Consultation on Revisions to Warwick DC Local Plan
I am writing in response to the consultation on the revisions to the Local Plan which Warwick District Council is currently proposing. Specifically, I wish to object to the revised proposals for Hampton Magna, namely the increase in the density of housing on land to the south of Arras Boulevard, and the allocation of land south of Lloyd Close for 115 houses.
My objection addresses three issues:-
Whether the plan is legally compliant.
Whether the proposals are sustainable in the context of the district's needs
Whether there are alternatives which would better meet the needs.
There are a number of issues which potentially question whether the plan is legally compliant.
The change to the plan for Hampton Magna more than doubles the amount of housing proposed. As a consequence, the plan constitutes a major revision to the proposals. On the grounds of reasonableness, an issue governed by the Wednesbury principle, and indeed under the district council's own policies on communicating with local communities, there should have been consultation on the plan with Budbrooke Parish Council and the local community. There was none in advance of the proposals being published and agreed for consultation. Moreover, the documentation relating to the district council decision was not published until the latest possible date for the consultation, and it is in a form which is unintelligible to a layman.
Secondly, the plan considers proposals for Hampton Magna and Hatton Park separately. Other than a small local shop, there are no facilities in Hatton Park, and residents there use the facilities (school, GP surgery, etc.) in Hampton Magna. The impact of development in both Hampton Magna and Hatton Park should have been considered jointly, and has not been.
Thirdly, at a public meeting, residents of Hampton Magna were informed that the plan has been prepared only on the basis of taking account of land available for sale. This means that a substantial number of sites, indeed most sites, have simply not been considered. Given that a compulsory purchase process takes eighteen months typically, and the plan is for the period up to 2029, this again has to be of questionable legality in a Wednesbury context.
Finally, the proposals for Hampton Magna are all on land currently delegated as greenbelt. Greenbelt development is permitted in situations where an exceptional need is demonstrated. The revised local plan over-programmes the amount of housing required in the district by 800. This would tend to indicate that far from an exceptional need for greenbelt development, for the development of 800 properties there is, in fact, no need whatsoever. The threshold for exceptional need cannot, therefore, be met.
In summary, for the foregoing reasons, there is a significant question of whether the local plan is legally compliant, and I would contend that it is not.
The issue of sustainability relates to a number of factors;
i) whether infrastructure is sound and adequate and has both the capacity and capability to absorb additional load;
ii) whether there is adequate access to employment in a way which does not impact on the environment unduly detrimentally;
iii) whether it meets the district's housing needs in a reasonable way.
On the first of these issues, Hampton Magna has a range of community facilities, a school, a shop with post office, a beauty salon, and coffee shop, a public house and a GP surgery. These facilities are also extensively used by residents of Hatton Park which has only a small shop.
The school has room on site to expand, but parking around the school is a major issue, i.e. it is unsafe, and there is no possibility of sensibly absorbing the additional Hampton Magna and Hatton Park students. Other respondents have, I understand, included photographs of the current parking problems.
The GP surgery does not have room to expand in size, and already suffers from significant parking problems, with a very small number of parking spaces.
The most significant infrastructure constraint is provided by the roads into the village, all of which have severe restrictions. Ugly Bridge Road and Old Budbrooke Road have height restrictions. Both of these and Woodway have weight restrictions (which would have significant implications for developers' heavy traffic). All roads into the village are single lane at some point along their length (although Woodway purports to be two-way, which it is not). A study for the district council demonstrated that with only an additional 130 vehicles the road capacity would be exceeded in the morning rush hour, leading to routine traffic hold-ups. The revised proposal worsens this. There are no road proposals in the parish which would alleviate this (a proposed development at the A46 roundabout would have no effect on the parish roads. Even disregarding other impacts of the development, simply from a transportation perspective, any development on the scale proposed would require new access roads into the village from either the Henley road or the A46 directly.
Hampton Magna has had longstanding problems with its sewerage and drainage systems (the Parish Council have regularly met STWA and local councils about the issues). These would require major upgrading to cope with development on the scale now proposed.
Air quality in the village is poor. The revision to the plan is being proposed to take account of an additional housing need falling into the district from a corresponding shortfall in Coventry. It is, therefore, entirely likely that a reasonable proportion of new residents would have Coventry as their place of work. Despite Hampton Magna having excellent rail links, and some local bus services, travelling to Coventry by public transport would mean journeys in excess of an hour. In all likelihood, as a consequence, car usage would increase significantly in the village, further degrading air quality.
The proposed density of development is different to that currently found within the village, which is relatively low density with plenty of green areas and open spaces. Higher density development would change the intrinsic character of what is, despite it's relatively young age, a very rural village.
The proposal for Lloyd Close would also degrade the amenities of the village in two ways. Firstly, and recognising that no individual has a right to a view, the view across the fields to the south of Lloyd Close is an important public amenity, in that there are very few sites (the proposed area of development and Hampton on the Hill only, in all likelihood) where both of the historically important Warwick North and South Gates (St Mary's Church and Warwick Castle) can be seen together. As such, this is an important vista which should materially affect whether the exceptional use of a greenfield site can be considered in this context. Warwick has had a history of losing significant and important views (for example, through the development of the County Council's Barrack Street building), and it would be tragic to lose this as a public amenity. Secondly, the site, which has a footpath (dating back several hundred years) running across it, is used daily by walkers and dog walkers. Bats, a protected species, have also been reported on this site, and consequently a full survey should have been carried out.
The question of how the employment of incoming residents would impact on the village is an important one. There are very limited employment opportunities within the village. Good rail links exist to Birmingham and London, and intermediate stations, but, as stated earlier, public transport links to Coventry are very poor, and road links are along already heavily congested roads. Additionally, while rail links are good, parking at Warwick Parkway already operates at or near capacity, and four extensions to parking provision have already had to be made, with limited potential for further expansion. New residents from both Hampton Magna and Hatton Park would place additional demands on this parking.
Finally, an important consideration is whether the revised proposals meet the identified needs in the most appropriate way. A number of issues are relevant here.
As the additional need derives from a shortfall of housing in Coventry, having the largest proportionate increase in housing in a village 11.8 miles from Coventry, and without adequate public transport links to the city, is perverse.
The presumption of only using land available for sale was coupled with a wholly unreasonably short period for vendors to notify the Council of land availability (which was, I believe, only fifteen days) means that many potentially suitable sites have simply not been considered.
There is a Warwickshire village, Bubbenhall, which is much closer to Coventry (only 6.7miles), with similar facilities to Hampton Magna (and considerably better facilities than Hatton Park), and with considerably better transport links to Coventry, which has been excluded from consideration as a growth village, by the adoption of an arbitrary cut-off by the district council in a subjectively scored assessment matrix. This is unreasonable, and Bubbenhall should be reconsidered as a growth village.
If development at the revised level is required in Warwick, there are also freestanding greenfield sites (including a large site opposite Ajax football club on the Henley Road, which should have merited consideration for the development of a wholly new village (as Hampton Magna and Hatton Park were when they were developed). This would provide a number of advantages:-
The amenity of existing villages would be substantially unaffected.
The costs of creating the wholly new infrastructure required for a new village are much more readily determinable, meaning that the costs can be much more readily recovered through s106 agreements with developers, rightly limiting the costs falling on the public purse. Writing as a retired local authority treasurer, it is notoriously difficult to recover from developers anything like the full cost of enhancements to existing infrastructure for smaller scale developments.
A new development would much more clearly meet the threshold for exceptional development in the greenbelt, albeit subject to my earlier comment about whether any over-programming of provision could be considered legally to meet this threshold.
In summary, there are significant question marks about whether Warwick District Council's revised plan is legally compliant. There are further significant concerns about the sustainability of the revised proposals, and whether they provide for the most appropriate way of meeting the identified housing need for the district and the overspill need from Coventry. My conclusion would be that they do not.

see attached

Shirley Estates (Developments) Ltd wish to support Modifications 3 and 7 and paragraphs 2.22 and 2.56 in that they allow for rural developments on Greenfield sites next to built up rural areas and recognise the importance of windfall sites in achieving the 5 year housing supply

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

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We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

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Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

See attached

See attached

1.0 Introduction
1.1. McLoughlin Planning are instructed by Centaur Homes to submit representations on the proposed modifications to the Warwick Local Plan 2011-2029. This document will take each relevant modification in turn and where necessary, refer to the Evidence Base, National Planning Policy Framework (NPPF), Planning Practice Guidance (PPG) and other material considerations.
1.2. By way of context, Centaur Homes has an interest in Land at Old Budbrooke Road, (also referred to as Maple Lodge or land north of) as shown on the enclosed site location plan and seek its allocation for residential development within the emerging Local Plan. These representations cover policies relevant to the allocated housing sites at Hampton Magna.
1.3. Centaur's site is adjacent to the settlement boundary on the western side of the village. Hampton Magna is identified within the Local Plan as a 'Growth Village' and suitable for development. It is ideally located to provide sustainable housing development in accordance with the Framework paragraph 55 and has excellent connectivity to Warwick and the wider area.
1.4. The Old Budbrooke site extends to 5.5 hectares in size. This consists of a mix of brownfield and greenfield land, with approximately 1.5 hectares of this being brownfield. The site already benefits from an access fronting onto Old Budbrooke Road and facing the existing village. the site is contained by the existing road network to the south, east and west, with mature field boundaries to the northern edge. The site sits within a valley that rises up to east and the village.
1.5. The existing uses on the site create a significant number of lorry movements and associated noise and disturbance. The allocation and redevelopment of the site will bring the land into a use that is more suitable to its village location.
2.0 Modifications 1 & 2, 4 & 5
2.1. Centaur Homes support the Council in meeting its Duty to Cooperate and the increase in housing need to accommodate the unmet need from outside of the District. However, this unmet need should not be separated out from the actual need for Warwick DC.
2.2. As acknowledged, the 2015 SHMA has a critical role to perform in helping the Council prepare a Local Plan, which is sound. However, it is noted that the SHMA covers a 20-year period, but the plan period is only 18 years. To allow for this, the Council has applied a pro-rata figure the to the plan period. Centaur's concern with this is that although the total need over the 20 year period is known, the breakdown of demand for housing during the period is not, it is not a constant perfect linear line, but dynamic.
2.3. Therefore, the Plan's target of 16,776 new dwellings is not justified and potentially could under deliver in the short term. Failure to provide the required level of housing will further compound supply problems as well as hinder economic growth and fail to address affordability concerns. This is further supported by the affordability of market housing data shown in table 46 in the SHMA, which identifies that Warwick District is less affordable, than the England average.
2.4. If the Council insist on using a figure different to that in the full OAN identified in the SHMA, This figure needs to be justified for the shorter period. It is also considered that in accordance with the need to "boost" housing supply that the housing target should be expressed as a minimum to provide for additional flexibility to make for any under-delivery on allocated site.
3.0 Modification 3
3.1. Centaur Homes supports the change to Policy DS4. This clarifies that allocations can occur to a wider range of settlements across the district.
4.0 Modifications 6 & 7
4.1. Following on from the Inspector having found the windfall figure as previously put forward unjustified, the Council have lowered the figure.
4.2. However according to the letter from the Council leader, Cllr Andrew Mobbs, to the Inspectorate dated 14th October 2015, work is still on going "regarding a justifiable level of windfalls" and the figure put forward is "just an estimate" and no further evidence has been provided within the proposed modifications to support this figure, even though it is lower than the previous allowance.
4.3. As a result, Centaur consider the Plan's approach towards windfalls to still be unsound as it is clearly contrary to national guidance and the fact that the Plan is supported by a robust SHLAA. Given the detail in the SHLAA, further housing allocations can be made to further reduce any risk of the housing target being met.
In addition, subject to other representations looking for the Plan's target to be
expressed as a minimum, it would provide the necessary flexibility for windfalls to come forward.
4.4. It is considered that the concerns about the windfall figure can be redressed (in part) through the allocation of additional land at Maple Lodge at Hampton Magna for housing development.
5.0 Modifications 8 & 9
5.1. Centaur Homes supports the revised distribution and the increase of dwellings to the Growth Villages. Such an approach is consistent with paragraph 55 of the Framework.
6.0 Modifications 10, 11, 16 and 19
6.1. Centaur Homes objects to these modifications on the basis that they are unsound as they are inconsistent with national policy and not justified by the evidence base.
6.2. Centaur Homes do not dispute the need for additional housing in Hampton Magna as reflected by earlier representations supporting the development of land on the western side of the village. However, these modifications underline the flawed approach the plan has made to development in the village in respect of:
* The Green Belt.
* Landscape Impact.
* Sustainability Appraisal.
6.3. Each is addressed in turn below.
The Green Belt
6.4. The green belt is the key issue relating to the modifications is that both sites are proposed to be removed from the green belt. In so doing, the additional release proposed and intensification of the allocated site, have to be justified by the evidence base.
6.5. In this respect, the modifications are flawed as there is no cross-reference to the appropriate evidence base to support the allocations. As per earlier representations, Centaur Homes is unconvinced about the Modifications put forward as Core Document CD V13 and makes a more robust case for the release of land on the western side of the village, rather than on the eastern side, where the two allocations are proposed.
6.6. Whilst it is unreferenced in the EiP Core Documents list, the 2015 Warwickshire Green Belt review does provide an analysis of the green belt around Hampton Magna in terms of parcels WA2 (where allocations H27 and H51 are sited) Old Budbrooke Road (HM2).
6.7. A general criticism of the approach by the 2015 document is that it is too broad brush, that the assessment parcels are too large, encompassing areas with different sensitivities to the green belt. This is especially the case with HM2, where the southern part of the parcel is not close to Warwick, unlike the northern part. In contrast, CD V13 does look to provide a more fine grain analysis of development areas.
6.8. In terms of allocation H27, the Modifications impose an arbitrary additional 30 dwellings on the site, with no evidence suggesting how this could be accommodated or what the associated impacts are.
6.9. In the case of H51, the concerns are more fundamental, in that the extent of the allocation does not account for the whole of the field in which the allocation sits. This is considered to be a serious misjudgement in terms of how a site should be allocated for housing development, when releasing it from the green belt and the need to make use of clearly defendable boundaries.
6.10. Making specific reference to the guidance in paragraph 80 of the Framework, the following analysis of the intensified H27 and newly allocated H51 is as follows:
Check unrestricted sprawl
6.11. Both allocations are identified in an area in CD V13 that are characterised as being very open. Therefore, their development will have an immediate impact on the green belt. In the case of H51, given the arbitrary extent of the allocation, not using the whole of the field in which it sits, its development would lack context and effectively sprawl.
Prevent neighbouring towns merging
6.12. Notwithstanding the presence of the Warwick bypass, this is a critical area of the green belt, where the gap between Warwick and Hampton Magna is as little as 1km (2015 GBR). Clearly the intensification of development on H27 and the development of H51 will clearly increase the perception of Hampton Magna and Warwick merging.
Safeguarding the Countryside from Encroachment
6.13. The key concern here is the openness of the allocated sites. Their development, topography and lack of a layered approach to multiple field boundaries means that development will clearly encroach into the green belt and be heavily reliant on the creation of new boundaries. Whilst the presence of sports pitches in assessment area WA2 are noted, their presence does not confer that housing development would be equally acceptable as sports pitches are appropriate development in the green belt, whereas housing is not.
Prevent the setting of historic towns
6.14. Core Document V13 makes reference to the inter-visibility of the area in which these sites sit an the Warwick conservation area. Especially as these sites have an elevated location overlooking Warwick.
Assist in urban regeneration
6.15. Clearly, given the scale of Warwick's housing challenge, there is a need to allocate additional greenfield sites.
Strong & defensible boundaries
6.16. Following on from the critical assessment of the Green Belt Assessment, and it having been undertaken at an appropriate scale, it is clear that the Council has not identified the allocations in accordance with the final bullet point of NPPF paragraph 85. This requires boundaries to use physical boundaries that are clearly recognisable and likely to be permanent.
6.17. With allocation H51, the allocation boundary does not follow any existing boundaries at all. It sits within an asymmetric shape field and the allocation cuts off the bottom and eastern sections of the field. This will leave areas of land that are not connected to the neighbouring field and may lead to further hedgerow loss as they are incorporated into the neighbouring fields having a very significant landscape impact and making the developments even more visible from the long distance views of the site from the south and east.
6.18. For both allocations the likelihood of the permanence of the boundaries should be questioned. Apart from H51 having no boundaries at all, allocation H27 is only contained by field boundaries on its two longest sides, these are generally considered to be weak and are easily broken through, especially as they are not particularly dense, deep or contain a significant number of mature trees. The location of a public right of way along the southern boundary does not add any weight to the boundary as this could be incorporated within a development.
6.19. As such, the allocation, as it is put forward within the modifications version of the Local Plan is not NPPF compliant.
Landscape Capacity Study/ Assessment Concerns
6.20. The second area of concern with the Modifications is the compatibility of the Modifications with the landscape evidence which underpins the Plan.
6.21. The main Landscape Sensitivity and Ecological & Geological Study dated November 2013 considered the sensitivity of all sites around Hampton Magna. This located Land South of Arras Boulevard (site H27) within land parcels HM_05 and HM_06 and Land South of Lloyd Close within land parcel HM_07.
6.22. Regarding land parcel HM05, the study focus on land to the east of the village, down to the A46, however, it does state that new development should not extend beyond the current settlement edge to the east, or to the south of public right of way WB12.
This public right of way links into public right of way W84, this is not mentioned in the commentary on land parcel HM_05. This study acknowledges that there is: "some potential for a very small amount of development in this zone providing that views towards Warwick from the existing settlement are preserved."
6.23. Based on this evidence document, how can the intensification of allocation H27 comply with this Landscape Sensitivity Assessment? Any development of allocation H27 will restrict existing (public) views from the settlement towards Warwick, as these are currently open and far reaching. Therefore it is not possible for these to be preserved as new development will break up the view and sight lines, especially the current open view from Arras Boulevard and the intensification of development on the site will further compound this loss.
6.24. The commentary on land parcel HM_06 provides further evidence against the intensification and development of the whole, again it notes that there is some scope for "limited development adjacent to the existing settlement edge" and the graphic provided within the Landscape Sensitivity Assessment acknowledges that this should be limited to the northern half of the eastern field. Any intensification of this allocation will significantly alter the key views within land parcel HM_06, the evidence document notes that existing mature trees break up the "hard edge" of the settlement to some extent and a significant landscape buffer will be required to mitigate any development of this site and to maintain the existing relationship between urban and rural that will greatly impact on the density of development across the main site and therefore, further compound the problem.
6.25. The Landscape Sensitivity Assessment for Allocation H51 again acknowledges the scope for some small scale development and the graphic within the assessment suggests that this should be within the extremities of the existing development and bot push the settlement boundary further into the rural landscape. Public views from the existing settlement boundary are far reaching and it is possible to see Warwick from this point. The site is on the high point in a rolling landscape and therefore, it would be highly visible from a significant number of viewpoints including the surrounding public rights of way and Warwick to the east.
6.26. Centaur are concerned that the Landscape Assessment's conclusions that H51 could accommodate "small scale development" does not reflect the level of development which is proposed in the allocation (115 units). The allocation covers an area of land measuring some 5.5 ha, in a open field parcel measuring 10ha in size. With this latter point, the size of the 10ha field parcel could be more than able to accommodate the whole of the housing allocation for Hampton Manga without the need for allocation H27. This fact underlines, the difficulty associated with the allocations made by the Plan in the village and why both allocations are considered unsound.
6.27. In contrast, the Centaur site sits within a natural depression and is visually contained, unlike the land to the south of the village (allocations H51 and H27), although the site sites within a green landscape, it does not benefit from the rolling landscape views that make it highly visible. Therefore, it should be considered a suitable location for development on two grounds. The first being partly brownfield and therefore the allocation of this site would see it redeveloped and save a greenfield site from being lost. The second is the contained nature of the site makes it more suitable in landscape terms then the allocations being put forward within these modifications.
Sustainability Appraisal
6.28. An addendum SA has been provided with the modifications to the Local Plan. There is very little content within this addendum regarding the allocated sites beyond the content within the original Submission Local Plan SA Report February 2015. Within the 2015 SA, allocation H51 was rejected based on it having "some connectivity to the main settlement but potentially significant impact on nearby residents and little regenerative impact"
6.29. There is no justification provided within the modifications documents to justify how these sustainability concerns have been overcome.
6.30. Within the justification for the intensification of H27, the SA addendum states that the site has a medium to high landscape value, but that the intensification will save the loss of greenfield land elsewhere and that mitigation can overcome any significant effects. There is no justification for how any significant effects might be overcome, especially against biodiversity, or what the mitigation might be.
6.31. Referring to the 2015 SA, the reason for the Old Budbrooke Road site being rejected was: "located within a parcel of high landscape value - disconnected from the main village and its core services / facilities."
6.32. As highlighted above, the landscape assessment for the site is flawed as it has not considered the site itself, but combined it with a land parcel and the analysis of this has focused on the land to the north of the village. Therefore, the evidence base does not find the site itself as of high landscape value, in fact the evidence base is silent when regarding this site.
6.33. As for the site being disconnected from the main village, this analysis has not taken into account the wording within Appendix Vi of the SA. This clearly states: "With regard to travel and transport, the potential allocations have excellent access to public transport with a bus stop within 0 - 400 m and there are pavements which provide safe access for pedestrians into the village centre or to public transport"
6.34. It continues to note the distances for some of the sites from Warwick Parkway, namely the sites within 1km. it should be noted that the shortest walking distance from the represented site to Warwick Parkway is 1.2km, whilst for allocation H51 this distance is 1.4km. Likewise to the local shops and primary school both sites are equidistant.
Material Considerations : The Brownfield Register
6.35. It should also be highlighted that the modifications to the Local Plan does not appear to have considered the requirements of the emerging Planning and Housing Bill currently progressing through Government. This will require all authorities to maintain a register of brownfield sites that it considers suitable for housing development. As such, it is possible that the brownfield element of the represent site may come forward through this process anyway. However, if the Council were to allocate the whole of the Old Budbrooke Road site it could create a more suitable form of development that could to be comprehensively planned as one whilst delivering a level of housing suitable to the settlement.
Summary
6.36. Therefore, the Plan's evidence base clearly continues to contradict the allocations made in the plan.
6.37. In conjunction with previous representations, whilst Centaur seek the de-allocation of H51 in preference to its site, it also objects to the intensification of development on H27 and seeks this modification to be deleted.

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