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1.1 These submissions relate to the proposals for meeting the housing provision for Leek Wootton of 70 to 90 dwellings as set out within the Revised Development Strategy. These submissions need to be read in the context of Bloor Homes submissions in respect of paragraph 4.10.
1.2 Bloor Homes do not support the Council's Preferred Options for the village, and do not consider the strategy is deliverable or that the sites identified are the most appropriate for allocation when considered against the alternative options north and south of Hill Wootton Road.
1.3 The land at Woodcote House (Preferred Options sites 1 to 4) comprises of a Grade II listed building and its setting, as well as containing a significant number of protected trees and being designated a locally important historic park included in the Warwick District Local Register. Preferred Option 2 also adjoins the Leek Wootton Conservation Area.
1.4 The land at Woodcote House is clearly a heritage asset and of high environmental value. In accordance with paragraph 129 of the National Planning Policy Framework, the Council must identify and assess the particular significance of the asset before considering the impact of its proposals. No such assessment has been published by the Council in order to inform the consultation report, and the identification of the land at Woodcote House as a Preferred Option. The reference within the Council's evidence to requiring 'comprehensive master planning' and a 'sensitive approach' to development suggests that no assessment has yet to take place.
1.5 In this context and in accordance with paragraph 14 of the Framework, there is considerable uncertainty as to whether all of the land at Woodcote House can be developed due to the potential harm to a designated heritage asset. Moreover, there is also considerable uncertainty as to whether the land can deliver the number of dwellings proposed (75 in total). By way of example, Preferred Option 2 is identified for 10 dwellings and yet is bounded on two sides by public highway making the number of properties difficult to achieve given the need for development to enhance the character of the area and maintain appropriate distance separation standards.
1.6 It is considered therefore that the land at Woodcote House is unlikely to be able to satisfactorily accommodate 75 dwellings of an appropriate housing mix to meet the needs of the village without causing significant adverse impacts in respect of the historic environment and failing to achieve good design.
1.7 It is also noted the land is not currently available for development, although the landowner has indicated their intention to release some or all of the land for development. Notwithstanding the previous marketing exercise, it remains currently as operational land required by the Police Authority and as such there is a degree of uncertainty as to the timing and extent of release of land for development.
1.8 In this context, Bloor Homes do not therefore consider that a strategy within the draft Local Plan that places reliance on the housing provision for Leek Wootton being almost entirely met at Woodcote House would be found sound. There are significant doubts as to whether the plan would be effective in demonstrating it is deliverable in respect of development at Woodcote House. In accordance with paragraph 14 of the Framework, flexibility is required to ensure the assessed housing need and provision for Leek Wootton is met.
1.9 A further Preferred Option is identified (site 5) to the south of the village to accommodate 5 dwellings. Development of this site would extend a 'finger' of development away from the village, and its location would not satisfactorily integrate with the built form of the village as required by paragraph 61 of the Framework. This site would not therefore be a suitable location for development, and it would not represent sustainable development.
1.10 Paragraphs 17 and 110 of the National Planning Policy Framework require plans to allocate land of the least environmental or amenity value. Bloor Homes consider the land to the north and south of Hill Wootton Road is of lesser environmental value, and its development would not result in any significant adverse impacts.
1.11 The land has no environmental or historic designations, and is acknowledged by the Council as being of only medium landscape value recognising it is bounded on three sides by residential development, Hill Wootton Road and the A46. The land has also been surveyed and is considered of limited ecological value (see a technical appraisal of the land north of Hill Wootton Road submitted separately).
1.12 The Council's evidence refers to the land acting as an 'environmental buffer' to the A46, although this is not a designation within the adopted Local Plan and no justification is given as to why a buffer is required for the village. It is noted that similar land between the edge of Warwick and the A46 has been allocated for development previously (South West Warwick), and land between the edge of Kenilworth and the A46 is now proposed for development and not retained as an 'environmental buffer'.
1.13 Having regard to the evidence, the land north and south of Hill Wootton Road is therefore considered to be of lesser environmental value when compared to the Preferred Options.
1.14 The land (both north and south of Hill Wootton Road) is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). In order to provide evidence to the Council on this matter, Bloor Homes have received a technical appraisal of the land to the north of Hill Wootton for a development of circa 40 homes. Its findings are also relevant to the land to the south and this appraisal is submitted separately to the Council.
1.15 The land is therefore available for development now, technically developable, viable, and is in a suitable location in that it is:
* well located in relation to village services and facilities, such that it can enhance and maintain their vitality, as well as ensuring the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework; and,
* capable of successfully integrating with the village in accordance with paragraph 61 of the Framework through extending built development along Hill Wootton Road up to a defensible boundary (the A46) and thereby avoiding harm to the wider countryside and setting of the village.
1.16 Bloor Homes acknowledge that development of the land will need to have regard to the impact of road noise as recognised within the Council's evidence. Noise monitoring and an assessment of the findings have been undertaken to inform these representations within the technical appraisal. This concludes that road noise is not considered likely to cause significant adverse impact, subject to satisfactory mitigation through consideration of an appropriate layout of development, internal layout, and acoustic glazing.
1.17 Bloor Homes have also assessed the highway implications of development of this area for up to 40 dwellings. Traffic generated from the development would not 'materially' increase levels on the road network, and could be safely and adequately accommodated by the existing footpath and road network and junctions. Furthermore, accommodating some of the housing provision for Leek Wootton in this location would have the benefit of spreading the impact of additional traffic on the junctions along Warwick Road. The Preferred Options at present will load the majority of additional traffic movements on an acknowledged sub-standard junction of Woodcote Lane with Warwick Road, and with poor pedestrian footways along Woodcote Lane.
1.18 The exact boundary of the land to be allocated and the quantum of housing development that can be accommodated needs to be informed by detailed master planning. This has commenced and will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.19 Bloor Homes do not therefore consider the Preferred Options represents the most appropriate allocation when considered against the alternative options, north and south of Hill Wootton Road.
1.20 Furthermore, Bloor Homes do not consider that there are any adverse impacts of the development of the land north and south of Hill Wootton Road which would significantly and demonstrably outweigh the benefits when assessed against the policies of the Framework as a whole.
1.21 Bloor Homes therefore respectfully request the Council identify land north and south of Hill Wootton Road as an allocation within their Draft Local Plan recognising that the land is of lesser environmental value, and is consistent with the policies of the Framework.