No

ID sylw: 108099

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Two of South Warwickshire’s most sustainable locations for growth fall within this potential buffer - Shipston-on-Stour and land at Long Marston, identified as a Strategic Growth Location (SG17) and Potential New Settlement (E1) respectively.

This appears to have been influenced by comments from the Cotswold National Landscape Board to the Issues & Options Consultation. However, there is no basis for a National Landscape buffer in national policy. No evidence been provided to suggest that this is needed. The Cotswolds National Landscape Management Plan 2023 – 2025 doesn't refer to a buffer or suggest that one should be established. The Management Plan serves as a material consideration in the determination of planning applications within the National Landscape and its setting. The current policy approach to the National Landscape in the Stratford Core Strategy should be carried over in the absence of evidence or justification tor a buffer. Development shouldn't be precluded in sustainable locations where schemes can be designed in a manner which doesn't adversely impact the National Landscape or its setting.

NPPF Paragraph 189 already requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in National Landscapes. It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” The requirement for development within the 'setting' of National Landscapes to be sensitively located and designed means that a policy on this matter and a buffer are unnecessary.

No

ID sylw: 108100

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Special Landscape Areas only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Evidence needs to be prepared on which parts of South Warwickshire merit a Special Landscape Area designation.

Such a designation would not be based on national guidance and policy. It is also not included in Natural England's approach. Paragraph 187 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes’. It is considered that the special landscape character across South Warwickshire can be suitably conserved and enhanced through a generic landscape policy, without need to create an additional landscape designation, which would require another study to be undertaken to form part of the evidence base.

If the Councils do wish to proceed with Special Landscape Areas regardless of the above, it is imperative that these do not restrict development in what may be sustainable locations for growth. The policy direction currently recognises this; thus, this aspect is supported.

Other

ID sylw: 108101

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This policy direction is broadly supported, with it generally aligning with the aspirations in the NPPF with regards to the protection and enhancement of landscapes, set out in, for example, Paragraph 187. However, it should be noted that Paragraph 135(c) does state that whilst development should be sympathetic to the surrounding landscape, this should not prevent or discourage appropriate innovation or change, such as increased densities. This should be acknowledged within the policy. It is affirmed that it is unnecessary for all major developments to provide Landscape and Visual Impact Assessments (LVIA) as currently suggested. This will need to be fully justified, and such justification has not been provided within the Preferred Options document. The need for an LVIA should be considered on a case-by-case basis, and/or specific criteria for when one is required should be prepared by the Councils.

Other

ID sylw: 108102

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Seven Homes has an interest in Land at Russells Garden Centre, Mill Lane, Baginton.

The River Sowe flows north-to-south along the western and southern boundaries. Environment Agency datasets show no historic flooding within or surrounding the Site. The Site is partially within Flood Zones 2 as well as 3a and 3b. Residential development is ‘More Vulnerable’ under the NPPF. This is considered compatible with Flood Zone 1 and 2 and compatible with Flood Zone 3a provided the Exception Test is passed. The Flood Map for Planning was likely informed by hydraulic modelling of the River Sowe dating back to 2010. We have updated the hydraulic model as given its age it does not reflect current best practises, data and climate change allowances. The updated modelling demonstrates more realistic predicted flood extents. We can demonstrate that the access and built development will be outside flood zones 3a and 3b. Any development within the classification of a Design Flood Extent will be designed to be safe for its lifetime. Floodplain compensation measures will be provided in line with current guidance.

Foul water discharge rates and dry weather flows in the Severn Trent response were predicated on a development of c.170 units. The alternative connection point offered by Severn Trent is deemed to be prohibitive. Further information regarding the nearest connection point requiring indirect discharge into the adopted network via an existing upstream pump station was pursued. A Severn Trent Developer Enquiry determined that further infrastructure improvement works are required to accommodate development of the Site within the local foul water network. Seven Trent have confirmed a hydraulic modelling exercise would be undertaken to determine future capacity and necessary upgrade requirements. This would consider a broader catchment, accounting for the Site but also future nearby developments. It would assess current network performance, impacts of proposed flows, and potential effects on the wider network. Severn Trent’s Growth Team will monitor the planning status of Sites and associated applications so that development of the Site is included within their assessment management periods. This work will be undertaken in parallel with the Local Plan process through an iterative two-way process.

To provide short-term certainty of deliverability, the feasibility of connecting to the local network downstream of the pump station via gravity is being explored as an interim solution. Early engagement with Severn Trent will be crucial in collaboratively reviewing this approach and to understand whether Seven Trent Water will accept an initial connection as part of the proposed development. Once additional technical input has been undertaken to inform the capacity of the Site, Seven Homes will be in position to make a further Developer Enquiry application to Seven Trent Water to confirm this position.

To support the promotion of the Site for housing, pre-development appraisal enquiries with the relevant Statutory Authorities and District Network Operators has been undertaken. This is summarised below.

• Identification of potential utility constraints and diversionary requirements (Water, Sewer, Gas, Electricity & Telecoms) as well as obtaining C3 budgetary obligations for diversionary works.

• Investigating suitable Points of Connection and budgetary obligations, where available, from host utility companies for Water, Gas, Electricity and Telecoms. Including all contestable and non-contestable costs to assist with an onsite Multi-Utility approach/strategy.

• Identifying new utility supplies, where we would typically explore open market opportunities to potentially lower infrastructure costs (Multi Utility companies for gas, electric, fibre and explore the emerging NAV market and/or self-lay companies for water).

• Identifying relevant asset values for proposed utilities adoption

There are no significant physical, environmental, or technical constraints which would preclude housing development of this grey belt site. Suitable design and adequate mitigation would ensure an acceptable and policy-complaint development.

The Site is extremely well-located due to sitting on the strategic road network immediately adjoining the southern edge of Coventry, with direct links to the City Centre via public transport. A bus stop is located adjacent to the Site at Mill Lane.

In terms of landscape, the Site benefits from enclosure at the site level due to structural landscaping and built form within and adjoining the site boundaries, as well as within the wider local landscape due to the valley landform and surrounding higher ground to the south and west; proximate settlement to the west and north; and tree cover to the west, south and east. Due to the Site’s degree of enclosure the Site has limited visual influence within its immediate and broader landscape context.

The Landscape and Visual Overview prepared by Pegasus Group (Appendix 2) sets out design parameters as summarised below:

• Appropriately designed green infrastructure within the site to respond to the ‘Arden Parklands’ landscape type through delivery of additional woodland planting and reinforcement of existing tree cover, and parkland style planting where appropriate.

• Retention of primary hedge lines on the Site perimeters.

• Retention of tree cover particularly in the east to preserve the wooded character to the settled fringes. Careful management of existing vegetation with additional woodland planting on this rising ground

• Opportunities to enhance or recreate riverside wetland habitat and retain/enhance the vegetated riparian corridor of the River Sowe within the site through species-appropriate woodland belt planting and linear habitat creation along western and southern boundaries;

• Introduction of parkland planting in the south to reflect the characteristics of the landscape area, create variety between the key green spaces and offer visual interest. Carefully planned planting distribution could accommodate public open space, ‘blend’ a detention basin into the landscape and make effective use of sloping ground which would likely restrict some potential uses of a multi-function recreation space

• Open space to the Site frontage could reflect a more ‘domestic’ scale of landscape treatment and planting to appear cohesive with the existing residential address to Mill Hill. A new tree belt along the River Sowe could be tapered off towards the northern limit of housing to meet this green space and transition the scale of landscape proposals from linear structural planting along the river corridor to a finer grain of smaller select trees and hedge planting.

• Distribution of built form can be delivered to maximise opportunities for enclosure by settlement, topography, and existing peripheral and retained structural vegetation, further enhanced with new landscape planting. Given the site form there is opportunity to maintain an irregular settlement outline.

Allocation of the Site for housing would align with the Strategic Growth Strategy of the SWLP. The Site is within the highly sustainable Spatial Growth Priority Area 2, with good access to employment opportunities within existing immediately to the east, Jaguar Land Rover to the north, Coventry City Centre and the wider urban conurbation immediately to the east of the Site. Any landscape and visual constraints can be overcome with a landscape-led design approach. The site presents an opportunity to deliver a sympathetic and responsive green infrastructure framework, through an appropriate strategy of existing and proposed structural landscaping. This would enhance the existing landscape and biodiversity value of the Site.

The Site was assessed in HELAA Part A and B as Ref: 131. Under Part A, the Site scored ‘Green’ for most assessment criteria. The site scored ‘Green’ for most locational/technical areas. The Site scored ‘Green’ in terms of achievability and availability. It scored 'Amber' for flooding, but as discussed above further technical work is being undertaken by Seven Homes to support the development of the Site. The Site scored Amber in relation to listed buildings, likely to be due to the Site’s proximity to the Grade II Baginton Bridge adjacent to the north-western corner of the Site. The proposed development of the Site will incorporate an area of open space at the northwestern corner of the Site. The Site scored ‘Amber’ in relation to minerals safeguarding, Given the Site’s previously developed status the score should be ‘Green’.

In the HELAA B assessment, the Site was given a score of 40.10, and it remains in consideration for SWLP Part 1 allocation. The score should be revised in respect of Green Belt as the parcel has a weak contribution to Green Belt purposes. The score should be 34.7 (with 0.00 for Green Belt criteria).

Seven Homes support a Green Belt review. The need for housing, lack of capacity in urban areas, and the tightly-drawn Green Belt boundaries around some of the most sustainable settlements are exceptional circumstances supporting the release of land from the Green Belt for development. The site is within the BAG2 parcel identified in the Stage 1 Review. The Review considers the parcel's contribution to the Green Belt purposes as follows:

• Purpose (a) – NO contribution
• Purpose (b) – WEAK contribution
• Purpose (c) – MODERATE Contribution
• Purpose (d) – NO Contribution
• Purpose (e) – MODERATE Contribution

Release of land at Russells Garden Centre, Mill Lane, Baginton, would not harm the purposes of the Green Belt for the following reasons:

• Purpose (a) – the Kenilworth Bypass sits immediately to the east, creating a physical barrier between the Site and the urban edge of Coventry. The Site in part is previously developed with the floodplain to the south restricting the extent of development.

• Purpose (b) – Development would not result in the merging of Coventry with any other settlement.

• Purpose (c) – the Site is partly previously developed. The remainder is horticultural including numerous structures. The Site is well-enclosed with limited views from the immediate and broader landscape context. The flood plain to the south helps prevent encroachment given its unsuitability for development.

• Purpose (d) – the Site is not adjacent to a defined historic town. The Site is outside the Baginton Conservation Area, however as Baginton is a village this does not relate to purpose (d).

The December 2024 NPPF introduced the concept of the ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. Priority should be given to the release of land at Russells Garden Centre as previously developed grey belt land.

The Stage 1 Green Belt Review was undertaken prior to the December 2024 NPPF. In identifying land the Councils must now consider categorisation of sites as Grey Belt. The Site should be considered Grey Belt as it meets the tests of NPPF Paragraph 155. Development of the Site could also meet the relevant Golden Rules set out at NPPF para 156 including provision of up to 50% affordable housing, improvements to infrastructure as required, and provision of publicly accessible green spaces within the development.