Issue and Options 2023

INTRODUCTION 1.1 Barton Willmore, now Stantec, is instructed by the Church Commissioners for England (‘The Church Commissioners’) to prepare a representation to the South Warwickshire Issues and Options (Regulation 18) Consultation (‘the Local Plan’), including relevant documents within the evidence base. 1.2 This Representation follows the structure of the Local Plan and seeks to respond to the questions posed within the document, where relevant. 1.3 The Church Commissioners have an interest at Land north of Long Marston Airfield, Stratfordupon-Avon, which has previously been submitted as part of the Scoping and first Call for Sites Consultation, which took place between May-June 2021 (Site Ref. ID 333: ‘Land North of Long Marston’). 1.4 Prior to this, the Church Commissioners submitted representations to the Stratford-upon-Avon Strategic Housing Land Availability Assessments (SHLAA) in 2017 and 2018 as site reference LSL.18 – ‘West of Campden Road, Long Marston in the 2019 SHLAA’. 1.5 We are continuing to promote the Site on behalf of the Church Commissioners for allocation in the new South Warwickshire Local Plan Part 1. 1.6 The following supports documents are appended to this Representation: • Vision Document, including Concept Masterplan (Appendix 1) • Highways Note (Appendix 2) • Sustainability Appraisal Review (Appendix 3) 1.7 Land North of Long Marston Airfield has capacity to deliver a strategic residential-led development for up to 2,800 dwellings, including a new primary school, nursery, health centre, extra care facility, retail and community facilities, sports facilities, public open space and other supporting infrastructure, such as mobility hubs. 1.8 This development would form an extension to, and be amalgamated with, the existing Long Marston Airfield Garden Village, which has previously been allocated for a new settlement comprising 3,500 dwellings (2,100 to be delivered within the plan period) with associated infrastructure, services and facilities including new schools, a local centre, open space and recreation provision, and a potential new railway station. 1.9 The Church Commissioners welcomes the opportunity to provide a response to the Local Plan consultation and looks forward to engaging with the Council further in respect of residential matters within South Warwickshire. LAND NORTH OF LONG MARSTON AIRFIELD Site Description and Context Site Description 11.1 The Site measures approximately 138 hectares in size and is located immediately north of the existing allocation at Long Marston Airfield Garden Village. The land and buildings are currently in use as a commercial arable farm. The Site is under the single ownership of the Church Commissioners. 11.2 Current access to the Site is via a lane that crosses east-west, with access points from both the eastern and western boundaries. 11.3 The Site is relatively flat and is understood to be largely free of any significant physical and environmental constraints to future development 4. 11.4 There are no Public Rights of Way (PRoW) running across the Site. Context 11.5 The Site is bound by agricultural land to the north, east and west with associated individual farm buildings (and small scale residential development at Willicote Pastures to the southeast). 11.6 The Site is located nearby the existing villages of Long Marston, Welford-Upon-Avon, Clifford Chambers and Quinton, and approximately 5 miles south-west of Stratford-upon-Avon town. Accordingly, there are a range of services and facilities across each of these settlements, including primary schools, medical centres, post offices, convenience stores, and pubs/ restaurants. 11.7 In addition to existing services, the Site would benefit from being in proximity to services and facilities at Long Marston Airfield Garden Village, including employment land (including a business park), a village centre comprising a range of uses, primary schools, a secondary school, and open space, including parks and amenity space. 11.8 There are several PRoWs in the local area, including surrounding villages, which provide opportunities for wider connections. 11.9 The Site benefits from being well located with regards to transport connectivity. There is an existing bus stop adjacent to Willicote Pastures on Campden Road (B4632) to the east of the Site. This provides access to several bus services (numbers 1, 1A, 2, 2A, 3, and 3A) which link Stratford-upon-Avon to Moreton-in-Marsh. These services run from approximately 7am to 7.30pm, twice an hour, with a slightly reduced service on the weekend and Bank Holidays. 11.10 Stratford-upon-Avon railway station is approximately 5.5 miles from the Site by road, or 4.5 miles via the Greenway, and provides sheltered cycle storage. The station provides frequent connection to a number of key destinations such as Birmingham (2 trains an hour on a weekday) and (via Warwick Parkway or Leamington Spa) to London (2 trains an hour on a weekday) 5. Honeybourne railway station is approximately 7miles south-west of the Site via road and is served by one/ two trains every two hours to London Paddington via Oxford and Reading and a similar frequency of services to Hereford via Worcester. 11.11 The Site is approximately 20 miles from Junction 15 of the M40. This provides connectivity to the strategic highway network. 11.12 As set out in this section, there are several accessible sustainable transport options to local and national destinations. Long Marston Airfield Garden Village 11.13 The Site is directly adjacent to the Long Marston Airfield Garden Village, which is allocated within the adopted Stratford-on-Avon Core Strategy for 3,500 new homes, of which 2,100 are to be delivered within the Plan Period to 2031. 11.14 Of these, 400 dwellings are currently being constructed, having been granted planning permission in 2017. Outline planning application ref: 18/01892/OUT for the remaining 3,100 dwellings is currently pending determination. 11.15 An opportunity exists to further extend the scope of the allocation at Long Marston Airfield through the delivery of The Church Commissioners’ Land to deliver a truly innovative and sustainable new settlement which should be explored in greater detail with the Council and relevant stakeholders. Future development on the Site would closely relate to existing proposals and would represent an appropriate pattern for further development to the meet housing needs. Constraints and Opportunities 11.16 The Site is not located in the Green Belt or the Cotswolds Area of Outstanding Natural Beauty (AONB), which lies approximately 4.5 miles to the south of the Site. The Stratford-on-Avon Core Strategy (adopted July 2016) notes that although views across the Garden Village are afforded from the top of Meon Hill to the south (within the AONB), those from public vantage points, including PRoWs are limited. Whilst specialist landscape work will be required to assess any implications in respect of this Site, it is considered that views are likely to be similar or perhaps less apparent given the Site is to the north of the Garden Village. It is also considered that the landscape context will change as a result of the Garden Village development. 11.17 The majority of the Site is located within Flood Zone 1 with the exception of a limited area of land which falls within Flood Zone 3 in the vicinity of Marchfont Brook which runs along the northern and eastern edges of the Site, and Gran Brook which forms part of the western boundary. No built development is proposed in Flood Zone 3 and instead the development elsewhere will provide opportunities for both Blue and Green Infrastructure enhancements. 11.18 The Site is not subject to any statutory environmental or heritage asset designations. The closest heritage asset is the Grade II listed Wincote Farmhouse which lies approximately 900 metres to the southeast. There are trees and hedgerows on the Site, however these are not considered to be substantial relative to the scale of the Site. 11.19 The Long Marston Greenway runs along the western edge of the Site and provides a pedestrian/ cycle connection with the PRoW network and to Stratford-upon-Avon. It is an approximately 20 minute bike ride to Stratford-upon-Avon from the Site, although it has been previously proposed to re-open the Stratford-Honeybourne Railway Line along with route. Concept Plan • Several iterations of a Concept Plan are included within the Vision Document at Appendix 1 to this Representation, to demonstrate the potential development of the Site. It has sought to build on the opportunities identified in the Vision Document. On this basis, the Concept Masterplan includes the following: • Proposed delivery of approximately 2,800 dwellings • Land for: a) A new 2FE/3FE primary school b) A nursery c) health centre d) extra care facility e) retail and community facilities f) sports facilities g) public open space and h) other supporting infrastructure, such as mobility hubs. • The proposed development seeks to retains the existing hedgerow field pattern. An integrated sustainable drainage strategy utilities existing landscape features along with the Site’s topography to create blue and green corridors, infrastructure, and SuDS areas, most notably to the west of the Site. • Vehicular access from Campden Road (B4632) to the east, with clearly defined routes going westwards through the Site. • Enhancement of surrounding PRoWs and pedestrian/ cycle connections, most notably the Greenway, with an emphasis on linking the Site to the local movement network. • An average density similar to that of the adjacent Airfield proposals has been applied; 35 dwellings per hectare for the developable area, which equates to around 20 dwellings per hectare when the various open space and envisaged SuDS infrastructure etc are incorporated. Applying these principles has led to an indicative capacity of approximately 2,800 dwellings. Highways and Access Access Strategy 11.20 There are no third-party constraints to accessing the Site. The proposed Site access is located on the eastern boundary, off Campden Road (B4632). This is a suitable access point for the development proposed, with a reduced 50mph speed restriction already in place at the point of the proposed site access. Cycling and Walking Strategy 11.21 The Site benefits from being well-located to pedestrian and cycle facilities, most notably the Greenway to the west. This provides local access to nearby villages in addition to Stratfordupon-Avon. It is proposed to connect to these facilities and seek to enhance them where possible. In addition, it is proposed to provide pedestrian/ cycle infrastructure within the Site to encourage use and alleviate any safety concerns. Public Transport Strategy 11.22 As set out above and identified in the Vision Document, the Site is well located with regards to transport connectivity. This includes local bus routes via existing bus routes on Campden Road (B4632) and proximity to Stratford-upon-Avon and Honeybourne train stations. 11.23 We would welcome future discussions with the appropriate stakeholders to agree a strategy to integrate into the local transport network to provide the best possible links for existing and future residents. Flooding and Drainage 11.24 The proposed development, as shown on the Concept Plan, currently proposes no built form in parts of the Site affected by Flood Zone 3. Green-blue infrastructure corridors are proposed to manage surface water flows, providing a connection to the Brooks to the north and west of the Site. This will, inter alia, ensure the sustainable management of surface water, enrich biodiversity, provide amenity value, and enhance water quality throughout the development. 11.25 Furthermore, sustainable drainage systems will be implemented in areas affected by Flood Zone 3 in order to limit surface water flows in addition to providing multifunctional benefits, including green-blue corridors, public open space, and attenuation areas. 11.26 Further technical work in respect of flooding and drainage will be carried out in due course and shared with the Council when finalised. Open Space Network 11.27 As set out within the Vision Document, it is proposed that the Site be divided into separate components through the use of green corridors/ fingers. These will provide pedestrian and cycle routes through the Site connecting to existing connections such as the Greenway, in addition to the adjacent Garden Village development to the south. These are also proposed to accommodate SuDs features, playing fields and significant tree planting, seeking to retain existing trees and hedgerows where possible. 11.28 The majority of the open space is proposed is concentrated on the western part of the Site to create a linear green corridor/ park adjacent to the Greenway. Summary 11.29 This representation has been prepared by Barton Willmore, now Stantec, on behalf of The Church Commissioners for England, in response to the South Warwickshire Local Plan Part 1 consultation. Following the initial promotion of Land North of Long Marston Airfield through the Scoping and first Call for Sites Consultation (May-June 2021), we are continuing to promote the site for allocation in the new Local Plan Part 1. 11.30 The Site is not located in the Green Belt and consequently, there would be no need to argue very special circumstances to justify its development.. The Site is in single ownership and can come forward immediately. 11.31 The Site is capable of delivering approximately 2,800 dwellings based on a similar density strategy to the adjoining Long Marston Airfield Garden Village to the south. The Site’s proposed access is off Campden Road (B4632) and will also seek to include pedestrian and cycle route provision (both within the Site itself) and to connect with the surrounding area including the Greenway, public open space, and SuDS areas. 11.32 The Site is in a sustainable location, directly adjoining the Garden Village to the south which is currently being built out. It is proposed to utilise services and facilities coming forward as part of this development in part, whilst also providing a range of its own amenities and services. 11.33 In line with both Planning Practice Guidance and the NPPF, the Site is deliverable due to it being: • Suitable for development – the Site has no constraints which restrict its development. Whilst parts of the Site are in Flood Zone 3, this has been considered when developing an initial Concept Masterplan. • Available and achievable for development – the Site is within single ownership and can come forward immediately, certainly the first part of the plan period, at least in part due to the potential large scale. In addition, a robust framework could enable the site to come forward holistically alongside adjacent landowners if required.

Nothing chosen

Issue V1: Vision for the Local Plan Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? 2.1 The Church Commissioners broadly supports in principle the Vision set out within Chapter 3 which states ‘The Vision is to meet South Warwickshire’s sustainable development needs to 2050, while responding to the climate emergency. Where appropriate and agreed, this could include unmet need from neighbouring authorities. The Plan will provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.’ 2.2 In particular, The Church Commissioners endorses the support provided by the Vision that the Plan will provide homes, jobs and appropriate infrastructure, in suitable locations, at the right time. The Church Commissioners also supports the recognition of the potential to meet unmet need from neighbouring authorities. However, it is crucial the scale and distribution of this need should be agreed through the plan making process. This Vision should accordingly evolve and become more specific, once the detail surrounding the scale and distribution of the unmet need is established. 2.3 In addition, clarity should also be provided in respect of what is meant by ‘Warwickshire’s sustainable development needs’. This could be achieved by including specific reference to the scale of housing growth required during the Plan period. 2.4 The Church Commissioners supports Strategic Objective 2 (Providing infrastructure in the right place, at the right time) whereby infrastructure is required to support growth in new homes and contribute towards achieving sustainable development. However, whilst the Objective states infrastructure will be secured through new development, additional work is required in terms of the evidence to demonstrate what infrastructure is needed, in what geographical location, timescales for its delivery and sources of funding. 2.5 Strategic Objective 4 (Delivering homes that meets the needs of all our communities) acknowledges the need for further housing within South Warwickshire, and that a variety of house types, mixes and tenures are required to fulfil wider needs, also contributing towards sustainable development. Whilst this is supported by The Church Commissioners, reference should be made to meeting the unmet needs of neighbouring authorities, in order to align with and support the delivery of the Vision. 2.6 Strategic Objective 5 (Contributing towards Net Zero Carbon Targets) seeks to ensure that new development does not cause a net increase in carbon emissions. It proceeds to state that every opportunity should be taken to reduce existing carbon emissions and mitigate against climate harms. Whilst there is a clear and undeniable need to move towards net zero carbon development, this Objective is onerous and the requirement to result in no net increase in carbon emissions is beyond the scope of national policy. It should be made clear that development should reduce carbon emissions where possible, and provide additional mitigation where necessary, in order to contribute towards achieving Carbon Targets. At present, it is unrealistic to state that all new development should not cause a net increase in carbon emissions, and would impact upon development opportunities, restricting both the development of opportunities for jobs (Strategic Objective 3) and Delivering Homes that Meet the Needs of all our communities (Strategic Objective 4). 2.7 Overall, the Councils need to ensure the Strategic Objectives achieve a collaborative approach together to achieve the overall wider Vision and ensure they do not conflict with one another. As such, Strategic Objectives 2 and 5 need to be considered as part of a wider context, such as realistically achieving Strategic Objective 4. 2.8 The Strategic Objectives should also clearly set out how they will meet South Warwickshire’s sustainable development needs, in conjunction with contributing to meeting unmet needs of neighbouring authorities and be clear as to what these needs are.

The HEDNA for Coventry and Warwickshire says it provides evidence about how many jobs should be created by 2050 and how many homes would be needed to house those workers (page 25). The SA provides an evaluation of the different spatial options for growth, concluding that all options tested would increase the volume of housing. However, in terms of the level of growth the SA has only tested two options for housing numbers (page 128). Option I uses the HEDNA trend-based projections point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. Resulting in a combined total of 1,679 per annum. Option II uses the Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire, but with 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Resulting in a combined total of 1,239 per annum. 3.2 The South Warwickshire Local Plan should be more ambitious with its housing numbers and the SA process should include an option of a higher level of housing. As described elsewhere within this Representation, housing growth should be significant elevated if both Councils are to even come close to meeting the level of affordable housing need identified within the HEDNA. This also does not include the provision of housing to meet unmet need arising from within neighbouring authorities. 3.3 As set out in the NPPF, the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Government’s standard methodology identifies the minimum annual LHN, which is only a minimum starting point. This is not a housing requirement figure. The Government’s objective of significantly boosting the supply of homes set out in the NPPF remains (para 60). 3.4 Further comments in respect of the Sustainability Appraisal are including within the Sustainability Appraisal Review, included at Appendix 3 to this Representation.

selected

selected

Issue I2: Infrastructure Requirements and delivery QI-2 - Please select the option which is most appropriate for South Warwickshire Option I2a states that Part 1 of the Local Plan would set out infrastructure requirements for all scales, types and location for development equally across South Warwickshire, whilst Option I2b would only focus on the strategic infrastructure relating specifically to the growth strategy. 3.6 However, the scope of the Plan as stated on Page 2 of the Consultation Document is that the Part 1 document would set out the overall strategy for the pattern, scale and design quality of places within South Warwickshire. This includes the provision of housing, employment and infrastructure at the strategic level. Subsequent Part 2 Plans would then ‘set out detailed policies for specific areas, neighbourhoods or types of development. This could include allocating sites and the provision of infrastructure at a local level, establishing design principles and setting out other more detailed planning policies’. 3.7 In this context, Option I2b is most appropriate, as the Part 1 Plan cannot pre-determine the infrastructure provision that may be required as a result of the identification of sites through Part 2 Plans. To do so would otherwise be pre-emptive of the location and scale of growth to be provided through Part 2 Plans. Any viability assessment undertaken in support of the Part 1 Plan cannot accurately assess the viability of Part 2 sites, given their full infrastructure requirements cannot be known. 3.8 The Councils should nonetheless be clear that infrastructure identified within the Part 1 Plan should be funded through a combination of developer contributions from strategic sites, combined with other sources of external funding. In either Option, development should only be required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision. Any policy wording in the Plan for Section 106 agreements will need to ensure decision makers consider the need for infrastructure requirements at the time of making the decision. Planning obligations be necessary to make the development acceptable in planning terms, directly related to the development; and fairly and reasonably related in scale and kind to the development (PPG, Reference ID: 23b-002-20190901). QI-3: Please select the option which is most appropriate for South Warwickshire The establishment of a CIL charging schedule (Issue I3) is also directly related to Issue I2: Infrastructure Requirements and delivery. In this regard, it is submitted that strategic infrastructure brought forward through the Part 1 Plan is most appropriately delivered through the use of S106 agreements, rather than CIL. This ensures that infrastructure funding derived from a development is more inherently linked to the infrastructure required to deliver that development. The timing and delivery of infrastructure can also more appropriately monitored through legal agreements. 3.10 However, should the Councils be minded to introduce CIL, it is considered that new settlements, such as that proposed at Long Marston Airfield, should be exempt, due to the scale of the bespoke infrastructure required to deliver it. QI-5: Viability and deliverability are key aspects of the Plan, without which the Vision and Objectives cannot be met. The Consultation Document identifies that: ‘all of the sites considered for development as part of the growth strategy will be assessed through the South Warwickshire Housing and Economic Land Availability Assessment (HELAA) to assess their availability, suitability and viability for development. Additionally, an Infrastructure Delivery Strategy and associated viability assessments 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.’ The Church Commissioners strongly emphasises that viability work referred to within the second sentence above should be undertaken ahead of, and to inform, the next stages of the Part 1 Local Plan. Considerations relevant to viability and deliverability should be considered at the earliest stages of plan-making, to ensure that any allocations identified are viable and deliverable, including identifying infrastructure requirements.

Nothing chosen

The current local plans seek to safeguard land to help facilitate the delivery of a number of key infrastructure projects across South Warwickshire. Within Stratford District, this includes (amongst others) the route of the former railway south of Stratford-upon-Avon to Honeybourne to facilitate its re-opening and the Stratford South Western Relief Road. 3.12 The Church Commissioners supports the safeguarding of these infrastructure projects and submits that this protection should continue forward into the new South Warwickshire Local Plan.

selected

selected

Q-S1: Please select the option which is most appropriate for South Warwickshire? The Church Commissioners supports the concept presented in the Consultation Document that the SWLP will take a proactive approach and seek to identify its own ‘Green Corridors’ across the plan area in advance of the Local Nature Recovery Strategy, in line with Option S1a. The Consultation Document suggests that this would allow Strategic Green and Blue Corridors to ‘inform the growth strategy.’ Whilst this is agreed, determining Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced will also ensure that the identified corridors and growth strategy do not conflict with one another. Furthermore, including these corridors within the Local Plan also ensures that they are appropriately consulted upon against the statutory tests for plan-making, whereas this would not be the case within the Local Nature Recovery Strategy. 3.16 The Church Commissioners reserves the right to comment upon any Strategic Green and Blue Corridors identified within future iterations of the Plan. Any such corridors such be based on proportionate evidence, including in respect of their delivery. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Given the clear deficiency in the supply of brownfield land identified above in response to Question S3.1, The Church Commissioners strongly believes Option S3.c should be followed. This is not to say that The Church Commissioners does not support the redevelopment of brownfield land, but the lack of available supply evidence through the Urban Growth Study is clearly acute, with the Study concluding that ’…it is unlikely to be possible to meet current development needs without significant greenfield development.’ 3.21 It would therefore be inappropriate to ‘prioritise’ brownfield land ahead of developing other sustainable greenfield sites. This would result in an artificially constrained supply of housing, particularly at the start of the Plan Period, restricting the ability of both Councils to be able to demonstrate a five-year housing land supply, as required by National Policy. 3.22 Alternatively, brownfield and greenfield land should be brought forward coherently as part of a comprehensive growth strategy. Q-S5.2: Do you think new settlements should be part of the overall strategy? 3.25 The Church Commissioners supports the provision of new settlements as part of an overall growth strategy and submits that Land North of Long Marston Airfield (Location Reference: E1) should be allocated for development. 3.26 Table 6 summarises the potential locations for a new settlement, including any overarching constraints. It is clear from this Table that Land North of Long Marston Airfield (Location Reference: E1) is subject to fewer constraints than other alternatives; it is not Green Belt, Conservation Area, Special Landscape Area, Ancient Woodland or SSSI. 3.27 However, the Church Commissioners dispute the assertion that development at Long Marston Airfield would be dependent on the provision of a new railway station and line. The Highways Note at Appendix 2 to this Representation sets out how the utilisation of the existing Greenway serves as a traffic free route into Stratford. 3.28 Similarly, the Church Commissioners dispute the assertion that the development of the Site would result in coalescence with existing settlements. The northern boundary of the Site is approximately 3.75km from the southern edge of Stratford-upon-Avon, ‘as the crow flies’. There would accordingly remain a clear distinction between these settlements.

The Study sets out that its purpose is to provide evidence that helps to reduce the need for development outside of South Warwickshire’s 23 existing urban areas as far as justifiably possible. Section 4.6 of the Study identifies that there is a total baseline housing supply for the 2025-2050 Plan Period of 19,950 dwellings, of which 6,145 would be located within existing urban areas. The Church Commissioners questions the robustness of this figure, as it is partially derived from development occurring on existing public car parks, which is not considered to be realistic. Notwithstanding, the Study then goes on to compare this supply against a housing need for South Warwickshire of 30,750 dwellings across the Plan Period. This figure is incorrect. The Consultation Document and HEDNA seeks to establish a ‘trend-based’ alternative to the Standard Method, which result in annual housing need of 868 dwellings per annum (Stratford) and 811 dwellings per annum (Warwick), totalling 1,679 dwellings per annum. Multiplied across a 25-year Plan Period, this need is in fact 41,975 dwellings. This figure is importantly also exclusive of meeting any unmet need arising from neighbouring authorities, such as Coventry or Birmingham. 3.19 The identified supply, inclusive of sites within existing urban areas, is therefore less than half of the overall housing need required during the Plan Period. This clearly therefore indicates a need to look to greenfield sites for development, such as Land at Long Marston Airfield.

selected

selected

selected