please select the option which is most appropriate for South Warwickshire Option There will be a need to maintain established settlement boundaries identified within the currently adopted local plans as a minimum to accommodate development that is of an appropriate and sustainable scale in relation to these settlements, where appropriate within the plan period. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. Beyond this, to be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. It is considered that a review of settlement boundaries may be an appropriate approachfor the Joint Local Plan. Where the Plan seeks to allocate land for development, especially when considering the provision of a strategic new settlement, it would be necessary to undertake a review of settlement boundaries as part of the proposed site allocation. For example, land at Deppers Bridge plus the existing settlements to the northwest and south could potentially be defined by a settlement boundary which relates to their strategic function in delivering growth and development. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire It is noted that within Figure 12 of the Issues and Options document that New Settlement Potential Location A1 is labelled as Henley in Arden. However, when reviewing the locationof the proposed allocation area it is apparent that the proposed allocation is sited closer to the existing settlement Tanworth in Arden and therefore lacks clarity in respect of the location of this new settlement proposal. The assessment of site A1 within Appendix D of the Sustainability Appraisal, specifically Figure D.2.1 demonstrates that the general area for the proposed allocation is located to the west of Tanworth in Arden. Therefore, we would advise that going forward this allocation proposal is renamed to reflect its accurate geographic location within South Warwickshire.
Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. The Planning Practice Guidance (PPG) (para 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Housing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the South Warwickshire Local Plan area. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle.The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. It is noted that the HEDNA has modelled new demographic projections which take account of the initial Census data releases, and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions The new trend-based projections point to a need for 4,906 dwellings annually across the sub-region which is Standard Method figure due to the recognised issues with population data which have informed previous projections for Coventry. The trend-based figures, which equate to an overall housing need across the South Warwickshire Local Plan area of 1,679 dwellings per annum is supported in principle. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now and will continue to exist in the future. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix 3) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear.” It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted BirminghamDevelopment Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed ainto the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further.
