Report to Stratford-on-Avon District Council by Pete Drew BSc (Hons), Dip TP (Dist) MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government Date 20 June 2016 PLANNING AND COMPULSORY PURCHASE ACT 2004 (AS AMENDED) SECTION 20 REPORT ON THE EXAMINATION INTO THE STRATFORD-ON-AVON CORE STRATEGY Document submitted for examination on 30 September 2014 Hearings held between 6 and 29 January 2015 and 12 and 21 January 2016 Accompanied site inspections made on 2 and 3 February 2015 and 21 January 2016 File Ref: J3720/429/2 Contents Topic Page Table of abbreviations used in this report 3 Non-Technical Summary 4 Introduction and Background 5 Assessment of Duty to Co-operate 8 Assessment of Soundness 8 Main issues 8 Issue 1: Objectively Assessed Need 9 Issue 2: Sustainability Appraisal 27 Issue 3: Development strategy, including whether the 43 allocated housing sites are sound Issue 4: Economic development 83 Issue 5: Housing land supply 92 Issue 6: Affordable housing 118 Issue 7: Housing mix and type 123 Issue 8: Green Belt 129 Issue 9: Historic environment and design 131 Issue 10: Climate change and natural environment 133 Issue 11: Retail development 136 Issue 12: Miscellaneous policy issues: (i) special landscape areas; (ii) areas of restraint; (iii) the area strategies; (iv) accommodation for gypsies, travellers and travelling showpeople; (v) tourism and leisure development; (vi) healthy communities; (vii) transport and communications; (viii) developer contributions; and, (ix) the evening and night-time economy 138 Issue 13: Delivery, monitoring and review 148 Assessment of Legal Compliance 150 Overall conclusion and recommendation 151 -2 Stratford-on-Avon Core Strategy, Inspector’s Report June 2016 Table of Abbreviations Used in this Report AML Aston Martin Lagonda BUABs Built-Up Area Boundaries CRT Canal & River Trust CCG Clinical Commissioning Group CIL Community Infrastructure Levy CS Core Strategy CSH Code for Sustainable Homes CW Coventry & Warwickshire DMC Development Management Consideration DtC Duty to Co-operate dpa dwellings per annum EHO Environmental Health Officer EPB Economic Prosperity Board ELS Employment Land Study EA Environment Agency GLH Gaydon Lighthorne Heath ha hectares HE Highways England HMA Housing Market Area IDP Infrastructure Delivery Plan IC Interim Conclusions JLR Jaguar Land Rover LEP Local Economic Partnership LSV Local Service Village LPA Local Planning Authority LMA Long Marston Airfield LRBS Large Rural Brownfield Sites LWS Local Wildlife Site MM Main Modification MoU Memorandum of Understanding MRC Main Rural Centre NE Natural England NP Neighbourhood Plan OAN Objective Assessment of Housing Need PAS Planning Advisory Service PPA Planning Performance Agreement SA Sustainability Appraisal SAP Site Allocations Plan SEP Strategic Economic Plan SHLAA Strategic Housing Land Availability Assessment SHMA Strategic Housing Market Assessment SPD Supplementary Planning Document SSSI Site of Special Scientific Interest STA Strategic Transport Assessment STC Southam Town Council STP Stratford Transport Package STW Severn Trent Water SWRR South-Western Relief Road the 2004 Act Planning & Compulsory Purchase Act 2004 (as amended) - 3 - Stratford-on-Avon Core Strategy, Inspector’s Report June 2016 the 1990 Act Planning (Listed Buildings and Conservation Areas) Act 1990 the Act Town and Country Planning Act 1990 (as amended) the Council Stratford-on-Avon District Council the Framework National Planning Policy Framework the Guidance Planning Practice Guidance the 2004 The Environmental Assessment of Plans and Programmes Regulations Regulations 2004 the 2012 The Town & Country Planning (Local Planning) (England) Regulations Regulations 2012 Non-Technical Summary This report concludes that the Stratford-on-Avon Core Strategy provides an appropriate basis for the planning of the District, providing a number of main modifications are made to the Plan. Stratford-on-Avon District Council has specifically requested me to recommend any modifications necessary to enable the Plan to be adopted. Almost all of the recommended changes have been put forward by the Council in response to matters discussed during the examination. However, where necessary, I have amended detailed wording to reflect the representations made by participants and/or added consequential modifications. I recommend their inclusion after considering the representations from other parties on these issues, including those made in response to the consultation in the Spring of 2016. The MMs can be summarised as follows: To increase the Plan’s housing requirement to reflect the further work that has been done since the original Hearings and my interim conclusions; To make additional site allocations, including a new settlement at Long Marston Airfield [LMA] associated with a new bypass for Stratford-upon- Avon, and significant additional allocations at Stratford-upon-Avon and Southam, in order to help to meet the increased housing requirement; To update other site allocations, including a new settlement at Gaydon Lighthorne Heath [GLH], in the light of changed circumstances, including an additional employment allocation to meet the needs of Aston Martin Lagonda [AML]; To delete one site allocation for employment land [SUA.3, East of Birmingham Road] in respect of which exceptional circumstances have not been shown in order to justify its release from the Green Belt; To introduce one site allocation for employment land [SUA.5, Atherstone Airfield] which is considered to be necessary to provide for the Council’s ambition to redevelop the Canal Quarter; To provide effective mechanisms to address any failure in the delivery of the development sought by the Plan and to meet other housing needs as they are identified, including a new policy for a Plan review and more detail on the approach to the release of reserve sites; and, A number of changes to a range of policies in order to ensure that they are positively prepared, justified, effective and consistent with national policy. - 4 - Stratford-on-Avon Core Strategy, Inspector’s Report June 2016 Introduction and background 1. This report contains my assessment of the Stratford-on-Avon Core Strategy [CS] in terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended) [the 2004 Act]. It briefly comments on the Duty to Co-operate [DtC], but focusses on whether the Plan is sound and compliant with the legal requirements. Paragraph 182 of the National Planning Policy Framework [the Framework] makes clear that to be sound, a Local Plan should be positively prepared, justified, effective and consistent with national policy. 2. The starting point for the examination is the assumption the Local Planning Authority [LPA] has submitted what it considers to be a sound plan. The basis for the examination is the submitted draft plan, i.e. the Stratford-on-Avon Core Strategy Proposed Submission Version1. This was the subject of consultation in July 2014, as a result of which a number of modifications were proposed that form part of the main modifications [MMs]. I have had regard to the Proposed modifications in response to the Inspector’s Interim Conclusions2 insofar as it seeks to substantially revise three key policies in the Plan, allied to which a number of additional housing allocations have been identified. 3. Hearings were originally held in January 2015 but, after the issue of Interim Conclusions [IC] in March 2015, the examination was suspended. The IC gave reasons why the legal duty to co-operate in the preparation of the Plan had been met and found that the employment land requirement figure set out in submitted Policy CS.21 was soundly based. However it found shortcomings in the approach taken to the assessment of the housing requirement and problems with the Sustainability Appraisal [SA]. The suspension allowed the Council to produce further evidence in relation to housing and to revisit the SA. This evidence was produced during 2015. The new evidence along with the Council’s proposed changes to relevant parts of the Plan was the subject of further consultation for six weeks between 13 August to 25 September 2015. Hearings were re-convened in January 2016 during which the need for further MMs was identified. Comments were invited from participants on selected documents that were submitted during and immediately after the resumed Hearings and these have been taken into account. 4. My report deals with the MMs that are needed to make the Plan sound and legally compliant and these are identified in bold as [MM]. In accordance with section 20(7C) of the Act, Stratford-on-Avon District Council [the Council] requested that I should make any modifications needed to rectify matters that make the Plan unsound/not legally compliant and thus incapable of being adopted. The MMs relate to the policies and the principal changes to the reasoned justification. This report needs to be read in conjunction with the IC, which is at Appendix 1, which covers some points in detail that are not repeated. The updated Schedule of MMs is set out in Appendix 2. The updated Infrastructure Delivery Plan [IDP] is set out in Appendix 3. The updated Schedule of Infrastructure Projects is set out in Appendix 4. 5. The MMs that are necessary for soundness all relate to matters that were discussed at the examination Hearings. Following these discussions, the 1 Document Ref. ED.1.1. 2 Document Ref. ED.11.1. - 5 - Stratford-on-Avon Core Strategy, Inspector’s Report June 2016 Council prepared a schedule of proposed MMs and this schedule has been subject to public consultation for six weeks from 31 March to 12 May 2016. I have taken account of the consultation responses in coming to my conclusions in this report and in this light some amendments to the detailed wording of the MMs have been made and consequential modifications have been added where these are necessary for consistency or clarity. None of these amendments significantly alters the content of the modifications published for consultation or undermines the participatory processes and SA that has been undertaken.