Have your say on the South Warwickshire Local Plan
We are extremely concerned about a plan for new housing across South Warwickshire. Proposed by Stratford-on-Avon and Warwick District Councils, the Local Plan will:
- Decide the location of future houses and developments
- Review the Green Belt and remove our proposed designation of ‘Wildbelt’, to protect land for conservation
- Determine how much new habitat will be created for wildlife
- Determine how much land is protected from development.
Warwickshire Wildlife Trust is extremely concerned that the proposed areas of new housing and development include important Local Wildlife Sites, and loss of these sites and increased activity in these areas would threaten vulnerable wildlife.
Furthermore, in its current form the Local Plan contains no push for increasing biodiversity, which is essential for the health of the natural environment in South Warwickshire and beyond. There is also no proposal to review blue and green infrastructure in the area, which could further impact wildlife by reducing the number of safe ‘nature corridors’ between habitats.
Residents of Stratford-on-Avon or Warwick districts can respond to the Local Plan until Friday 7th March.
You can give your opinion on the Plan and raise your concerns over its impact on nature. More information and suggested responses to the questions can be found below.
Further information
The Local Plan includes new settlements and land for large-scale housing and employment next to and on important Local Wildlife Sites, and in many cases on existing Green Belt land. These areas act as vital refuges for wildlife in a landscape which is already fragmented by roads, housing, and development. Whilst it is important to provide housing and infrastructure, these developments must work with nature to deliver positive outcomes for both wildlife and people. House building targets in the plan seem to have been grossly exaggerated, putting additional pressure on important wildlife sites.
The Plan states ‘Biodiversity Net Gain’ will be used as a tool to deliver biodiversity ambitions and increased diversity of plant and animal life, but there is nothing ambitious about the already required target of just 10% net gain. We believe this target should be 20%. Other Councils in the UK have adopted plans with higher targets, such as Cornwall Council.
We are also very disappointed about the removal of the Wildbelt Policy. Previous consultations state 80% of respondents supported the inclusion of a Wildbelt Policy to designate land specifically for nature recovery. The Councils propose to remove the policy, contrary to previous consultation results. Local Nature Recovery Strategies (LNRS) are different from Wildbelt, as Wildbelt land would be for safeguarding sites in recovery. LNRS is not a designation, so it is unclear how LNRS alone would safeguard areas for nature.
The plan does not have an updated Green/Blue infrastructure evidence base and doesn’t include a detailed strategic policy looking at opportunities for wider corridors.
Suggested responses
The consultation asks a number of questions about the Local Plan. See our suggested responses below to help you answer.
Policy 36 - Protection of Sites, Habitats and Species
Do you agree with the approach laid out in Draft Policy Direction-36 - Protection of Sites, Habitats and Species?
No. The policy does not provide enough detail on how important environmental assets will be protected and enhanced, especially when a large number of the allocations are next to and even covering important designated Local Wildlife Sites.
Policy 37 - Local Nature Recovery Strategies
Do you agree with the approach laid out in Draft Policy Direction-37- Local Nature Recovery Strategy?
No. The policy says ‘expected to support the principles’ and this wording isn’t strong enough. If the Councils intend to reach 30% of land dedicated to nature and in recovery by 2030, as stated in the Environment Act 2021, then more ambitious targets are needed.
Policy 38 - Biodiversity net gain (BNG)
Do you agree with the approach laid out in Draft Policy Direction-38 - Biodiversity Net Gain?
No. Warwickshire Wildlife Trust is not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.
Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.
Policy 39 - Green/Blue infrastructure
Do you agree with the approach laid out in Draft Policy Direction 39?
No. It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base, in line with the NPPF and in time to influence chosen housing sites in the Local Plan.
Policy 42 - Trees, Hedges and Woodland
Do you agree with the approach laid out in Draft Policy Direction 42?
No, the plan should set out a tree canopy target, as other Councils have done, to be more ambitious at a wider scale.
Policy Direction 43a - Local Green Space
Do you agree with the approach laid out in Draft Policy Direction 43a- Local Green Space?
No. The Councils should not be relying on the few adopted Neighbourhood Plans. It is their duty to allocate Local Green Spaces for protection within their local plans and be proactive in regards to this important designation.
Policy Direction 45 - Areas of Restraint
Do you agree with the approach laid out in Draft Policy Direction 45- Areas of Restraint?
Yes, in principle. It is not clear if this allocation will be used to replace the important Green Belt, green infrastructure corridors and Wildbelt designations which should already be included in the Plan and given substantial weight. Green Belts shouldn’t include housing allocations.
Policy Direction 46 - Protecting the Cotswold National Landscape
Do you agree with the approach laid out in Draft Policy Direction-46- Protecting the Cotswold National Landscape?
Yes, in principle. The National Landscape Area is important, although it is essential to provide more details on how the buffer will work in practice, and that there are sufficient powers to refuse future applications that impact this important landscape area.
Policy Direction 47 - Special Landscape Areas
Do you agree with the approach laid out in Draft Policy Direction 47- Special Landscape Areas?
This policy needs stronger wording as it currently states that the SLA designation will not restrict development. In these areas, which are valuable for wildlife, development must be restricted and directed towards lower value areas where the impact on nature will not be so significant.
Policy 48 - Protecting and Enhancing Landscape Character
Do you agree with the approach laid out in Draft Policy Direction-48- Protecting and Enhancing Landscape Character
Development should not be allowed in the area, and the caveats should be removed (such as that ‘unless there would be an over-riding benefit, for instance to meet an evidenced local housing need’). The Local Plan should be allocating suitable land for housing need.
Policy 1 - Housing
Warwickshire Wildlife Trust is extremely concerned by the scale of the proposed housing, which seems grossly exaggerated. The Plan reports a need for 1,679 dwellings per annum, but suggests allocating 600 surplus houses to allow sufficient flexibility. This will have a significant negative impact on the important habitats and protected species across the area. The Local Plan must deliver houses in suitable numbers for residents but in suitable locations and must not disregard the Environment Act 2021 target of 30% of land allocated to nature and in recovery by 2030.
The Plan also allocates many housing sites in the Green Belt, which is an important land designation intended to protect the edges of wildlife sites and provide a transitional and safe area for important protected and declining species.
Warwickshire Wildlife Trust is not satisfied that the Councils have carried out a detailed Green Belt Review to include this land, particularly the Stage 2 work as well landscape impact assessments. They have not done individual Flood Assessment work (SFRA part 2s), which should be carried out in order to help choose sites.
Housing and employment land allocation concerns:
Housing Question: Do you have any comments on a specific site proposal or the HELAA results? (please include site name and reference number as identified on the interactive map).
Please view a list of the key Local Wildlife Sites which would be impacted. The Council should be using the most up to date Local Wildlife Site layer available.
South Coventry SG01 and 2 - Broadwells Wood and Black Waste Wood Local Wildlife Site (LWS) and Wainbody and Kenilworth Road Woods LWS, Kenilworth Common LWS and River Sowe & Finham Brook & lakes
SG03 South Coventry - Stonebridge Meadows LWS and River Sowe Potential local Wildlife Site
SG05 North of Leamington - River Avon LWS and Hill Wootton Farm Meadows Potential local Wildlife Site., North and South Cubbington Woods LWS, Waverley and Weston Wood LWS
SG12 Southam - Long Itchinghton Quarry LWS and River Itchen PLWS
SG13 - Lighthorne Quarry LWS and Chesterton Wood LWS
SG14 - Oakham Coppice LWS, River Avon LWS, Itchington Holt and the Centenary Way
SG15/16 South of Leamington - River Avon and tributaries LWS and Hampton Wood LWS, Grove Fields Lane LWS, Wasperton Manor Farm LWS, Hampton Lucy Escarpment LWS, Charlescote gravel pits and Thelsford brook LWS
SG10/11 - River Avon and tributaries LWS
SG10/X1 - Oakley Wood
SG17 Shipston upon Stour - River Stour PLWS
SG20 - River Avon and tributaries LWS
SG18 - Hatton Hill Fields PLWS, Brownley Green Lane LWS, Home Farn Woods PLWS, Hatton Park LWS and Grand Union Canal West LWS
SG19 - River Avon LWS and disused railway PLWS and Bridgetown Fields LWS
SG20 - River Avon LWS
SG21 - River arrow LWS and Coldcomfort Wood PLWS
SG24 - Stratford-Upon-Avon Canal
SG07 - River Avon LWS and Budbrooke Farm woodlands LWS and Warwick Cemetery LWS
SG22 - New Coppice LWS, Coughton Park LWS Studley
SG23 - Mockley wood LWS, River Alne, Mockley Manor Farm PLWS
Do you agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements?
No. Warwickshire Wildlife Trust (WKWT) is extremely concerned regarding the allocation of a new settlement and the potential environmental impacts. Local Wildlife Sites, Potential Wildlife Sites, Sites of Special Scientific Interest, designated Nature Reserves and other important sites are incredibly important for wildlife within our natural landscape. It doesn’t appear that the Councils have considered these in the selection of their new settlement locations.
Several proposed settlements in the Local Plan are within existing Green Belt, which if built on would have a negative impact on designated sites and wildlife including protected and declining species at these locations, which act as transitional buffers for nature and would reduce access to nature for people living in urban areas.
Impacted Local Wildlife Sites are listed below:
A1 /2- River Alne LWS, Round Wood and Long Wood LWS, Grove Wood PLWS and Grotton Hill Wood LWS
C1 - Gilbert’s and Claypits coppices, Linnear Woodland LWS
E1 Allocation – This site is very concerningly directly adjoining and Area of Outstanding Natural Beauty, Meon Vale LWS, River Avon LWS and the greenway, dismantled railway, Welford Hill Farm Meadows PLWS, Rumerhill Coppice PLWS and Coxmere Coppice PLWS
BW Allocation - Newfoundland Wood LWS, Stratford Canal PLWS, River Avon LWS and Wood by Churchill
G1 Allocation - Itchington Holt PLWS
Allocation F1 - Long Itchington and Ufton woods SSSI
Allocation F2 - Deppers Bridge Meadow PLWS
Allocation F3 - South Southam LWS and Disused railway LWS.
Employment
Do you agree with the approach laid out in Policy- 12-Locations for Employment Growth?
Evidence recommends that between 75 and 125ha of land be allocated for Employment Growth, however the Plan proposes 125ha, the upper limit of development. This is unnecessary and will have larger impacts on important environmental assets and habitats in the area, as well as designated sites and protected species, and does not align with the Government’s 30% by 2030 targets.
Warwickshire Wildlife Trust is also concerned regarding the lack of up to date employment need data, and no evidence for Strategic Industrial Need before 2045.
The allocations are directly next to Chesterton Wood, an important Local Wildlife site, and extremely close to the River Avon and Tributaries LWS, Redlands Brake PLWS, New Waters LWS, Budbrooke Farm Woodlands and Black Brake Plantation LWS, development on which would have detrimental effects for wildlife and climate change targets.