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1.1 These submissions relate to the proposals for meeting the housing provision for Hatton Park 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 Option for the village. The land north of Birmingham Road is not considered the most appropriate site for allocation when considered against the alternative discounted Option 2 (land between Hatton Park and Canal Road).
1.3 Having regard to the Council's evidence, the land north of Birmingham Road is considered to be of higher environmental and amenity value compared to Option 2. The land is acknowledged within the Council's evidence as being within a highly visible area, and that its development would negatively impact on the visual amenity of the Green Belt. This is a prominent site when viewed from within and outside of the village, and would extend built development along Birmingham Road into open countryside in what might be described as a more sensitive gap locally between the settlement and the town of Warwick.
1.4 The land north of Birmingham Road is also of significant environmental value in the role it plays in contributing to the integrity of the Ancient Woodland and potential Local Wildlife Site (Smith's Covert) to the immediate north of the site. The land represents the only physical link between the Ancient Woodland and open countryside.
1.5 The eastern boundary of the land north of Birmingham Road is also formed by the original 'drive' to the former King Edward VII Memorial Sanatorium. The existing avenue of trees along this 'drive' is of historical significance to the area, and as such is a heritage asset.
1.6 The land to the north of Birmingham Road is therefore of significant visual, ecological and historic value. Moreover, its development is only assessed as potentially suitable by the Council with 'substantial buffering'. No information is provided as to how large the buffering would need to be to retain the integrity of these assets, however, they would clearly require a significant proportion of the land to be kept open.
1.7 Given the need also to provide adequate distance separation from the adjoining residential properties within Hatton Park and an appropriate environmental buffer from the Birmingham Road, a significant proportion of the land on all four sides is acknowledged as not suitable for development due to its environmental and amenity value.
1.8 In comparison, the value of Option 2 is not considered of such significance. Whilst the canal towpath to the south of the site has some ecological value as a corridor for wildlife (although it is not formally designated), a substantial tree belt already exists along this boundary which would be retained, enhanced and managed as part of any development.
1.9 The Council's evidence acknowledges that this tree belt provides 'good tree cover' and forms an 'important setting for the canal and its flight of locks', separating the locks physically and visually from the site. The extent to which Option 2 therefore contributes to the integrity of the ecological value of the canal towpath, or the amenity value of the locks themselves is considered very limited. Moreover, as a general principle, it is noted that the Council have identified preferred options on other greenfield sites alongside the canal at Lapworth and Radford Semele in similar circumstances.
1.10 Having regard to the Council's evidence of the wider landscape and ecological value of the site, particularly its role as a green link or buffer, an assessment has been undertaken of the extent of harm that might be caused by the development of the site on the character and value of the wider area. This concludes that the site is considered to be appropriate for development in landscape and visual terms due to its visual containment (particularly with the retention of the belt of vegetation alongside the canal), its ability to retain important green functions and key visual links as part of any development layout, and its opportunity to consolidate the surrounding built form.
1.11 Paragraphs 17 and 110 of the National Planning Policy Framework require plans to allocate land of the least environmental or amenity value. Having regard to the evidence, the land north of Birmingham Road is not considered to be of lesser environmental value when compared to Option 2.
1.12 Paragraphs 17 and 110 also require consideration to be given to whether the development of the site would be consistent with other policies of the Framework. In this context, particular regard must be given to the requirement of paragraph 28 of the Framework for plans to support a prosperous rural economy.
1.13 The development of Option 2 is considered more consistent with the policies of the Framework than the Preferred Option for the following reasons.
1.14 Option 2 is better located in terms of its proximity to village services and facilities, such as the village shop, village halls, pubs, church, Hatton Locks and visitor facilities, and primary school (as shown on the plan submitted separately of the facilities within the area). Furthermore, the ability of the development to provide a safe means of pedestrian access across the Birmingham Road will ensure that walking or cycling are attractive options for residents of the development to access the shop and village hall within Hatton Park.
1.15 Development of Option 2 is therefore more likely than the Preferred Option to enhance and maintain the vitality of village services as required by paragraph 28 of the Framework, and also noted as a key requirement for the Council in allocating development to the rural area. Moreover, its location will ensure the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework.
1.16 The development of Option 2 is also able to add to the built form of the village in a way that improves the way it functions, as required by paragraph 64 of the Framework. The development can deliver improved access for pedestrians and cyclists to the canal locks facilities from Hatton Park by providing a more direct and safer link across the Birmingham Road and through the new development (as shown on the layout plan submitted separately). In addition, the provision of a new junction for Brownley Green Lane with Birmingham Road will improve road safety and reduce speeds of vehicles travelling through the village.
1.17 These proposals will improve the safety and convenience for residents and visitors going between Hatton Park and the canal locks facilities and footpaths beyond which will improve the way the settlement functions. Furthermore, these proposals will successfully integrate the development with the village as required by paragraphs 61 and 70 of the Framework.
1.18 The development of Option 2 also has the potential to incorporate an area of car parking to serve visitors to the canal network as well as a an alternative vehicular access to the locks complex. This would provide additional parking and means of access to the canal which could reduce or even potentially remove all visitor traffic from using Canal Road and its existing junction with the Birmingham Road. The Council will be aware that it is recognised within the Parish Plan that this is a junction requiring improvements to address safety issues. Again, therefore, the development of Option 2 has the potential to make a significant contribution to safety within the village and the way in which it functions.
1.19 Furthermore, the above proposals for improved linkages and access that would form part of the development of Option 2 will have a significant positive impact on rural tourism and leisure facilities which will be of benefit to local businesses and communities. The allocation of this site would therefore be entirely in accordance with paragraph 28 of the Framework, in so far as supporting rural economic growth.
1.20 In comparison, there is little detail provided in the consultation report as to how the Preferred Option will improve the way Hatton Park functions or how it will be integrated with the settlement. The development of the Preferred Option with its primary access onto Birmingham Road to the south east of the village has the potential to 'turn its back' on the village and encourage its residents to travel to Warwick or Hampton Magna for their day-to-day needs. Moreover, the requirement for a 'substantial buffer' to the north of the site adjoining the Ancient Woodland will limit the extent to which the development can integrate with the existing village.
1.21 Its development is therefore unlikely to improve the way the village functions, and is less likely to enhance or maintain village services, or contribute towards economic growth in the area. The development of the Preferred Option would therefore result in adverse impacts when assessed against the policies of the Framework.
1.22 Bloor Homes do not therefore consider the Preferred Option represents the most appropriate when considered against the alternative, Option 2.
1.23 Furthermore, Bloor Homes do not consider that there are any adverse impacts of the development of Option 2 which would significantly and demonstrably outweigh the benefits when assessed against the policies of the Framework as a whole.
1.24 Option 2 is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). The land is available for development now, technically developable (a site assessment report is submitted separately identifying the ability of the land to be developed), viable, and is in a suitable location for the reasons set out above. Initial master planning demonstrates that the quantum of development (70 to 90 dwellings) and associated land uses, including suitable open spaces, buffers, and a new access road and parking can be provided on the site. An illustrative masterplan is submitted with these representations to demonstrate how the site might be developed. Further details will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.25 Bloor Homes therefore respectfully request the Council identify Option 2 as an allocation within their Draft Local Plan recognising that the site is of lesser environmental value, and that its development would meet a number of objectives of the Framework.