Issue and Options 2023

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Q-B3: Please select the option which is most appropriate for South Warwickshire Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no grounding in national policy, as they are not necessary, not consistent with national policy and are therefore not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas." The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land…" In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. If a specific policy is to be proposed for the emerging Local Plan then it should be fully evidenced by information to demonstrate that it is justified and does not unduly prevent sustainable development from coming forward in accordance with relevant considerations regarding the NPPF and Development Plan. Given the rural nature of both districts within the Plan there will be development proposals and allocations where there will be a loss of some agricultural land. In respect of the deliveryof new settlements there is likely to be loss of some BMV agricultural land due to the scale of the proposals and the siting of the proposed new settlement locations. The location of BMV land should be recognised to inform choices in the location of development proposals but the wider sustainability benefits of developing certain areas of BMV land, particularly for strategic developments such as new settlements may significantly outweigh its loss. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.

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There is no objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1.

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These representations are made by Pegasus Group, on behalf of a Lone Star Land Ltd, in response to the South Warwickshire Local Plan Issues and Options consultation. The representations have had regard to the published consultation document and questions set out therein, accompanying published evidence and the national and local planning policy context. They provide in-principle support for the Council's spatial approach to their emerging Local Plan and, in particular, support for the identification of large-scale strategic sites and for a positive allocation of land for a new settlement at Deppers Bridge for a residential-led development. Whilst it is acknowledged that both Stratford Upon Avon and Warwick District Council identify there is further work to do on housing numbers, these representations seek to make some detailed comments on that subject. These are intended in a positive manner, and we would welcome the opportunity to make further detailed comments on this matter at the appropriate time. These representations fully support the proposed identification of a new settlement strategy to deliver housing and infrastructure to accommodate growth at scale. Given the quantum of development which will be needed in South Warwickshire, a dispersed growth option which seeks to allocate housing across existing towns and villages, relying on existing infrastructure would quickly overwhelm those settlements and their social infrastructure. A strategy which seeks to rely on large scale strategic sites that provide the opportunity to deliver infrastructure-led development alongside housing growth in new settlements that can contain and consume their own needs, is a more sustainable and effective way of addressing the development requirements of South Warwickshire. This representation considers that land at Deppers Bridge forming site F2 of the new settlement sites within the Issues and Options document demonstrates its suitability as strategic new settlement site to accommodate future growth in South Warwickshire. It provides a sustainable opportunity to deliver growth and to meet future needs and the requirements of the emerging South Warwickshire Local Plan. The identification and delivery of a new settlement at Deppers Bridge would assist in delivering the objectives of the South Warwickshire Local Plan. Lone Star Land Ltd are committed to the delivery of necessary supporting infrastructure. Technical work in a number of disciplines is underway and a full programme of engagement will be undertaken with relevant stakeholders. Emerging work is being undertaken to fully evidence the delivery and feasibility to facilitate the creation of a new railway station at Deppers Bridge which would be one of the many benefits crucial to creating a new sustainable settlement in this location. Lone Star Land welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site to assist in the accurate assessment of the site, this can be provided upon request.