Issue and Options 2023

No

On reading through the I&O and supporting documentation the emerging approach appears to focus on large-scale development(s) and the concentration of development and growth. This appears to be predicated on tackling climate change and carbon reduction yet the evidence supporting that approach is high level and shows there is relatively little difference in performance between the high-level options. The inevitable consequence of this approach is that it too readily dismisses the potential benefits of more dispersed growth which could reduce the number of larger scale developments required to meet needs as well as help spread the benefits of growth more widely, as well as meeting more nuanced needs and demands. The preparation of the local plan in separate Parts 1 and 2 reinforces this outcome because any potential development sites below the scale of strategic allocations and carrying forward of existing allocations and commitments seem to be bumped into Stage 2, ‘some years down the line’. This is illogical. The final version of the local plan is likely to be, and probably should be, an amalgam of several approaches, so it is critical that the shape of the emerging plan is not unduly restricted at this early stage in the process. In respect of climate change and carbon reduction it is suggested that the approach is too heavily based on the benefits of concentration which it is believed are becoming increasingly outdated through, as examples, the rapid shift to zero carbon vehicles and an increased propensity to work from home. Unfortunately, there is a significant risk that the approach in the emerging plan is potentially excluding reasonable options from proper consideration. We support V1, the overall vision as drafted in the consultation document, but wish to stress that a more dispersed pattern of development involving a smaller number of large-scale development could provide at least as good, if not better performance against the overarching principles as set out. In relation to V2, Vision for places, we believe it is fundamental that Part 1 of the plan should set out the scale and pattern of development across the plan area, establishing levels of growth into all local areas and this should take account of a reasonable level of dispersed growth and aspirations for improving services and facilities in smaller settlements and groups of small settlements for the reasons set out above. If Neighbourhood Development Plans are to be part of delivery, then it is important that realistic levels of growth, taking account of realistic opportunities identified through the Call for Sites are established. It would also be important that delays in bringing forward Neighbourhood Development Plans should not be used to delay the bringing forward of otherwise suitable development opportunities. In relation to the strategic objectives, while we are generally supportive, we have the following observations: Providing infrastructure in the right places: as drafted this appears to suggest the plan is to be led by infrastructure provision whereas the opposite should also apply. The provision of new or improved infrastructure should be plan-led. Developing opportunities for jobs: It is important that the plan provides a framework encouraging growth of businesses of all types and sizes and does not unduly focus on the needs of big business. Delivering homes that meet the needs of all our communities: This objective should also refer to market demand and aspirations as well as needs. This is more than simply the numbers of new homes. Enriching the tourism potential: This objective should be clear that supporting and enhancing tourist infrastructure will be supported.

Reasonable Alternatives: The reasonable alternatives do not consider developments less than 50 dwellings. This appears to be an arbitrary and an unreasonably high threshold.

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Q-I2: Option I2a: Set out infrastructure requirements for all scales, types and location of development This is the approach we would favour. Integral to this would be consideration of the potential to accommodate growth where spare infrastructure capacity currently exists. Dispersed infrastructure is generally more deliverable and flexible and in many circumstances can be provided more easily and quicker. Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy We would not support this option. This option which appears to favour large-scale development and large-scale infrastructure schemes to support them. A far more considered and balanced approach is required. Q-I3: Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan We would not support this option. Option I3b: Each District Council to produce its own Levy A joint approach would seem to be more logical and supportive of the preparation of the local plan on a joint basis.

Yes

Yes, but this should be subject to continuing review of the appropriateness of the protected schemes. Just because a scheme is safeguarded should not automatically mean that it should have priority in respect of implementation throughout the plan period, nor preclude identification of further schemes should the decision be made to proceed with a two-part plan.

Q-S1: Option S1a: There should be sufficient existing technical evidence already available to identify the corridors. There would also be scope for these to be modified, as necessary as the local plan progresses. If this approach is taken it is important that maps and images are at a scale and have sufficient clarity so that the status of specific land parcels can be distinguished. Option S1b: It seems unlikely that the scope for any reduced synergy would be very significant and, as mentioned above, there is scope to reduce that as the local plan progresses towards adoption. Q-S2: Option S2b would appear to be the most realistic, and achievable option. It is of some concern that the consultation document identifies some of the potential climate change benefits that can arise from intensification while at the same time failing to recognize potential dis-benefits such as adding to congestion in already congested areas and undermining the character and appearance, as well as the attractive of urban areas though over-intensification. In addition, since all development should be carbon-free by 2050 the differential impacts on climate change between different locations should be significantly reduced. The plan appears to be predicated on a principle that development in urban areas is preferable in climate change terms that development elsewhere. This appears to be a principle based on assertion rather than definitive evidence. It could lead to the degradation of attractive urban environments which would be counter-productive. Q-S3.2: These options and the analysis behind them appear somewhat confused and focused towards urban concentration. As highlighted earlier in this response, the evidence to conclusively prove those options are the most sustainable and have the least impact on climate change and CO2 reduction is based more on assertion rather than on conclusive evidence. We also feel that the term 'prioritise’ may not be the most suitable, not least because of its uncertain meaning. Perhaps ‘make best use of’ would be a better terminology. Q-S8.2: A 10 dwelling limit generally seems appropriate although any such limit should also be caveated to enable developments of more than 10 dwellings in exceptional circumstances or where criteria have been met in terms of sustainability and perhaps provision of additional infrastructure, otherwise potential developments of 11-49 dwellings which might be acceptable on all other grounds would have been excluded from the local plan process. Q-S9: The development strategy should enable a proportion of development to come forward outside strategic sites with a capacity of 50 or more dwellings. The scale of small scale dispersed growth should be disaggregated across the plan area to provide the basis for Neighbourhood Development Plans and the review of settlement boundaries where this is necessary. However, it is important that identification of suitable sites is not unduly delayed and the potential identification and release of an appropriate scale of development where sites have been taken through the Call for Sites should not be unduly delayed. Ideally, where it is known that settlement boundaries require amendment then these settlements should, at the very least, be identified in the plan. If, having identified these settlements then it should be accepted that land might be released adjacent to the extant development boundary. This would provide a strong incentive for Neighbourhood Development Plans and or Site Allocation Plans to be put into place. Q-S10: The level and distribution of growth should be clearly set out in the plan to provide a sound basis for Neighbourhood Development Plans.

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The study would appear to potentially over-estimate brownfield capacity because it includes capacity on existing new settlements which could have been greenfield. In addition, the inclusion of windfall capacity does not necessarily take place on brownfield land. The urban capacity title is a little misleading because of these points. The future supply of windfall capacity is not fixed and has potential to be influenced by planning policy. Since windfalls tend to occur on smaller sites this can be an important future resource that can reflect, as examples, market demand, self-build and permitted development (such as Class Q conversions). There is potential for this to be used a deliberate strategic component of future housing land supply. Inclusion of the windfall analysis within the urban capacity study suggests the scope of this source has not been fully considered.

Yes

The local plan is a plan for the whole of the plan area which by definition includes the existing development including settlements of all sizes. This is important because a local plan is for the whole area and new development forms a relatively small proportion of the whole. It is a matter of some concern that that a decision “to maximise the capacity of its existing urban areas in order to meet development needs to 2050” has apparently already been taken. This undermines the consultation by suggesting predetermination of the preferred strategy. The concept of the 20 Minute Neighbourhood (based on a 10 + 10 minute walk there and back) seems rather idealized and not especially effective for a plan area that includes an extensive mix of settlement types across both urban and mainly rural landscapes. There are many smaller settlements and groups of settlements where services could be protected or enhanced through a more dispersed pattern of development and the strategy should allow for a level and distribution of growth that takes account of this. The Connectivity Analysis and Density Analysis have produced a significant amount of information but the extent to which these can help to inform the strategy in the plan is less clear. The landform analysis is clearly helpful in helping demonstrate land where new development should generally be avoided.

The emissions analysis is high level and shows relatively little difference between the options. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. This is because mitigation could be put in-place under each of the options so the contribution each proposal makes overall to the economic, social and environmental strands of sustainable development should be the determining factors and they should stand up, or fall, against the benefits of other options for accommodating growth.