THE CABINET 5 OCTOBER 2020
Subject: Site Allocations Plan – Preferred Options Consultation Lead Officer: John Careford Contact on 01789 260801 Lead Member/ Portfolio Holder: Councillor D Pemberton
Summary This report presents to Members the Council’s Preferred Options version of its Site Allocations Plan for public consultation. The Site Allocations Plan is a Development Plan Document that will accompany the adopted Core Strategy. This version of the plan replaces the previous Proposed Submission version from July 2019. As well as a number of specific proposals, the Site Allocations Plan includes reserve housing sites, sites for Self-build and Custom-build Housing, and identifies built- up area boundaries. Recommendations to Council: (1) That the Sustainability Appraisal/Strategic Environmental Assessment of the Site Allocations Plan (attached at Appendix 5) be received as forming part of the Site Allocations Plan evidence base; (2) That the Proposed Submission Site Allocations Plan (attached at Appendix 2) be endorsed for public consultation and in doing so, the previous Proposed Submission (July 2019) version of the Site Allocations Plan is formally withdrawn; (3) That the Policy Manager, in consultation with the Deputy Leader and Portfolio Holder for Place, is authorised to make any further minor and editorial amendments to the Site Allocations Plan prior to the Preferred Options consultation.
1. Background/Information 1.1 Background 1.1.1 The Site Allocations Plan sits alongside the Core Strategy and emerging Gypsy and Traveller Plan, and once adopted will form part of the Development Plan for Stratford-on-Avon District. These documents, along with Neighbourhood Plans prepared by parish councils, set out the principles and policies against which planning applications are considered and determined. 1.1.2 The context for the Site Allocations Plan is set by the Core Strategy which was adopted in July 2016. As such, although a Development Plan Document in its own right, the Site Allocations Plan is subservient to the Core Strategy, i.e. it does not set strategy or requirements (these have been established by the Core Strategy) but provides further detail to the approach set out in the adopted Core Strategy.
1.1.3 Indeed, there are a number of references in the Core Strategy to the Site Allocations Plan, in particular, in respect of identifying reserve housing sites and built-up area boundaries for settlements. The Plan also sets out a number of site-specific proposals as well as dealing with new planning requirements that have emerged since the Core Strategy was adopted. 1.1.4 In July 2019 the Council endorsed, and subsequently consulted on, a Regulation 19 Proposed Submission version of the Site Allocations Plan. During the consultation it transpired that a key assumption relating to the strategy for identifying reserve sites was not correct. In light of this, the Council has been able to revisit its strategy and as such, has taken a step back to Regulation 18 and is now consulting on a preferred options version of the Site Allocations Plan. Doing so has also allowed the Council the opportunity to further consider the mechanism for releasing reserve sites, as well as identify some additional site specific proposals. As such, the Preferred Options version of Site Allocations Plan replaces the Proposed Submission version, which is to be withdrawn. 1.1.5 The content of the Preferred Options version of the Site Allocations Plan has been informed by the comments received to the Proposed Submission consultation and a summary of these, in addition to the officer responses, is attached at Appendix 1. 1.1.6 Following this consultation, the Council will analyse the comments made and prepare a Proposed Submission version of the Site Allocations Plan for further consultation. This version, along with any necessary changes, will then be formally submitted to the Government for independent examination. Proposed submission consultation is expected from April 2021 with formal submission by December 2021 and adoption by summer 2022, although officers will endeavour to progress the Plan more quickly than this. 1.1.7 As per the Proposed Submission version, the Preferred Options version of the Site Allocations Plan includes policies and proposals covering the following topic areas, although there are a number of important changes summarised below. The Site Allocations Plan also identifies corresponding changes to the Policies Map, adopted alongside the Core Strategy in 2016. Section 2: Reserve Housing Sites – Policies SAP.1 – SAP.5 (previously Policies SAP.1 & SAP.2) Section 3: Self-build and Custom-build Housing Sites - Policy SAP.6 (previously (Policies SAP.3 - SAP.5) and Proposals SCB.1 - SCB.11 Section 4: Built-up Area Boundaries - Policy SAP.7 (previously Policy SAP.6) Section 5: Employment Enabling Sites - Policy SAP.8 (previously Policy SAP.7) Section 6: A46 Safeguarding - Policy SAP.9 (previously Policy SAP.8) Section 7: Specific Site Proposals (various) Section 8: Policies Map The Site Allocations Plan itself also contains four Appendices and four separate Annexes that are referred to throughout this report.
1.1.8 The draft Preferred Options version of the Site Allocations Plan is attached at Appendix 2. For the sake of clarity, deletions have not been shown although new text is shown underlined in order to highlight where the main changes are. Please note: both policy and proposal references may have changed. 1.1.9 Officers are also embarking on the Core Strategy Review, although this is intended to now be subsumed into the South Warwickshire Plan, prepared collaboratively with Warwick District Council (see separate report). This plan will set new housing and employment requirements, identify new locations for growth with supporting infrastructure, and establish new planning policies (e.g. climate change) for a new plan period post 2031. Whilst there is an intention to progress this plan as quickly as is practicable, officers consider that there is still merit in progressing with the Site Allocations Plan to provide clarity and certainty to both communities and the development industry in the interim period. 1.1.10 Members will also be aware of two Government consultations, namely, Changes to the Existing Planning System and the Planning White Paper. If implemented, both would have fundamental consequences for Stratford- on-Avon District, not least in terms of the housing requirement increasing by 120%. For this reason, having a Site Allocations Plan setting out a plan- led approach to accommodating additional housing and moving quickly to a review of its Core Strategy, are pragmatic and sensible responses. 1.1.11 Before summarising the main changes between the Preferred Options and Proposed Submission versions, it is worth highlighting two aspects that arose out of the Proposed Submission consultation. 1.1.12 The first relates to accusations that the Council had failed to properly consult by not previously undertaking a Preferred Options consultation under Regulation 18. When the current system was established in 2004, it was particularly prescriptive setting out various stages of consultation under Regulation 18, namely Issues and Options and Preferred Options, before moving to Proposed Submission under Regulation 19. Changes to the system in 2012 gave local planning authorities much more flexibility under Regulation 18 as to how to consult. As such, it was perfectly legitimate to move from the consultations the Council had undertaken under Regulation 18 to Proposed Submission under Regulation 19. However, in light of the need to revise the Site Allocations Plan, it is felt prudent to revert to a Preferred Options stage. 1.1.13 The second issue relates to the relationship of the Site Allocations Plan to Neighbourhood Plans. A number of parishes have prepared Neighbourhood Plans setting out how they wish development in their community to be managed. The District Council welcomes this expression of localism and is fully supportive of Neighbourhood Plans. Officers accept that there were instances in the Proposed Submission version where the Council had been inconsistent in the application of its approach.
1.1.14 There is, however, a tension within the plan-making system between these ‘bottom-up’ views of the community as expressed though a NDP and the ‘top-down’ approach of a Local Plan prepared by the Local Planning Authority that has to take a strategic or District-wide perspective. This tension is further reinforced by the different methods for preparing and adopting a NDP and a Local Plan - the former having to satisfy a number of basic conditions whereas the latter is subject to detailed scrutiny to ensure that its proposals are positively prepared, justified, and effective - although both then go on to form part of the statutory Development Plan. 1.1.15 This is a fundamental point and it is important to remember that Neighbourhood Plans and Local Plans sit side-by-side to manage development in their area. Importantly, both are necessary because they do different things. Given the different role of Local Plans and NDPs and the different evidence base that underpins their preparation, it is entirely appropriate that the two types of plans can co-exist even if they have reached different conclusions about the appropriateness of development in certain locations. Where the Site Allocations Plan identifies reserve sites on land not identified by an NDP, that proposal does not undermine the NDP. The policies and objectives in the NDP remain valid and all relevant policies will still be used to determine any subsequent application, e.g. design, housing mix, etc. 1.1.16 The Council has taken the approach of not identifying reserve sites in those settlements with a reserve site identified in its NDP. The Council has applied this approach to those NDPs that are at a significantly advanced stage, i.e. those NDPs that are either made or where the Council has resolved to submit the NDP for referendum. This is because it is only at this point that the content of the NDP is not liable to change. The Council acknowledges that the Site Allocations Plan is only at Preferred Options stage and that a number of NDPs with identified reserve sites are progressing well (e.g. Clifford Chambers, Tysoe). It is expected that these NDPs will have reached an advanced stage (as defined above) by the time the Site Allocations Plan is ready for submission. As such, it is fully expected that the Submission version of the site Allocations Plan will be amended to reflect the changing status of these NDPs. However, at the current time, for consistency purposes, the Council has NOT taken into account emerging NDPs. 1.2 Reserve Housing Sites (Section 2) 1.2.1 It is not proposed to rehearse the justification for the need for reserve sites here other than to remind Members that reserve sites are to be identified to meet four purposes: maintain 5 year housing land supply, meet additional housing needs from expansion of JLR at Gaydon Lighthorne Heath; meet additional housing needs from Coventry and Warwickshire housing market area, and meet additional housing needs from outside Coventry and Warwickshire. Rather, this section focuses on the main changes between the Proposed Submission and Preferred Options versions. 1.2.2 There are a number of key changes: Selection of reserve sites Relationship to reserve sites identified in NDPs
Mechanism for releasing reserve sites Birmingham shortfall Applications for reserve sites. 1.2.3 The proposed list of reserve sites is set out in Annex 1 to the Site Allocations Plan itself (i.e. Appendix 2 to this report), with new sites highlighted. The Preferred Options version identifies a pool of approximately 3,130 homes on reserve sites to meet the requirement of 2,920 homes. Annex 1 is supplemented by a series of Site Proformas (Annex 2 to Appendix 2 to this Report) which provide further detail on each individual site, including identifying site-specific constraints that will need to be overcome in order for the site to come forward. Further explanation as to why certain sites have not been identified as reserve sites is set out in the accompanying Topic Paper that is attached at Appendix 3 to this report. It should be noted that reserve sites have not been identified in the Green Belt nor the Cotswolds Area of Outstanding Natural Beauty (AONB). 1.2.4 The Council has also taken the decision not to identify reserve sites in those settlements that already have reserve sites identified, albeit through a neighbourhood plan (see above). However, to provide clarity, it is proposed to use the SAP (Policy SAP.2) to ensure a consistent approach to the release of reserve sites across the District and align NDP reserve sites with those identified in the Site Allocations Plan itself (Policy SAP.3 – see below). In all other respects, NDP reserve sites will be brought forward in accordance with the NDP. 1.2.5 The starting point for the identification of reserve sites is the distribution strategy set out in the Core Strategy. Whilst Policy CS.16 apportions a quantum of development to each of the various locations identified in Policy CS.15, these numbers exclude any provision for reserve sites. This is because reserve sites are in addition to the housing requirement of 14,600. 1.2.6 It has been suggested that the quantum of reserve sites in any particular location should correspond to the quantum for each location set out in Policy CS.16. It is the view of officers that the identification of reserve sites should not be a mathematical exercise but should be informed by the most up-to-date information regarding the suitability and availability of individual sites for potential development. The Council is therefore taking the same bottom-up approach that it took in specifying the quantum of development in the Core Strategy. 1.2.7 Having said that, the Council does need to acknowledge the relative sustainability of each location and, taking into account the concerns raised during the Proposed Submission consultation particularly about the quantum of development earmarked to the Local Service Villages, has sought to address these concerns through the application of its release mechanism (Policy SAP.3 and Annex 3). It has also sought to address both of these issues through the application of different indicative densities depending on location: 35dph in Stratford-upon-Avon, 30dph in the Main Rural Centres and Category 1 and Category 2 Local Service Villages, and 25dph in Category 3 and Category 4 Local Service Villages.
1.2.8 Policy SAP.3 and Annex 3 of the Site Allocations Plan (Appendix 2 to this Report) set out the approach for identifying how, when and which reserve sites will be released. It replaces the previous geographic approach based on proximity to the source of the identified need, in light of comments received to the Proposed Submission consultation. 1.2.9 In the first instance, Policy SAP.3 applies a cap of 1,000 homes to meeting each of three of the four reserve site purposes. This is an evolution of the approach proposed in the Proposed Submission consultation. That approach received some criticism from the development industry in particular who argued that applying a cap was both arbitrary and contrary to the Core Strategy minimum housing requirement of 14,600. Officers reject these criticisms as they are based on misunderstandings. 1.2.10 Firstly, the cap is necessary because of the fact that reserve sites have been identified to meet four very different purposes, none of which, with the exception of Birmingham (see below) have been quantified nor confirmed to date. It would not be appropriate to attempt to speculate as to what the quantum for the respective purposes would be. As such, in the absence of any evidence, the Council considers that the most appropriate approach is to ensure that, in the first instance, some quantum of reserve is available for each purpose should the need arise. In circumstances where a purpose has been satisfied utilising fewer than 1,000 homes, any ‘residual’ will then be made available for the remaining purposes. 1.2.11 Secondly, objectors are conflating the Core Strategy minimum housing requirement (which sets out in Policy CS.15 the circumstances in which additional homes over and above the 14,600 can come forward), with the requirement in Policy CS.16 to identify a specific quantum of reserve equivalent to up to 20% of the requirement. In any event the reserve sites will deliver additional homes over and above the 14,600 requirement but it is not correct to argue that the reserve should be unlimited. 1.2.12 Policy SAP.3 sets out the detail as to how the Council will confirm that a reserve site purpose has been triggered. As part of this, officers are proposing to require promoters of reserve sites to provide accurate and up-to-date delivery information in respect of their site and Appendix 2 of the Site Allocations Plan (Appendix 2 to this Report) sets out the standard template. Where sites are not capable of being delivered quickly, they will not form part of any release. 1.2.13 In respect of the purpose of reserve sites which relates to maintaining a 5 year housing land supply, it is proposed that a trigger of 5.5 years is applied. Whilst this makes it a more challenging target to achieve, the Council cannot wait until supply falls below 5 years before taking action. This is because of the way that the NPPF is written; as soon as supply falls below 5 years, relevant policies relating to the supply of housing, i.e. reserve housing sites, cease to be applicable. To put it bluntly, there would be no point in having reserve sites if our supply falls below 5 years; reserve sites are there to ensure that we maintain at least 5 years at all times and a buffer of half a year’s worth of supply is considered appropriate. Officers also consider that it is appropriate to relate the trigger for the 5YHLSurpose to the Housing Delivery Test which is a post-Core Strategy adoption NPPF requirement. Had it existed at the time of the Core Strategy examination, it is likely that the Inspector would have referred to it. For information, the latest test results confirm that Stratford-on-Avon District achieved a delivery of 271%.
1.2.14 In releasing reserve housing sites, it is proposed to apply the basis of the distribution of development established in Policy CS.15 of the Core Strategy. Reserve sites will be released in tranches in settlements in the following order. The settlements and reserve sites within each tranche are set out in Annex 3 of the Site Allocations Plan (Appendix 2 to this Report). 1. Main Town of Stratford-upon-Avon 2. Main Rural Centres 3. Category 1 Local Service Villages and Large Rural Sites 4. Category 2 Local Service Villages 5. Category 3 Local Service Villages 6. Category 4 Local Service Villages 7. Local Service Villages that have significantly exceeded the indicative numbers set out in Core Strategy Policy CS.16. 1.2.15 As set out in Annex 3, the above order also takes into account those settlements with a made NDP, with the Council seeking to acknowledge the effort of those communities that have opted to take a proactive approach to development in their area. Significantly exceeded has been defined as being in excess of 20% above the indicative housing numbers set out in Core Strategy Policy CS.16. Please note: owing to the COVID- 19 pandemic, housing monitoring site visits have been delayed. As such, the most recently published monitoring data is as at 31 March 2019. The Site Allocations Plan will of course be revised to take into account the latest monitoring information as it progresses. 1.2.16 In respect of the Main Rural Centres, it is also appropriate to give consideration to the presence of Neighbourhood Plans with identified reserve sites. However, unlike the LSVs, the Core Strategy does not specify an indicative quantum of development considered appropriate for each MRC; the numbers quoted (Core Strategy Figure 1) simply refer to the expected likely scale of growth envisaged at the time of adoption of the Core Strategy. This would leave circa 1,400 homes as a single MRC tranche, which would not be appropriate. 1.2.17 To remedy this, and in the spirit of Paragraph 68 of the NPPF1, it is proposed to apply site-size thresholds to provide appropriate delineation to the tranches by bringing forward the smaller sites in the first instance: i.e. less than 100 homes; between 100 and 200 homes, and more than 200 homes. However, applying this approach to the identified reserve sites does generate a slight peculiarity in that all the sites between 100 and 200 homes are in the west of the District and all the sites over 200 homes are in the east of the District. In itself, this is not an issue. However, given that two of the four purposes relate to sources of need arising from the east of the District, it would seem perverse to release reserve sites in the west of the District to meet those needs. As such, the following approach is proposed for the MRCs:
1 National Planning Policy Framework, February 2019
Order Purpose 1 – Purpose 2 – Purpose 3 – Purpose 4 – 5YHLS GLH within CW HMA beyond CW HMA 1 Tranche A Tranche A Tranche A Tranche A 2 Tranche B Tranche B Tranche B Tranche B 3 Tranche C1 Tranche C2 Tranche C2 Tranche C1 4 Tranche C2 Tranche C1 Tranche C1 Tranche C2
1.2.18 In releasing reserve sites, it is highly likely that the above tranches will not correspond exactly to the quantum of needs identified. The Council will apply its approach to reserve sites pragmatically. Providing that overprovision against the Core Strategy requirement continues, then there may be instances where the Council decides not to release an additional tranche of reserve sites if this overprovision were to be significant. Alternatively, where overprovision is made because of the numbers related to the tranches, the Council will determine whether that overprovision should contribute further to meeting the identified need or whether it should simply contribute to further bolstering the Core Strategy housing requirement itself. 1.2.19 For example, let’s say a need arises for an additional 150 homes. Tranche A will deliver 140 homes and Tranche B will deliver 200 homes. The Council may consider that it is sufficient just to release Tranche A. Alternatively, if a need arises for 300 homes outside the District, the Council may decide to release Tranches A and B. Whilst this provides 340 homes in total, only 300 are ‘ascribed’ to the identified need; the additional 40 homes would be provided to contribute to the supply of housing within Stratford-on- Avon District as a whole. 1.2.20 It is fully acknowledged that the proposed release mechanism operates at the settlement level as opposed to the site level. Officers accept that in some instances, this approach will most likely see a significant quantum of development coming forward in the same settlement at the same time. The likely resultant cumulative impacts are a concern. Whilst the approach to ascertaining the deliverability of individual sites (see above) may go some way to negate these impacts, in the absence of an alternative that can robustly, reasonably and equitably prioritise sites, officers consider that the proposed approach is appropriate. At the very least, it provides certainty that both site promoters and the community require and will prevent a speculative ‘free for all’ that would occur without any release mechanism at all. This was a criticism highlighted through the Proposed Submission consultation. 1.2.21 One of the four purposes for reserve sites is to meet any additional needs from outside the Coventry and Warwickshire housing market area (HMA). The most obvious area of need is from the Greater Birmingham HMA, of which the District is part. Exercising its Duty to Co-operate obligations, the Council has been working with the other 13 authorities within the HMA to address the acknowledged shortfall. The HMA authorities have jointly prepared and published a position statement confirming the most up-to- date position as at July 20202. This confirms a HMA-wide shortfall of 2,597 homes for the period to 2031, the plan period of the Site Allocations Plan.
2 Available at www.stratford.gov.uk/strategicplanning
1.2.22 The existence of this shortfall confirms that the trigger for the release of reserve sites under this Purpose has been met. Taking a proactive approach, Policy SAP.4 therefore proposes to release reserve sites to contribute to meeting that shortfall. 1.2.23 The strength of the functional relationship of the District with Birmingham is relatively weak with commuting flows of just 2.1% (based on the 2011 census). Applying this ratio, the District should accommodate just 41 homes. However, that assumes that the other authorities are capable of meeting their share. The Council is aware that the four Black Country authorities also have very limited capacity to accommodate additional growth. As such, officers propose that Stratford-on-Avon District seeks to provide approximately 1/9th of the shortfall (i.e. excluding Birmingham City Council and the four Black Country Authorities). A signed Statement of Common Ground will be prepared to accompany the Submission version of the Site Allocations Plan confirming that the reminder of the shortfall is capable of being met by the remaining local authorities. 1.2.24 It is acknowledged that the sites identified in Policy SAP.4 do not strictly accord with Policy SAP.3 in that sites in Mappleborough Green (a Category 4 LSV) are identified ahead of sites in the MRCs and Category 1, 2 and 3 LSVs. The rationale for this is the very strong relationship that the sites in Mappleborough Green have with the Birmingham HMA, being on the boundary with Redditch Borough and accessed from Redditch. Owing to the Green Belt, the Mappleborough Green sites are the only reserve sites in the north-western quarter of the District capable of immediate release3. 1.2.25 It is also proposed to release site STR.B under Policy SAP.4. The rationale for the release of this site ahead of other sites in the Main Town is due to the added benefits that early release of this site would bring in terms of helping to facilitate delivery of the existing Core Strategy strategic allocation: SUA.1 the Canal Quarter Regeneration Zone. This is because site STR.B forms part of a wider land parcel that includes Proposal SUA.5 for Canal Quarter employment purposes (see section 1.3 below). Because of the costs of relocating existing businesses and providing adequate access to the employment land, it would not be viable to bring forward Proposal SUA.5 as a standalone allocation. Site STR.B, therefore acts as enabling development to facilitate delivery of SUA.5 and in turn, delivery of the Wharf Road component of the Canal Quarter. 1.2.26 The final policy in Section 2 (SAP.5) sets out specific requirements for reserve sites. There are two aspects to the policy. The first relates to seeking to ensure that reserve sites come forward in a timely manner by applying very challenging timescales for the submission of planning applications and starting construction on site. This approach replaces the previous approach of seeking full planning applications which was very strongly criticised for being contrary to planning legislation.
3 For the avoidance of doubt, although the Mappleborough Green sites are greenfield, they are not in the Green Belt.
1.2.27 The second aspect relates to requiring reserve sites to be future-proofed with low carbon heating and increased levels of energy efficiency. In the absence of a corresponding detailed policy in the Core Strategy, and noting the importance that Members have given to this issue, officers consider that a pragmatic and positive way forward is to explore the possibility of applying the Government’s preferred option from their Future Homes Standard consultation. This seeks a 31% reduction in carbon emissions from new dwellings. It is considered reasonable to apply this standard to reserve sites as these are new sites delivered through the auspices of the Site Allocations Plan and cannot in themselves come forward through the Core Strategy. As such, the Council is not seeking to apply stricter policy retrospectively. Whilst further technical work in respect of viability still needs to be undertaken, officers consider that it is appropriate to explore the principle of this approach through consultation. 1.3 Specific Site Proposals (Section 7) 1.3.1 Section 7 sets out a number of site specific proposals that it is considered appropriate to include within the Site Allocations Plan. These are as follows with new proposals shown underlined: South of Alcester Road, Stratford-upon-Avon (Proposal SUA.2) Atherstone Airfield (Proposal SUA.4) East of Shipston Road, Stratford-upon-Avon (Proposal SUA.5) Stratford-upon-Avon Gateway (Proposal SUA.6) Rother Street/Grove Road, Stratford-upon-Avon (Proposal SUA.7) Land at Stratford-upon-Avon College, Alcester Road, Stratford-upon- Avon (Proposal SUA.8) Bidford Centre, Bidford-on-Avon (Proposal BID.1) Studley Centre (Proposal STUD.1) High Street, Studley (Proposal STUD.2) Napton Brickworks (Proposal RURAL.1) University of Warwick Wellesbourne Campus (Proposal RURAL.2) Quinton Rail Technology Centre, Long Marston (Proposal RURAL.3) Meon Vale (Former Engineers Resources Depot), Long Marston (Proposed RURAL.4) Long Marston Airfield - Phase 1b (Proposal RURAL.5) 1.3.2 In terms of changes to the existing proposals, there are a number of relatively minor amendments principally relating to clarity over the specific requirements for each site. These are shown in the relevant parts of Section 7 of Appendix 2 to this report. The most significant changes to the existing proposals relate to STUD.1 and RURAL.2. 1.3.3 In respect of STUD.1, the extent of the site has been enlarged to facilitate a more comprehensive mixed-use scheme to create a new centre to the village of Studley. The proposal incorporates both publically and privately owned land, including a number of existing successful businesses and community facilities. The proposal seeks to retain all existing uses and occupiers but in improved buildings and facilities, in an improved public realm. Obviously such a proposal will require the consent and co-operation of those businesses affected, and subject to the outcome of this consultation, the District Council would then work with those landowners, businesses, groups and the Parish Council to deliver the Proposal.
1.3.4 In respect of RURAL.2, the major change here is in respect of clarity over the extent and nature of the development proposals. The Council is supportive of the University’s ambitions for Wellesbourne Campus and, as such, is seeking to establish in-principle support through the Site Allocations Plan. Whilst the whole site extends to approximately 110 hectares, the current campus buildings cover some 23ha. Three specific areas have been identified for development within the site: a) Land to the northwest of the campus – approx. 22ha b) Land to the southeast of the campus – approx. 3ha c) Land fronting Stratford Road (for commercial enabling development) – approx. 7ha. 1.3.5 Of the three new proposals, BID.1 is akin to STUD.1 in seeking the creation of a new village centre. Located on Waterloo Road, this proposal would see a mix of uses and new public space created in a location much more accessible to the vast majority of residents of Bidford-on-Avon. In turn, this proposal could also help to revitalise the historic high street as a destination for more leisure–related retail activities as opposed to local services. The land is in private ownership and is dependent upon the consent and co-operation of the landowner. 1.3.6 The second new proposal is at Meon Vale, the Former Engineers Resources Depot (Proposed RURAL.4), which is identified as a Large Rural Brownfield Site under Policy AS.11 of the Core Strategy, although the specific parcel of land in Proposal RURAL.4 comprises a substantial area of plantation woodland. This site was previously identified as a potential reserve site in the Proposed Submission version of the Site Allocations Plan. In light of its status in the Core Strategy, it is the opinion of officers that the site could come forward in any event and as such, is not appropriate as a reserve site. Given the desire of the landowner to promote the site, it is considered that a proactive and plan-led approach will secure the best outcome for both the District Council and the local community, hence its inclusion in the Site Allocations Plan as a site specific proposal. 1.3.7 It should be noted that there are a number of important considerations that still need to be resolved, including critically, ensuring that development would not affect the operational viability of the adjacent rail research centre (Proposal RURAL.3) and employment land. For the avoidance of doubt, Proposal RURAL.4 requires the retention of any mature trees and non-plantation woodland, as well as securing the provision of publically accessible green spaces throughout the site. It will also be necessary for the layout and design of the development to incorporate appropriate noise mitigation measures. 1.3.8 The third new proposal is at Long Marston Airfield (Proposal RURAL.5). This site is identified in the Core Strategy (Proposal LMA) as a new settlement seeking to deliver 3,500 homes. Subsequently, the site has also been awarded Garden Village status. Phase 1 of LMA has consent for 400 homes and is coming forward for development.
1.3.9 The specific requirements in Proposal LMA require the ‘completion of a south-western relief road before more than 400 dwellings can be occupied, unless a transport assessment demonstrates a higher threshold is appropriate’. Transport assessments undertaken to support the 2019 Proposed Submission consultation and further work undertaken to inform the preparation of this version of the Site Allocations Plan confirm that there is some additional capacity within the highway network to enable further development to the south of Stratford-upon-Avon in advance of the SWRR being constructed. 1.3.10 Officers consider that the bulk of this spare capacity should be ascribed to Long Marston Airfield as opposed to alternative reserve sites. This is because Proposal LMA is an existing Core Strategy allocation that the Council should deliver in the first instance. Indeed, it would be perverse to identify reserve sites (that are only to be released if needed), but which by their very identification could cause them to be brought forward because they undermined the Core Strategy itself. 1.3.11 To ensure that development at LMA continues to come forward in accordance with the masterplan and that the necessary infrastructure is provided alongside new homes, Proposal RURAL.5 seeks to provide clarity regarding the next phase of development. This includes bringing forward the land for the primary school, employment land in the form of a business park fronting Campden Road, and the northern access to the site from Campden Road, as well as accompanying open space. 1.4 Self-build Sites, Built-up Area Boundaries, Employment Enabling Sites and A46 Safeguarding (Sections 3, 4, 5 and 6) 1.4.1 The bulk of these sections remain as set out in the Proposed Submission version and again, this section focuses on the main changes as opposed to repeating the justification for their inclusion within the Site Allocations Plan. 1.4.2 In respect of Self-build and Custom Housebuilding sites, the policies have been combined into a single policy (SAP.6) to remove duplication. Consistent with the proposed approach to reserve sites, a low-carbon requirement has been inserted into the policy. Again, this is felt appropriate given that the Core Strategy is silent on the issue of self-build and it is only through the auspices of the Site Allocations Plan that such sites can come forward. Reference is also made to modern/advanced methods of construction. 1.4.3 Eleven sites are allocated as Self-build and Custom Housebuilding sites (Proposals SCB1-SCB.11) and these are set out in Section 3.2 of the Site Allocations Plan (Appendix 2 to this report). There are a number of new sites. 1.4.4 Aside from reflecting the progression of NDPs, the main changes in respect of Built-up Area Boundaries or BUABs (Policy SAP.7) are twofold. Firstly, the inclusion of BUABs for Salford Priors and Wilmcote; whilst both settlements are covered by ‘made’ NDPs, the communities decided not to promote a BUAB through the NDP and has left it to the District Council to define the boundaries through the SAP. The proposed BUABs are set out in Part C of Section 8 of Appendix 2.
1.4.5 Secondly, following the consultation, amendments are proposed to the methodology for defining BUABs (Annex 4 to Appendix 2 to this Report) and this has resulted in a number of changes to the BUABs themselves. Appendix 5 to the Site Allocations Plan (Appendix 2 to this Report) provides a schedule of the changes which should be read alongside the maps included in Part C of Section 8 of Appendix 2. 1.4.6 In respect of the approach to employment enabling sites, the main changes relate to revisions to the policy thresholds and clarity over the application of the policy (Policy SAP.8). For clarity and the avoidance of doubt, this policy only applies to those sites not specifically provided for under the Core Strategy. Such sites are over and above the Council’s employment land requirements and as such, it is reasonable to seek a percentage of affordable employment space. 1.4.7 The degree to which this policy will deliver is unknown partly because of the costs and returns associated with employment development. As such, some have queried the effectiveness of the policy. However, because sites brought forward under this policy will be in addition to the District’s employment needs, the Council is not relying on them to come forward. Officers are optimistic however, that there will be some landowners who will be prepared to accept a lower land value in order to facilitate such schemes. In this respect, the policy is considered to be effective 1.4.8 Following the Proposed Submission consultation, it is proposed to delete the proposed safeguarding at Marraway/A439 Warwick Road as this junction does not meet the criteria for wanting to safeguard land to ensure that development does not prejudice long-term improvements to the A46. This change is reflected in Policy SAP.9. 1.5 Public Consultation 1.5.1 Following endorsement at Council on 19 October, it is proposed to run a six week public consultation commencing on the 22 October. The Council has updated its Statement of Community Involvement (SCI)4 in light of the COVID-19 pandemic and considers it appropriate to consult at this time. However, officers acknowledge that the situation remains fluid. Officers will liaise with the Deputy Leader and Portfolio Holder for Place in respect of the consultation approach.
2. Options available to The Cabinet 2.1 The following options are available to The Cabinet to consider: Option 1: To endorse the recommendations to Council to enable the Site Allocations Plan Preferred Options version to be published for public consultation; Option 2: To request changes be made to content of the Site Allocations Plan Preferred Options version;
4 Available at www.stratford.gov.uk/sci. The updated version is subject to ratification at Full Council in October.
Option 3: Not to endorse the recommendations to Council to enable the Site Allocations Plan Preferred Options version to be published for public consultation. 2.2 Material changes to the Site Allocations Plan now would delay the consultation with the resultant knock-on effect of delaying submission beyond the end of 2020. It should be noted that changes would need to be assessed through the SA/SEA and may require additional technical assessments. This work would have additional resource implications. 2.3 The Council could chose not to progress with the Site Allocations Plan. As outlined above, this option is not recommended. Moreover, it is considered necessary to formally ‘draw a line’ under the previous Proposed Submission version. 3. Evidence Base 3.1 The Site Allocations Plan has been informed by a raft of technical evidence and these studies will accompany the public consultation: Education Assessments Employment Land Studies Heritage Impact Assessment (HIA) Highway Access Assessments Strategic Flood Risk Assessment (SFRA) Strategic Housing Land Availability Assessment (SHLAA) Stratford-upon-Avon Highway Capacity Study Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA). 3.2 The Council has prepared a Topic Paper setting out in more detail the justification for the Council’s preferred option and selection of reserve sites. This is attached at Appendix 3. 3.3 Perhaps the most crucial piece of evidence in respect of selecting actual sites is the Strategic Housing Land Availability Assessment or SHLAA. The Council is obliged to prepare and maintain a SHLAA and has utilised the agreed sub-regional methodology. The purpose of the SHLAA is to assess the suitability, availability and achievability of sites for development using a red-amber-green assessment. The latest SHLAA was endorsed by The Cabinet on 27 July 2020 and identified the potential for circa 5,100 homes5. It is from this ‘long-list’ of sites that the Council has identified self-build & custom-build housing sites and reserve housing sites; the latter totalling circa 3,000 homes. 3.4 The Council has also been assessing the infrastructure implications of reserve sites on primary and secondary education, highways, waste water and flood risk. Identified infrastructure capacity issues have informed conclusions about when potential sites may be able to come forward for development.
5 Available at www.stratford.gov.uk/shlaa.
3.5 A major piece of work has been the Heritage Impact Assessment (HIA). This has assessed the SHLAA sites in terms of their potential impact on heritage assets at both the site and settlement level. A summary of the results of this work is attached at Appendix 4 to this Report. In accordance with the NPPF, whilst harm to a heritage asset has been identified for the majority of sites (which is not unsurprising given the historic nature of the District), this harm is assessed as being less than substantial and can effectively be mitigated, e.g. through appropriate layout and design. A small number of sites have been identified as causing substantial harm and as such, these have been discounted as not being suitable as reserve sites. This approach is also set out in the Topic Paper at Appendix 3 to this report. Sustainability Appraisal/Strategic Environmental Assessment 3.6 The purpose of Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA) is to promote sustainable development through the integration of environmental, social and economic considerations in the preparation of Local Plans, and when compared with reasonable alternatives. This requirement for SA is in accordance with planning legislation and the NPPF. 3.7 SA/SEA is an iterative and ongoing process that informs plan-making by assessing developing elements of the plan, evaluating and describing the likely significant effects of implementing the plan, and suggesting possibilities for mitigating significant negative effects and enhancing positive effects. The SA/SEA framework established for the Core Strategy has been used, together with baseline information (updated as appropriate for the Site Allocations Plan) against which the various options have been tested (e.g. positive, negative, neutral and uncertain effects). 3.8 The SA/SEA report is attached at Appendix 5. Officers have worked closely with the Council’s independent SA/SEA Consultant on the iterative testing of approaches in order to develop a Preferred Option. 3.9 Eight high-level scenarios (A-H) were tested, developed from the initial Scenarios that had been investigated and consulted upon in late 2019. The findings of this assessment is set out in Appendix VIII of Appendix 5 to this Report. Scenario A Do Nothing Scenario B Cumulative: Base Scenario and include all Amber SHLAA Sites Scenario C Base Scenario and exclude Amber Sites in Local Service Villages (LSVs) & Large Rural Sites (LRSs): Alderminster, Bishops Itchington, Clifford Chambers, Ettington, Fenny Compton, Gaydon, Halford, Hampton Lucy, Harbury, Ilmington, Lighthorne, Long Itchington, Loxley, Mappleborough Green, Moreton Morrell, Napton-on-the-Hill, Newbold-on-Stour, Oxhill, Pillerton Priors, Priors Marston, Quinton, Salford Priors, Stockton, Tiddington, Tredington, Welford-on-Avon Scenario D Base Scenario and exclude Amber Sites with capacity under 30 dwellings Scenario E Base Scenario and exclude Amber Sites with capacity under 100 dwellings
Scenario F Base scenario and exclude Amber sites that are in settlements covered by made Neighbourhood Development Plans or Examiner’s Report recommends proceed to Referendum: Alcester, Bidford-on-Avon, Ettington, Harbury, Ilmington, Kineton, Long Compton, Loxley, Salford Priors, Shipston-on- Stour, Stratford-upon-Avon (including Tiddington), Welford-on- Avon, Wellesbourne Scenario G Base Scenario and exclude Amber sites in LSVs that have exceeded dwelling provision in Policy CS.16 based on all commitments & completions: Alderminster, Bishops Itchington, Ettington, Fenny Compton, Gaydon, Harbury, Long Itchington, Long Marston, Newbold-on- Stour, Oxhill, Salford Priors, Stockton, Welford-on-Avon Scenario H Base Scenario plus Amber Sites apportioned according to the % distribution of the Core Strategy requirement – Main Town (965); Main Rural Centres (1,047); New Settlements (0); LSV1 (124); LSV2 (193); LSV3 (124); LSV4 (124); Large Rural Sites (equates to Large Rural Brownfield in the CS) (343); and rural elsewhere (0)
3.10 The high-level scenarios A-H were refined in order to develop a meaningful tranche of scenarios that included some spatial specificity. The implications for each Scenario 1-5 (please see Appendix IX of Appendix 5 to this Report) were tested taking into consideration the findings of the SA/SEAs of the SHLAA sites. The findings of this assessment is set out in Appendix X of Appendix 5 to this Report. Scenario 1 Cumulative: Base Scenario of all other Site Proposals - plus all Amber sites Scenario 2a Base Scenario of all other Site Proposals - plus all Amber sites but exclude sites in LSV Category 4. Include: LSV Category 1: Bishop’s Itchington, Harbury, Long Itchington, Quinton, Tiddington LSV Category 2: Brailes, Fenny Compton, Lighthorne Heath, Napton-on-the-Hill, Salford Priors, Stockton, Tysoe, Welford-on- Avon, Wilmcote, Wootton Wawen LSV Category 3: Claverdon, Earlswood, Ettington, Great Alne, Ilmington, Long Compton, Newbold-on-Stour, Snitterfield, Temple Herdewycke, Tredington Scenario 2b Base Scenario of all other Site Proposals - plus all Amber sites but exclude sites in LSV Category 3 & 4. Include: LSV Category 1: Bishop’s Itchington, Harbury, Long Itchington, Quinton, Tiddington LSV Category 2: Brailes, Fenny Compton, Lighthorne Heath, Napton-on-the-Hill, Salford Priors, Stockton, Tysoe, Welford-on- Avon, Wilmcote, Wootton Waven Scenario 2c Base Scenario of all other Site Proposals - plus all Amber sites but exclude sites in LSV Category 2, 3 & 4 Include: LSV Category 1: Bishop’s Itchington, Harbury, Long Itchington, Quinton, Tiddington Scenario 2d Base Scenario of all other Site Proposals - plus all Amber sites but exclude Large Rural Sites & sites in LSV Category 1, 2, 3 & 4
Scenario 3a Base Scenario of all other Site Proposals - plus all Amber sites but exclude sites with capacity <30 dwellings Scenario 3b Base Scenario of all other Site Proposals - plus all Amber sites but exclude sites with capacity <100 dwellings Scenario 4 Base Scenario plus all Amber sites but do not include sites that are in made Neighbourhood Development Plans or those that are recommenced to proceed to Referendum & that already have identified reserve sites. This means removing all Amber sites in 13 settlements: Alcester, Bidford-on-Avon, Ettington, Harbury, Ilmington, Kineton, Long Compton, Loxley, Salford Priors, Shipston-on-Stour, Stratford-upon-Avon (including Tiddington), Welford-on-Avon, Wellesbourne Scenario 5 Base Scenario plus all Amber sites but do not include sites in LSVs that have exceeded dwelling provision in Core Strategy Policy CS.16. Include: Alderminster, Bishops Itchington, Ettington, Fenny Compton, Gaydon, Harbury, Long Itchington, Long Marston, Newbold-on- Stour, Oxhill, Salford Priors, Stockton, Welford-on-Avon
3.11 It should be noted that “doing nothing” is not a reasonable alternative for the Local Plan since the Council has a duty to plan positively for objectively identified needs for housing and employment land. However, the SA/SEA is required to investigate “the likely situation if the plan were not to be adopted” and this is set out explicitly as Scenario A in Appendix VII of the SA/SEA Report (Appendix 5) and the implications for the baseline conditions are described in section 3 of the SA Report. 3.12 The SA/SEA also tested the effects of providing a smaller quantum of reserve sites. However, because it is beyond the scope of the Site Allocations Plan to revisit the housing requirement and Government advice is to continue to use the adopted Plan figures, it is considered appropriate to base the quantum of reserve sites in the Site Allocations Plan on the Core Strategy figure of 14,600. It should be noted that the quantum of reserve sites in the Preferred Options version is in excess of 2,920. This provides the Council with some flexibility should some sites fall away as the Site Allocations Plan is refined and finalised. This is considered a more appropriate approach than to have to retrospectively insert additional sites to achieve the desired quantum. 3.13 In addition to testing the effects of various approaches to identifying reserve sites, the SA/SEA also assesses the impacts of all aspects of the Site Allocations Plan, e.g. self-build and custom housebuilding sites and the approach to defining BUABs and the site specific proposals. The findings of these assessments are also set out in Appendix 5. Habitats Regulations Assessment 3.14 The Council is also required to undertake a Habitats Regulations Assessment (HRA) of the Stratford-on-Avon Local Plan, including the Site Allocations Plan. The aim of the HRA process is to assess the potential effects arising from a plan against the nature conservation objectives of any relevant site designated for its nature conservation importance. The Core Strategy has been shown to not have any adverse effects, alone or in-combination with other plans or projects, on the designated sites (more than 10 km distance) outside the District’s boundary, and this includes Policies CS.15 and CS16 in relation to Reserve Housing Sites. There are
also strong mitigation measures provided by Core Strategy Policy CS.6 Natural Environment. Therefore, it is not necessary to consider revisiting the HRA any further. 4. Members’ Comments 4.1 Councillor Pemberton, Deputy Leader and Portfolio Holder for Place is supportive of the Preferred Options version of the Site Allocations Plan and endorses the recommendations for public consultation. He is also keen that the Site Allocations Plan can be progressed as expediently as possible.
5. Implications of the proposal 5.1 Legal/Human Rights Implications 5.1.1 The Site Allocations Plan is a Development Plan Document and as such, when adopted, will form part of the statutory Development Plan for the District. The Preferred Options consultation falls under Regulation 18 of the 2012 Town and Country Planning (Local Planning) (England) Regulations. The Council has a duty to consult stakeholders and the community in respect of its plans and proposals, and will do so in accordance with its Statement of Community Involvement6. The Plan is also being prepared in accordance with the Council’s Local Development Scheme7. 5.1.2 A Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA) has also been undertaken to inform the preparation of the Site Allocations Plan to ensure that the plan achieves the legal requirement of the achievement of sustainable development. The SA/SEA will also be subject to consultation alongside the Plan itself. 5.1.3 The Plan will be made available for public consultation and anyone can have their say on any aspect of the plan. No specific human rights issues have been identified. An Equalities Impact Assessment has also be prepared and is attached at Appendix 6. This has not identified any impacts. 5.2 Financial 5.2.1 The costs associated with the preparation of the Plan are to be funded through the existing Policy budgets. 5.3 Environmental/Climate Change Implications 5.3.1 The Site Allocations Plan contains a number of land-use proposals and sites. Development of these sites will have environmental impacts. However, as part of the plan-making process, the Council is legally required through the SA/SEA to assess the impact on the environment of its proposals. This process not only seeks to minimise impacts but where impacts cannot be avoided, as far as possible, to mitigate them. 5.3.2 The Site Allocations Plan also specifically includes proposals in respect of low carbon development.
6 Available at www.stratford.gov.uk/sci 7 Available at www.stratford.gov.uk/lds
5.4 Council Plan 5.4.1 As a Development Plan Document, the Site Allocations Plan will help the Council achieve all five of the objectives of the Council Plan. By proactively seeking to manage development and shape the future of the District, the Site Allocations Plan seeks to create jobs and attract new inward investment and improve the public realm and ensure that housing needs are met. 5.5 Analysis of the effects on Equality 5.5.1 There are not considered to be any equality implications. To ensure that any implications are addressed, the Site Allocations Plan is informed by an Equalities Impact Assessment. Specifically, the Site Allocations Plan seeks to address the housing needs of those who wish to build or commission their own homes. The EqIA is attached at Appendix 6 and will be available for as part of the consultation documents. 5.6 Data Protection 5.6.1 There are not considered to be any data protection implications arising from this report.
6. Risk Assessment 6.1 There are two critical components of the Site Allocations Plan, namely, self-build and custom housebuilding sites and reserve housing sites. In respect of the former, the Council has a legal duty to meet identified needs under the Self-Build and Custom Housebuilding Act 2015 and associated Regulations. The Site Allocations Plan provides the opportunity to fulfil that responsibility in a timely manner. 6.2 In respect of the reserve housing sites, these enable the Council, as the Local Planning Authority, to retain control of and continue to manage development in the District. There is always a risk that some sites with planning permission will not get built or that additional housing needs are identified that need to be met within the District within the plan period. If such eventualities were to occur, it could lead to an undersupply of housing and accusations that the Core Strategy is out of date and no longer valid. Not only could this lead to additional speculative sites coming forward for development but also that such decisions are made by the planning appeals system as opposed to the Council’s Planning Committee. Reserve housing sites can help prevent this from happening and provide certainty to communities as to where alternative or additional development will take place rather than having to react to speculative applications or appeals. 6.3 Not endorsing the Preferred Options version would have two effects: firstly, it would signal that the Council is not prepared to take responsibility to proactively manage development in the District thus leaving its communities open to potentially speculative applications. Secondly, it would leave the Proposed Submission version of the Site Allocations Plan in place; a plan that would not be found sound at examination. Alternatively, if the Council decided to withdraw the Proposed Submission version without a replacement Site Allocations Plan, it would leave a plan- making vacuum. It is crucial therefore that the Preferred Options version can replace that previous Plan.
7. Conclusion 7.1 This report presents to Members the Council’s Preferred Options version of its Site Allocations Plan for Public Consultation. The Site Allocations Plan is a Development Plan Document that, when adopted, will accompany the Core Strategy and any made Neighbourhood Plans to determine planning applications in the District. This version of the plan replaces the previous Proposed Submission version from July 2019.
Tony Perks DEPUTY CHIEF EXECUTIVE
Background papers: None