Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire
I am writing to express my strong objection to the proposed housing development in our village. As a resident of this community, I am deeply concerned about the potential negative impact this development will have on our quality of life and the character of our village. Firstly, the proposed development is incompatible with the existing character and scale of our village. The new housing units will negatively impact the aesthetics and charm of our village. Additionally, the increase in population density will put a strain on our already limited infrastructure, including roads, schools, and public services. Secondly, the development will have a significant impact on the natural environment in our area. The proposed site includes valuable green spaces and wildlife habitats, which will be destroyed to make way for the development. This will have a negative impact on the biodiversity of our village and the quality of our environment. Finally, I am concerned about the impact that the development will have on our local housing market. Our village already has a shortage of affordable housing, and the proposed development will only exacerbate this problem. This will make it difficult for many families in our community to find suitable housing, which will have a negative impact on our social fabric. In light of these concerns, I urge you to reconsider the proposed development in our village. I believe that a more sustainable and sensitive approach to development is necessary to preserve the unique character and quality of life in our community. Thank you for taking the time to consider my objections.
Introduction 1. These representations are made in response to the South Warwickshire Local Plan (SWLP) Part 1 Issues and Options consultation document and associated Call-forSites (January 2023) on behalf of Makestone Strategic Land (MSL). The representations relate to MSL’s land interests east of Snitterfield Street, a ‘reserve site’ identified in Stratford District Council’s Site Allocations Plan (SAP) (Revised Preferred Options, June 2022). Summary 2. MSL’s response to the SWLP is summarised as follows and included on the SWLP online consultation portal. The SWLP needs to plan for at least 47,012 dwellings 2022-2050(consistent with the HEDNA) with an uplift to address demographic and market signals plus unmet needs from the adjoining urban areas of Birmingham and Coventry as required by NPPF61. Whichever spatial option is taken forward to realise the above growth requirement, the SWLP needs to allocate sites at Local Service Villages (LSV) including Hampton Lucy to positively address the needs of rural communities, a key requirement of national planning policy and guidance (NPPF79 and NPPG0091in particular). MSL’s site at east of Snitterfield Street should therefore be allocated in the SWLP and released now. The site has already been identified as a suitable site for allocation, reflecting the site’s draft status as a ‘reserve site’ in Stratford District Council’s emerging SAP (draft Policy HAMP.A). Reserve sites are critical to the delivery and implementation of Policy CS.16 of the Stratford-upon-Avon Core Strategy (SACS) 2011-2031 to meet future needs – i.e. the needs now required in the SWLP to 2050. The allocation will help to meet rural needs in and around Hampton Lucy, and should be allocated for up to 30 homes, including 35% affordable provision, realising wider benefits for Hampton Lucy, including new green space for the local community (further details enclosed as part of these representations). Q-S7.2: Refined Spatial Growth Options 3. The SWLP Issues and Options consultation presents five growth options to address South Warwickshire’s requirements, with one of these to be taken forward as a subsequent Preferred Option. However, it is considered that a mixture of options is likely to be required to meet the needs of South Warwickshire’s communities. 4. Nevertheless, whichever option is taken forward the needs of rural communities needs to be met via dedicated allocations to LSVs in the SWLP. This will enable positive planning in response to the requirements of NPPF79 and NPPG009: “79. To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” (2021 NPPF, emphasis added) 5. In addition, provision of a mix of sites which includes smaller-medium site allocations in rural communities reflects the objectives of NPPF60, 68 and 69. 6. In doing so Stratford District Council has already identified suitable and sustainable sites for allocation as reserve sites as part of its emerging SAP. One of these sites is MSL’s site at Hampton Lucy: Policy HAMP.A. The Sustainability Appraisal (SA) (Addendum, May 2022) underpinning the SAP supports the allocation as follows, all informed by a Heritage Impact Assessment (HIA). 7. Reflecting the draft allocation in the SAP, MSL has undertaken masterplanning and technical work, enclosed with these representations, demonstrating that the site has capacity for up to 30 homes. Appendix A includes a masterplan for the site, underpinned by a landscape and visual strategy which reflects the site’s context to nearby heritage assets and the Council’s own HIA (Appendix B) as well as an appraisal to demonstrate how safe access can be provided in to the site for pedestrians, cyclists and vehicles (Appendix C). 8. In summary, the scheme comprises the following key features and benefits. Up to 30 homes, including 35% affordable provision, with a mix to reflect local needs. Extensive strategic landscaping and green space, reflecting the setting of heritage assets, the Council’s HIA and the site’s landscape and visual context, minimising views from the north and east in particular. Provision of a focal green space to the south of the site - as a potential hub for community activity and events, including LAP, wildlife habitats (to support biodiversity net gain) and a pond - which could potentially be transferred to the local community for management. Promoting walking and cycling to help reduce the need to travel by car, being well-located at the heart of the village, with a main walking/cycle link via the existing bridleway on to Bridge Street providing a direct link to Hampton Lucy C of E Primary School, St Peter’s Church and Boars Head public house. The site also benefits from further existing pedestrian links on to Snitterfield Street. Creation of an attractive new gateway into the village, reducing traffic speeds and extending the 30mph speed limit further north on Snitterfield Street. This scale of development would be able to support the viability of local services as NPPF79 requires – including Hampton Lucy C of E Primary School – as well as securing other funding and investment in local services and facilities where required. 9. The site is included on the interactive map of SHLAA sites from 2021 (site ref. 497) and has already been supported through the SA process informing the SAP, supported by HIA. The information enclosed within these representations provides further evidence on the site’s suitability and deliverability to help inform any further assessments via the SAP and SWLP process. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 13. Yes, MSL agree that a threshold approach would be appropriate for any settlement not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 14. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the availability of suitable land, proximity to nearby towns, or scale of local employment opportunities. Therefore, the threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
Section 4.2 Development Distribution Strategy for South Warwickshire 25. The HBF would wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The HBF does not comment on individual sites, other than to say the Plan should provide for a wide range of deliverable and developable sites across the area in order to provide competition and choice and a buffer to ensure that housing needs are met in full. The soundness of strategic and non-strategic site allocations, whether brownfield or greenfield, will be tested in due course at the Local Plan Examination. 26. Whilst the principle behind the 20-minute neighbourhood is a reasonable aspiration to take forward within the Plan this should be seen as an aspiration within appropriate locations rather than a blunt tool for development management or site allocations across South Warwickshire. As noted in the consultation under Issue S4 the application of this principal in more rural areas is inevitably more difficult as populations are generally too low to meet all the features of a 20-minute neighbourhood, but this should not prevent development from happening in such locations to support the need for new homes in those areas in Part 2 Local Plans and/or Neighbourhood Plans. 27. The Spatial Strategy should recognise that there may be clusters of villages that provide a range of services for that area within reasonable travelling distance of each other, so villages may need to be grouped together. These areas might be able to sustainably support a substantial level of development but may not meet the principles of the 20-minute neighbourhood. The plan will also need to recognise that settlements that currently do not have the services that are consistent with the 20-minute neighbourhood could expand to include those services if new development is allocated in those areas. The 20-minute neighbourhood should not be used as a basis for only locating development close to existing services rather identifying where services could be improved through new development. There is a real danger that the principle could be used negatively and become a way of preventing development in certain communities rather than promoting improved neighbourhoods. 28. With regards the potential for new settlements, the HBF notes that new settlements have long lead times. Reliance on one (or more) new settlement(s) for housing delivery will mean delivery from this source will occur later on in the Plan period. This increases the importance of the need for a range of other sites to be provided to ensure a 5 Year Land supply and early delivery of much needed housing. It will be important for policies and allocation in the Plan to provide for a range of housing sites. 29. The HBF agrees that if homes are being provided to meet needs arising in Birmingham and Black Country HMA and the Coventry HMA, then the Plan needs to consider where best such housing should be located. This must include considering the benefits of locating these homes as close as possible to the source of those needs, for example, in order to minimise travel. This consideration therefore necessitates the need for a review of the Green Belt (see also comments on Chapter 5).
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Representations by Braemar 1. These representations to the South Warwickshire Local Plan Part 1: Stage 2 Issues and Options Consultation have been prepared by Braemar, who have interests in land west of Gaydon Road at Bishops Itchington. 2. The focus of these representations concern the potential for other identified settlements, outside the Main Towns, to accommodate growth. General Comments 3. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at p.2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S1 15. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 16. Braemar is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too great a density of development. 17. Braemar is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 18. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 19. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20- minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S8.1 34. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In is context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy, including Bishop’s Itchington. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 35. Settlement boundaries will need to be reviewed to accommodate development.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
Q-S2: Stansgate clients consider a policy with ‘in principle’ support for intensification across the South Warwickshire area is appropriate, together with a general intensification design code, but that identifying specific areas with a design code for each is not necessary. Stansgate clients recognise that the National Planning Policy Framework places significant emphasis on making the best use of previously developed land, through redevelopment and intensification, to limit the need for greenfield sites. In principle support for intensification of suitable sites within the South Warwickshire area is therefore necessary to meet national policy requirements, and beneficial to improve the appearance of underused and disused yet often highly sustainable areas within the District. However designating individual areas may actually prevent other areas from being brought forward, as the focus is on land already considered suitable, stifling fresh ideas, and as such a policy which identifies specific areas is not considered appropriate. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of land available for intensification and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. All previously developed sites are unique so a single detailed design code to control the redevelopment and intensification of all sites is not appropriate. Instead a more generic list of guiding principles should be adopted with individual sites assessed on their own merits. Q-S3.2: Stansgate clients support Option S3.2b, prioritise development on all brownfield land irrespective of location. Whilst the need to direct most development to sustainable locations is accepted, failure to allow the redevelopment / reuse of brownfield sites in all locations, including Green Belt locations, will have a detrimental impact on the economy, the landscape and meeting local needs. There are many occasions when rural sites, particularly commercial sites and buildings, are underutilised or uneconomic to continue in their present use. Without a policy to support their redevelopment they may be left vacant, and as a result often fall into disrepair with visual harm. Reuse and/or redevelopment of buildings and sites can enhance the local economy, support and expand the local community, ensure improved appearance and meet local development needs. The generation of limited amounts of traffic associated with such development in less accessible locations, when balanced against the economic and visual benefits (and compared to traffic associated with previous uses), is an acceptable compromise. Notwithstanding the general support, previous independent examinations in both Warwick and Stratford Districts have indicated there is a limited supply of brownfield land available and the authorities must recognise that there will be a woefully inadequate supply to meet the likely development requirements for the District. The release of greenfield sites, to include those within the Green Belt, must therefore be considered to meet the full development requirements of the District. Q-S4.1: Stansgate clients firmly believe that yes, the overall strategy should include growth at some, and indeed many, of the existing settlements within the District. Stansgate clients commented on the Preferred Growth Options for South Warwickshire at the Scoping stage, concluding that a combination of the Dispersal, Main Urban Areas and Socio-Economic options, with a full review of the Green Belt, was the most sustainable solution to meeting the development needs of the area. This would mean new development at a wide range of existing settlements. New settlements were not seen as a solution. The additional work now undertaken by the Councils does not alter this opinion and confirms that there should be focus on growth at a range of existing settlements across the District. The golden thread running through planning is that of sustainability which is defined in planning terms in paragraph 8 of the Framework. It means balancing economic, social and environmental objectives, now with an increased focus on the environment and climate change, to meet the needs of all. With a growing population and an increase in households this means building new housing, and providing new land for employment, in the right places, to reduce the need to travel. The South Warwickshire area is substantial in size and contains within it a range of characteristics, which result in different needs and problems, and all must be addressed and balanced. A distinction can be drawn between the north and the south of the area. The north contains the main urban areas stretching from Stratford upon Avon and the East of Redditch in the west to Leamington Spa/Whitnash and South of Coventry in the east with Warwick and Kenilworth between. These areas are generally more accessible as they lie in corridors served by rail, bus and primary roads. They contain a large range of services and generally provide good access to higher order settlements. Journeys by private car are likely to be less frequent and shorter as people have local services and facilities close at hand and can walk, cycle and use public transport. With good levels of sustainability they have tended to be the focus for development in recent years. The south and east of the area is geographically larger and is characterised by rural settlements dispersed through a wide area. Despite the size of the settlements, in Stratford District some 45% of residents reside in the more rural south (Inspector’s Interim Report March 2015) and 33% in the Main Rural Centres spread across the District, with comparably few in the main town of Stratford upon Avon. The distinction is less great in Warwick District, but there remain a number of rural settlements across the District. In the rural south, settlements tend to be smaller with fewer services and facilities and less opportunity to travel by public transport and greater reliance on the private car. In recent years many of the smaller settlements have seen much less development and as a result the more limited services and facilities have suffered and reduced in number, for many increasing reliance on private car whilst for others resulting in isolation. There is an increasing affordability gap and there simply isn’t enough housing to meet the needs of the population. With such a varied area there cannot be a ‘one size fits all’ solution. Expansion of Larger Settlements The larger settlements, such as Stratford upon Avon, Warwick and Leamington Spa, with their substantial employment parks, range of shops and community facilities, good access to higher tier settlements and high quality, local, public transport options are able to sustain larger developments. Locating growth at the main urban areas (including those in the Green Belt) provides the opportunity for sustainable urban extensions with mixed use development and the provision of new infrastructure such as schools and local centres that build on the existing transport networks. The previous Sustainability Appraisal indicated this option to be highly sustainable and suitable to deliver housing and employment land in the right places. However this alone would deliver development in a limited number of locations all focused in the northern area and is unlikely to meet the needs of the more rural areas, particularly those settlements in the south and east. To meet those needs a more dispersed approach is required, as outlined by paragraph 79 of the Framework, which seeks to promote sustainable development in rural areas by locating housing where it can enhance or maintain the vitality of rural communities. Expansion of Smaller Settlements Given the high proportion of the population which lives in the small towns, villages and rural areas it is essential that a significant proportion of new growth is distributed to meet their needs, to reduce the affordability gap, to support existing services and facilities and to ensure the continued success of the settlements. Growth of existing settlements of all sizes, including those in the Green Belt, is the only way to achieve this. A hierarchy of settlements is already established in both the Stratford on Avon District Core Strategy and the Warwick District Local Plan, based on a sustainability assessment which has regard to the services and facilities available within individual settlements. These hierarchies need to be reviewed to enable more of these settlements to grow to meet their own needs and District-wide needs, and with more opportunities for growth in Green Belt settlements, as an appropriate basis for future dispersal of development. Additional Comments In line with an updated settlement hierarchy all settlements should be able to accommodate growth to meet local needs and address affordability issues. In the large part this can take place without need for significant infrastructure, and can be brought forward quickly in the early part of the Plan period to maintain supply whilst larger, more complex urban extensions which will require new infrastructure are planned and brought forward. Such a dispersed approach will also allow opportunities for the identification of a raft of small and medium sites and thereby accord with the Framework requirement in paragraph 69a, that local planning authorities should, through the development plan, identify land to accommodate at least 10% of their housing requirements on sites no larger than 1 hectare. Stansgate clients would also support an approach allowing areas with small villages and no towns to create a network of villages which can collectively provide what most people need for their daily lives, joined by active travel arrangements. Q-S5.2: Stansgate clients do not consider that new settlements should be part of the overall strategy. Instead they consider that a dispersed approach, which prioritises extensions to existing settlements of all sizes, will provide a more sustainable means to meet the development requirements of South Warwickshire during the Plan period. The South Warwickshire Area suffers from a considerable affordable housing gap. The Scoping consultation acknowledged this and suggested the prioritisation of employment opportunities to increase the housing requirements and therefore the amount of affordable housing provision. New settlements generally have extremely high infrastructure costs which results in the provision of lower levels of affordable housing. This will be detrimental to meeting the housing gap. The same is not true of extensions to existing settlements where most infrastructure, including road and rail, already exists. The need for significant infrastructure, particularly road and, if the general thrust of directing development to settlements with a railway station progresses, rail, often means a reliance on external funding. That funding provision is in jeopardy until actually paid, and with changes in government and policy directions there is no certainty proposed funding allocations will be available to support development. This means considerable uncertainty in the provision of new settlements. Other local authority areas have relied on new settlements with external infrastructure funding which is later withdrawn leaving their housing and employment provision in tatters. Stratford District is already reliant on housing coming forward from two new settlements, with some 3,600 dwellings anticipated in the early part of the next Plan period at Gaydon / Lighthorne Heath and Long Marston Airfield. Warwick District is also reliant on substantial housing numbers from the strategic development at Kings Hill, where some 2,200 dwellings will come forward beyond the current Plan period. If the Council proposes new settlements to meet a further substantial portion of the housing requirement to 2050 there will be significant reliance on this form of development which will make the Plan inflexible and top heavy, unable to keep pace with ever changing housing need or demand. Extensions to existing settlements are more flexible and better able to meet development requirements. New settlements inevitably mean taking residents from existing settlements, breaking up existing communities, which can cause harm to those communities and often result in increased travel by private car to bring families and friends back together. It also means existing communities cannot gain from the benefits associated with new development – the provision of affordable housing and housing to meet other identified needs, support for existing services and facilities, and improved infrastructure. The long term sustainability of existing settlements is therefore put in jeopardy. Q-S8.1: Stansgate clients recommend that a dispersed approach be adopted for the distribution of development across the two Districts, with housing directed to settlements of all sizes in a manner which is proportionate to the size and nature of the individual settlement. If this approach is adopted then no settlement would fall outside the chosen spatial strategy. If an option is chosen where some settlements fall outside the growth strategy then it is essential that policies still support small-scale developments in the remaining settlements, including those in the Green Belt. A threshold approach may be appropriate but it would need to be flexible to respond to the needs of individual settlements and the land available for development. Particular issues which may arise with a simple threshold approach: • It may be too simple to adapt and address the specific and changing needs and requirements of settlements of different sizes • It may result in the housing threshold being met within the first five years of the Plan period leaving no opportunity for further organic growth for the remainder of the Plan period, potentially another 20 years, even if further housing needs are later identified • It may artificially reduce the size of the most appropriate development sites, or result in under-development. For example the best site to meet development needs may accommodate 15 houses, but with a threshold set at 10 houses it may either be artificially reduced or under-developed. • If a threshold is too low it may result in reduced provision of affordable housing, particularly for sites with high infrastructure costs • It may result in buildings and sites being left vacant if thresholds are met before suitable sites become available. An example would be a small commercial yard in the centre of a settlement which is active at the beginning of the Plan period. Planning permission is granted for the development of a site adjacent to the settlement which uses the full threshold allowance. The commercial yard then becomes vacant and no other commercial use can be found. Policies must then be sufficiently flexible to allow further residential development to prevent the commercial site lying vacant. Q-S8.2: None of the options is appropriate. If thresholds are to be utilised, for each settlement these should be proportionate to the settlement itself and the characteristics of the site. Q-S9: Stansgate clients would choose Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The provision of settlement boundaries gives certainty to home owners and developers. Settlement boundaries have been provided for many settlements in Warwick District which avoids confusion and saves time. The intent when adopting the Stratford on Avon Core Strategy was that it would be quickly followed by a Site Allocations Plan which would provide settlement boundaries for at least the Local Service Villages within the District. The SAP has now been in production for more than five years and there is no end in sight. This leads to continuous debate regarding which policies apply and where. The emerging South Warwickshire Local Plan provides an opportunity to create certainty and part of this must be a full review of all settlements within the area and the setting of appropriate boundaries for each. The current consultation notes that the disadvantage of setting settlement boundaries now is that it would be ahead of the Part 2 Plan which will include non-strategic allocations, and making revisions is therefore difficult. Stansgate clients do not agree. It is appropriate to set boundaries for the settlements as they are now (including sites which already have planning permission for development). It is acknowledged that non strategic development sites will be allocated in due course, but it is inevitable that they will lie beyond existing confines of villages and they do not need to be within settlement boundaries to be allocated.
QS4.1 Growth of existing settlements - Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non- greenbelt site. Q-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
Q54.1 Growth of existing settlements - Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land. Q-S5.2 - New Settlements: I feel that it is wholly unacceptable to consider the development of a new settlement within greenbelt land. There are not exceptional circumstances to doing so. It is unacceptable that despite the NPPF principles, multiple new settlement locations are illustratively suggested in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-greenbelt options for new settlements. A new settlement in non-greenbelt land should be prioritised over any other development options in greenbelt land. New infrastructure can be developed to support such a non-greenbelt site. Q-S5.3 - Rail Corridors. I feel that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I feel development alongside rail corridors to the South of the region, explicitly avoiding greenbelt development should be supported. The plan outlines that an indicative 6000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the greenbelt. Additionally, this would reduce the likelihood of overcrowding existing areas/stations in locations with existing stations in the Greenbelt. Development in North Leamington is not appropriate to use Leamington Spa station as there is already heavy traffic congestion in people moving from the North to the South of the town. A new station in the greenbelt is unacceptable. The Climate Emergency must not be used as justification to develop on greenbelt land, this is a weak argument as there are other ways of mitigating against the climate emergency without developing on greenbelt. Q-S8.1 - Settlements falling outside the chosen growth strategy: I do not feel a threshold approach to small scale development is appropriate in greenbelt areas. We do not feel the plan should allow for more small scale growth developments to come forward in greenbelt areas. Q-S10 - Any other comments: I am specifically opposed to development of land in the greenbelt areas around Hunningham and other similar small greenbelt villages due to the impact on the rural character of the area of the North Leamington Greenbelt. The Climate Emergency must not be used as justification to develop on greenbelt land. This is a weak and bizarre argument. There are other ways of mitigating against the climate emergency without developing on greenbelt land, which itself is truly harmful. There is no option to comment on issue S6 within the plan (A review of the greenbelt boundaries). I do not feel it is necessary or appropriate to redefine greenbelt boundaries. This issue should not have been included within the consultation without the option to comment. The number of respondents (561 responses) to the first consultation was exceptionally small indeed and can in no way be considered representative of the population area. It is possible given these very small numbers they were from developers or others who would directly benefit from such development (there were almost as many sites submitted as responses received!). This tiny number of respondents is so small it should not be used as a basis for decision making and should not be used to justify development or review of the greenbelt.
. I live at Travellers Rest, Wootton Wawen and this is my response to the South Warwickshire Local Plan. These are some considerations that have come to mind when reviewing the above plan. I have listed them in bullet point for ease. The village has roughly 660 homes at present (including the static homes of Allens Caravan park) the proposed development of 500 homes seems incredulous when the area concerned has been classed as Medium Landscape sensitivity. Wootton Wawen sits within a greenbelt The surrounding countryside is not only productive farmland, helping feed our population (which carries ever more increasing importance in todays world) but also has abundant flora and fauna. By excessively building in such an setting you take food from peoples mouths, add pounds to peoples bills and further damage our dwindling wildlife number and diversity; causing environmental harm. Large parts of the village are already classed as a flood risk as the village itself sits in a sunken position. At present it is not unusual for the river to flood the road and some properties in winter. The current water drainage and infrastructure is barely fit for purpose as it is. Any further developments will only contribute to greater surface run off, greatly increasingly the risk of extensive flooding putting current residences at unreasonable and avoidable risk. A significant and costly improvement of current water services/drainage would be required. Linked to the above the aging and limited local sewage processing plant would not be able to meet the new expected demands, requiring further investment. The population of Wootton Wawen according to census data has increased by 197 people from 2001 to 2021, yet you are proposing in adding 500 new homes in a much shorter timeframe. Even an increase in 500 new people would increase the village population by over a third. This would not only destroy the geographical form of an historic English village it would tear apart the very fabric and character of the community therein. The A3400 which runs through Wootton Wawen is a very busy thoroughfare, linking the surrounding areas to Stratford and the M40. It is already at saturation and a daily risk to the residents. Although speed limits are well highlighted they are poorly abided. An increase in any traffic would endanger lives and make it only a matter of time until someone is seriously hurt or killed. Significant road improvements and speed calming measures would need to be invested to mitigate this. Paths would need improving to accommodate safely the increased footfall from the proposed developments. Having experienced multiple recent localised power outages I am concerned as how any increased demand of the system would be dealt with. The village does not have a gas service, meaning all of these new houses would be on oil (a huge environmental and global impact) or more likely fully electricity dependant (including an associated increasing percentage of electric vehicles). This would suggest that this would require significant and costly investment. Similar to the above mobile coverage for the area is limited to just several providers. Could current services meet an increased populations demands for mobile and high speed internet provision? An area that again would need significant investment to meet demand. One of the aims is to bring younger families to the village. I ask what is there for them here? There are no local amenities for young families. No safe places to play, no safe paths or roads to play or ride bikes on. The local school has a maximum capacity of around 120 pupils and very limited ground on which to expand, certainly not enough to accommodate such planned housing increases. Where are these new families going to send their children? There are currently limited local public transport services. Although we have a village shop, post office and pub, they are hugely hindered by parking and access. Further population demand would only cause further strain on limited parking and lead to road congestion and delays. There are no evident areas where parking could be improved upon. The nearest GP medical practices are in Henley-in Arden or Claverdon. Henleys current GP currently has 6500 patients and is stretched to breaking. Who is going to provide health care for the new residents or will the burden have to be shouldered by the already creaking local services? Similar to the above can local policing services cope with such an increase in local population? Rural areas often have a limited police presence. I’m sure the shop would testify regarding this having been broken into again in 2022. By increasing the local population, will this negatively impact current and future resident safety? All in all it does not seem of fiscal cost benefit to push through with the proposed housing due to the considerable and multiple further service and infrastructure developments that would be required. When combined with the potential personal and environmental risks associated with this plan, it would suggest that it would need sweeping changes to make this viable.
2.0 THE SITE Site Location and Context 2.1 The location of the site is shown at Figure 1 below. The site is located adjacent to the current settlement boundary of the village of Long Marston, which had a recorded population of 436 at the 2011 census. The site extends to circa 5.28 hectares located to the north east of Long Marston and is accessed from Welford Road, which runs north/south through the village, via Perry Orchard where access rights exist. 2.2 East of the site, on the boundary of the wider land holding, is the Long Marston Greenway, a former railway that has been converted to a footpath and cyclepath. The site is surrounded to the north and east by agricultural land. The village of Long Marston is located immediately to the west and the south of the site. 2.3 The site is not located within, or near to, any Green Belt, National Park, or Area of Outstanding Natural Beauty. The site is situated in Flood Zone 1, an area with the lowest probability of flooding. The site is not within, nor affecting, any Special Protection Area (SPA), Special Area of Conservation (SAC), or Site of Special Scientific Interest (SSSI). 2.4 Lagan Homes gained planning permission for the 20 dwellings now constructed on what is Perry Orchard. The approved application did include a new community centre and sports field, although this has yet to come forward. The relevant land for the community centre was gifted to the Parish Council by Lagan Homes. The Proposal 2.5 The Concept Plan available at Appendix 1 shows the potential layout for development at the site. This has been informed by the Opportunities and Constrains Plan shown within Appendix 2. 2.6 To respect the village character and density, a community-led scheme of 30-35 dwellings would be considered a sensitive and appropriate level of development considering the size of the site and the village. The layout would reflect surrounding development patterns and leave a substantial site area to the east for the purposes of open space, biodiversity net gain, and creation of a strategic gap / landscape buffer (in perpetuity). The accompanying concept plan demonstrates how residential development can be delivered in this sensitive manner. 2.7 The primary benefit of the allocation and delivery of this site would be the ‘unlocking’ of the stalled community building provision for the village. Furthermore, the creation of a substantial area of re-wilding to the east of the proposed dwellings would ratify the boundary between the village of Long Marston and the significant development likely to come forward at the airfield to the east. The site is available and could be delivered early in the plan period to help facilitate the delivery of the community centre.
Q-S4.1 – Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.1 Yes. The spatial strategy will no doubt seek to provide growth in a variety of settlement types. This should also filter down to smaller settlements such as Long Marston, to support services and facilities. Small scale development in the villages can also ensure that deliver rates are realistic, given the lack of reliance on larger scale infrastructure works. Q-S8.1 – For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 3.9 No. Placing a threshold on a particular site may not make efficient use of a site. For such settlements, capacity should be considered on a site-by-site basis. If for example a threshold of say 20 units is placed on settlements, but a site has a clear capacity for more, then these additional numbers would have to go elsewhere, potentially forcing development into less sustainable locations. A threshold approach will not assist in making best use of land and good sites such as at Long Marston. Further contributions to the community centre would be lost in a threshold scenario. 3.10 If the Council consider a threshold approach to be necessary, then it is suggested that it could include some flexibility. An example would be a higher threshold where it is agreed in dialogue with the local Parish Council or relevant Neighbourhood Plan Group. Q-S8.2 – For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.11 As noted in the response to S8.1 above, a threshold approach would impact on best use of land. For the site at Long Marston, it has a capacity of circa 30-35 dwellings. Any policy must ensure flexibility that such capacities can be achieved on appropriate sites such as Long Marston.
I am not surprised that our green belt is under threat once more. It is several years since surveyors were seen working at the edge of the milverton wood/farm land, despite denials about the true purpose of their task. Yet again, the council is willing to rape our open countryside and build on it without consideration of the unique attraction of our green, open land between Kenilworth and Leamington and milverton. Where will the real infrastructure of schools, health services, transport be directed? Grazing land, waterways and our trees are all at risk if this planning goes ahead. More pollution, traffic congestion and money are the main drivers for this type of planning discussion. The type of development at whitnash is a prime example of inconsiderate planning; (causing traffic problems and disruption to a village environment there can be no real consideration of the wellbeing of residents nearby.). Such development is harmful to both residents and wildlife in the quite expensive site. Affordable local housing within the town of leamington could be developed with less disruption and cost to us if empty and neglected properties were re-purposed for local people. Referral to the planning papers is unhelpful to the average person unused to finding their way through jargon. But housing people in affordable, convenient properties should be your aim throughout this process. Progress need not be destructive as the loss of our green belt surely will be.
USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies.
1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits.Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20 mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Poor Bus Links: The bus and train infrastructure is barely sufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….”. Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. 4. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable.
Q-S1: Green & Blue Corridor development could be appropriate due to the need for housing closer to Birmingham for people commuting to work in this region. If developments appropriately address the importance of habitat biodiversity features and sustainability, wherever possible.
1. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits.Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 2. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20 mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Poor Bus Links: The bus and train infrastructure is barely sufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….”. Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. 4. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 5. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 6. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable.
QS4.1 Growth of Existing Settlements: there is sense in extending existing settlements but NOT where the extending development uses green belt land and NOT where the extending development radically alters the character of the existing settlement. Q-S5.2 - New Settlements: it is wholly unacceptable to consider the development of a new settlement within green belt land. There are no exceptional circumstances for doing so. It is unacceptable that the NPPF principles are NOT being adhered to, as multiple new settlement locations, in green belt land, are apparently being considered in the current consultation document. If a new settlement is to be considered, this should only be in non-greenbelt land. There are ample non-green belt options for new settlements. A new settlement in non-green belt land should be prioritised over any other development options in green belt land. New infrastructure can be developed to support such a non-green belt site. Q-S5.3 – Rail Corridors: I consider that the prioritisation of rail corridors may offer a sensible option for development. There is substantial scope to include development alongside rail corridors outside of the greenbelt. I would be supportive of development alongside rail corridors to the south of the region, avoiding the use of green belt land, should be supported. The plan outlines that an indicative 6,000 new homes would be sufficient to support a new rail station, and there are ample geographical options to achieve this outside of the green belt. Additionally, this would reduce the likelihood of overcrowding existing stations. Further development north of Leamington is likely to see an increase in the demand for Leamington train station. This will inevitably increase traffic along the one connecting route (from Weston through Cubbington) to the station and in the already congested roads in the centre of Leamington itself. The Climate Emergency is of course of grave concern but it is NOT in itself a justification to develop on green belt land. Higher density housing, brownfield development or the equivalent, energy efficient or passiv haus standard housing, non-car use neighbourhoods are the way to remove the need for communities to use fossil fuels. Green belt development and relying on “mitigating measures” is, rationally, not the way.
[Redacted Text] [I have lived in] Henley in Arden my whole life [and I am] concerned about the development proposed so please find attached my main concerns associated with the development in Henley in Arden: 1. ABSENCE OF A FOCUS ON LOCALISM: The outline proposals make no reference to even the sense of the principles of localism in the Henley-in-Arden community and run contrary to local sentiment. Those responsible for the development of the plan must provide opportunities for communities to influence decision-making. support placemaking and. deliver services that reflect local requirements. The scale of the development proposed is completely inconsistent with the scale of the existing town and the development of the population to date. Between 1975 and 2015, the population of Henley grew by 14.3%, and grew even more strongly in later years where between 2000 and 2015, it grew by 10.2%. Using data and projections from 1. JRC (European Commission's Joint Research Centre) work on the GHS built-up grid and 2. CIESIN (Center for International Earth Science Information Network), the population in 2022, stood at 2,571. Assuming an average of 3.5 heads occupying a lower estimate of 500 additional houses in Henley-in-Arden as proposed in the Plan, the population of the town would grow by 68%, which is completely disproportionate development. The plan ignores Stratford Council’s own observations about the importance of Henley’s heritage and the impact of further development upon it. The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan of September 2022 observes that “The setting of some of (the) assets, particularly the castle and church, are still currently experienced within the historic open agricultural landscape. It is therefore recommended that development of the land beyond the north-eastern edge of the settlement should be avoided.” There are also similar observations about the land to the south-east and south-west of the town which are completely contrary to the scale of the development proposed in the plan. Similarly, there is little consideration of the sites north of the Warwick Road (reference HEN.02 in the Stratford Heritage Assessment) where the RED assessment risk of both harm to surviving Ridge and Furrow and harm to archaeological monuments runs contrary to the proposed sites offered for development to the East of the town. The economy of Stratford upon Avon is delicately dependent on visitors and those in search of rural tourism – the strength of demand is such that the town has its own Heritage Centre for visitors and queues for the locally-made ice cream regularly generate queues that extend up the High Street. Extensive development of the type which is proposed would likely jeopardise local businesses and a tourism-centred town: Solihull was originally a pleasant town in the Green Belt – literally ‘Urbs in Rure’ – but development without reference to local concerns has let it evolve into something much different. 2. INFRASTRUCTURE HAS ALREADY BEEN STRETCHED BY UNCONTROLLED DEVELOPMENT TO DATE Existing brownfield infill within the town has occurred over previous years without any improvement in the infrastructure within the local area. Stratford District Council agree and go further, commenting on its impact on the environment: “Henley-in-Arden has had modern development to the west and southeast which has partially enclosed and eroded its value and sense of place on those sides of the settlement.” (Settlement Sensitivity Assessment, 2022). The legacy infrastructure has already been stretched by infill development – further development would be unsustainable. 3. SIGNIFCANT INFRASTURCTURE LIMITATIONS AND CONSTRAINTS Poor Bus Links: The bus and train infrastructure is barely sufficient to sustain the existing population, before considering an additional 2,000 residents which might result from the proposed development. The X20 bus service runs 12 buses a day on a weekday and covers the North – South route between Stratford and Solihull. Bus passengers requiring to travel East – West to Redditch and Warwick are required to travel to the end of the north or south routes and then change to another service. Stratford District Council agree – the 2018 SDC Transport Strategy reports that “A key barrier to bus use is journey length and issues of punctuality and service reliability which are exacerbated in Stratford-upon-Avon by congestion”, which is central to the operation of any bus routing to service Henley-in-Arden. Further, SDC reports that “bus passenger facilities … are currently insufficient for the volume of passengers….”. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables. Traffic Limitations: Existing Plans to Match funding has been secured to calm traffic on the High Street in an initiative to impose during the first six months of 2023 a 20 mph speed limit on the High Street and commuter ‘rat run’ cul de sac roads that lead off the main artery. It is counterintuitive to simultaneously restrict the flow of traffic through the town – a demonstrated need in response to recent traffic safety issue – and at the same time expand the volume of traffic resulting from increased housing development around the town. Inability to Expand or Widen Existing Roads to Accommodate Traffic: Henley-in–Arden is a medieval market town with a strong architectural heritage reflected in the North – South road axis and the listed buildings which line the A3400 and High Street. The listed buildings which exist along the main roads in the town preclude any expansion or widening of the road to accommodate increased volumes of traffic arising from increased development and volume of housing. Impact of Closure of the M40 and other Congestion: With the current level of housing, any closure of the M40 south of the M42 junction leads to the diversion of traffic off the motorway and through the town, predominantly using the north-south axis along the High Street. Statistics show that the M40 is the subject of a temporary closure between 3 and 4 times a year. Roadworks anywhere in the town – typically driven by servicing the antiquated drainage system and other infrastructure – currently creates significant delays in the town. Additional development will have an adverse impact on the existing street scape within Henley. Road Safety: An increase in development in or around Henley-in-Arden will lead to an increase in traffic of all modes to service population movement around a market town based around two intersecting roads. A brief review of the traffic accident statistics for Henley in Arden for the last five years shows 25 incidents in the Henley-in-Arden area, one of which is classed as fatal and five of which are classed as serious, all of which centre on the High Street and the crossroads at the South of the town. An increase in population of the scale proposed by the draft Plan would inevitably lead to an increase in road traffic casualties. Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town. Car Parking: Car parking is an acknowledged problem in Henley-in-Arden, where the existing historic housing prevents the development of extensive car parking and on-street parking on the High Street predominates and cars have been forced into small off-street parking facilities – such as that behind the Co-op store. The proposed plan makes no accommodation for the resultant car traffic that would be generated by extensive development around the town. Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. 4. USING THE GREEN BELT INCORRECTLY TO RESOLVE STRUCTURAL PLANNING PROBLEMS: The proposed development in Henley-in-Arden uses development in the Green Belt incorrectly to resolve structural planning problems in the district. Henley lies between two much larger urban developments in a section of Green Belt land which serves to prevent urban sprawl extending such that the developed envelopes extend to such an extent that they join. To the south, there is extensive white space on the outskirts of Stratford upon Avon, for example, which is ideally suited to development that meets the needs of a modern economy that is responsive to the environmental demands and the new working patterns that have emerged as imperatives in recent years. Development of brownfield sites around existing urban envelopes is consistent with modern planning policy that co-locates living, working and leisure spaces, and preserves the integrity of the nearby Green Belt and all of its benefits. Stratford District Council itself highlights the evidence that supports this argument: “Unemployment across the District is low, with 0.3% of workers claiming jobseekers allowance in May 2016. This is lower than the UK average (1.8%) and West Midlands average (2.2%). There is an imbalance between the number of jobs in the District and its working population. An increasing number of residents commute to higher paid employment outside the District, while lower paid jobs are often filled by people coming into the District from adjoining areas. These commuting patterns impose significant pressures on the road network. Employers in and around Stratford-upon-Avon can struggle to recruit staff into lower paid and part time roles and cite the absence of affordable commuting options, particularly outside of peak travel times, as a barrier to filling vacancies.” 5. LOCAL SERVICES ARE INADEQUATE TO SUPPORT PLANNED EXPANSION: An increase in the housing stock in Henley-in-Arden such as that proposed in the draft Plan would require additional infrastructure investment, most obviously in schools and medical facilities. Henley in Arden School is part of the Arden Multi-Academy Trust. It has a capacity of 700 pupils and yet already has 710 pupils enrolled. Expansion would inevitably be necessary to sustain development of the extent proposed and local government would need to provide funds. The existing medical practice moved from the High Street to the existing site in 1990, and access is via a footpath from the High Street or via car through a housing estate to a council run car park. Again, the site of the existing facility and the lack of potential for expansion into surrounding space means that expansion in Henley-in-Arden would require a new medical facility in a new location. Any expansion of either of these facilities or the commission of new sites would inevitably lead to an increase in the risk of road, pedestrian and traffic incidents as a direct result of the crossroads and road configuration which dominates the town. 6. ERODES THE COMMITMENT TO THE PRESERVATION OF THE GREEN BELT The West Midlands Green Belt wraps around Birmingham, the Black Country and Coventry and extends to a ring of towns beyond the conurbation. Within Stratford-on-Avon District it stretches from the northern edge of Stratford-upon-Avon, along the A46 westwards and the A439 eastwards up to the District boundary with Redditch (apart from small areas of land to the west of Mappleborough Green), Bromsgrove, Solihull and Warwick. The settlements of Alcester, Henley and Studley are excluded from the Green Belt. Commitments from Stratford and Warwick in the existing planning frameworks reiterate a commitment to the integrity of the Green Belt and the prevailing government guidance and policy in respect of the Green Belt. It is critical that the Green Belt around Henley is preserved for its environmental benefits and the health and social benefits that it brings to residents. The proposed development is inconsistent with commitments made in the existing planning policies.
Q-S1: Please select the option which is most appropriate for South Warwickshire Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced There should be sufficient existing technical evidence already available to identify the corridors. There would also be scope for these to be modified, as necessary as the local plan progresses. If this approach is taken it is important that maps and images are at a scale and have sufficient clarity so that the status of specific land parcels can be distinguished. Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy It seems unlikely that the scope for any reduced synergy would be very significant and, as mentioned above, there is scope to reduce that as the local plan progresses towards adoption. Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b would appear to be the most realistic, and achievable option. It is of some concern that the consultation document identifies some of the potential climate change benefits that can arise from intensification while at the same time failing to recognize potential dis-benefits such as adding to congestion in already congested areas and undermining the character and appearance, as well as the attractive of urban areas though over-intensification. In addition, since all development should be carbon-free by 2050 the differential impacts on climate change between different locations should be significantly reduced. The plan appears to be predicated on a principle that development in urban areas is preferable in climate change terms that development elsewhere. This appears to be a principle based on assertion rather than definitive evidence. It could lead to the degradation of attractive urban environments which would be counter-productive. Q-S3.2: Please select the option which is most appropriate for South Warwickshire These options and the analysis behind them appear somewhat confused and focused towards urban concentration. As highlighted earlier in this response, the evidence to conclusively prove those options are the most sustainable and have the least impact on climate change and CO2 reduction is based more on assertion rather than on conclusive evidence. We also feel that the term 'prioritise’ may not be the most suitable, not least because of its uncertain meaning. Perhaps ‘make best use of’ would be a better terminology. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? A 10 dwelling limit generally seems appropriate although any such limit should also be caveated to enable developments of more than 10 dwellings in exceptional circumstances or where criteria have been met in terms of sustainability and perhaps provision of additional infrastructure, otherwise potential developments of 11-49 dwellings which might be acceptable on all other grounds would have been excluded from the local plan process. Q-S9: Please select the option which is most appropriate for South Warwickshire The development strategy should enable a proportion of development to come forward outside strategic sites with a capacity of 50 or more dwellings. The scale of small scale dispersed growth should be disaggregated across the plan area to provide the basis for Neighbourhood Development Plans and the review of settlement boundaries where this is necessary. However, it is important that identification of suitable sites is not unduly delayed and the potential identification and release of an appropriate scale of development where sites have been taken through the Call for Sites should not be unduly delayed. Ideally, where it is known that settlement boundaries require amendment then these settlements should, at the very least, be identified in the plan. If, having identified these settlements then it should be accepted that land might be released adjacent to the extant development boundary. This would provide a strong incentive for Neighbourhood Development Plans and or Site Allocation Plans to be put into place. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire The level and distribution of growth should be clearly set out in the plan to provide a sound basis for Neighbourhood Development Plans.
I am absolutely devastated, to see the plan to build thousands of houses on our green belt north of Leamington and I like others in north Leamington vehemently oppose it! Merging Leamington with Kenilworth, so we have one sprawling town, loses these towns their identity. Also,destroying valuable farm land, when this is so much needed, for future food security, destroying footpaths, trees, hedges, bio diversity, why is this a good idea? Why are the councils, overriding the overwhelming opinions of residents, who are dismayed already at the loss of our town's identity and loss of nature, so important for our health. The loss of our green spaces is evident everywhere, due to developers greed. HS2 have destroyed, acres of farm land and woodland. The council gives planning permission to developers, to cut down mature bushes, trees and shrubs. Where is there for our wild life to go and our birds to nest? Your answer is to plant hundreds of 50cm saplings that are not maintained, watered and then die! This proposed development is not in line with government policy and has to be stopped, for the sake of the well being of our communities. Build on brown field sites, not on our beautiful countryside, this is the easy, lazy ,cheaper option. There is nobody I know who agrees with this proposal. I hope the councils do the right thing for the future of our children.
I am writing to voice my concerns at the proposition of 500 new homes in Wootton Wawen, under the South Warwickshire Local Plan. I currently live with my family at Travellers Rest, Stratford road, Wootton Wawen.We moved to the village in 2019 and have expanded our family since being there. I work as a Neonatal Intensive care doctor in Birmingham. Although I would gladly welcome a smaller number of new houses within the village, the current village amenities and underlying infrastructure would not cope with a relatively rapid expansion to the village population. Having had a young family in the village, pedestrian access with buggies and younger children is very difficult. Pavements are narrow and cars have to drive close to the pavements when passing oncoming traffic. This is especially true near the waterfall bridge by Wootton Hall, which has to be walked single file and cannot accommodate an average buggy without the wheels intermittently coming off the pavement edge. I believe that the school can accommodate up to 120 children. It is a very small building with difficult pedestrian access, also requiring young families to walk partially on a busy road to get to the school entrance. After spending time in the school building, it would clearly be unable to facilitate a large influx of local children and would either have to be drastically extended or move to an alternative, larger location. There are currently no communal play facilities within the village for children, not ideal for a large increase in local families. Our village does not have gas supply and relies on oil. This already has a huge environmental impact and adding more houses with surely make this worse. Within the last year we have had a number of electricity outages, including 3 power cuts which lasted over 4 hours. Without a huge change to the electricity supply to the village, how will the current supply cope with at least a doubling in usage under the new plans? Mobile phone coverage is also patchy at best and would need an marked increase in coverage capability to accommodate 500 more houses. The road that runs through Wootton Wawen is currently marked as 30mph, but is very rarely adhered to. There have been many ongoing petitions to the council and local police, to add additional speed slowing tools within the village, to no avail. A local villager has used a personalised speedometer and clocked motorists and bikers at speed over 100mph. We as a village are already gravely concerned about potential accidents that can happen due to the general disregard to the speed limit by motorists, but it seems unfathomable that adding up to 500 homes, with likely 1-2 cars per home, into an already extremely busy road, will not result in potentially awful accidents. As a doctor, I am acutely aware that the general practice in Henley in Arden, which serves the people of Wootton Wawen, is already approaching safety limits for patient/doctor ratios. The chemist in Henley is small and often does not have a regular delivery of routine prescriptions. 500 new homes of potentially young families who generally require a fairly high number of clinic visits per year, on the background of a large aging population in Henley itself and Allen’s caravans in Wootton, would be unable to be safely looked after by the GP and Pharmacy in their current states. The village is currently at a moderate flood risk and sits at a sunken position. Further development will only impact on this negatively and all new homes will face higher insurance costs due to flood risk proximity, something I’m sure will not attract younger families to the village. Lastly, the village sits on a greenbelt and is surrounded by local, working farms. Losing this beautiful land to further development, along with all of the local nature, would be a tragedy. I hope that I have been able to convey some of my concerns about the development proposal and that these will be taken into consideration. I would hugely welcome any further discussions about future housing plans. I want our village to continue to thrive, but feel that the current services and infrastructure of the village will in no way be able to meet the demand of a rapid expansion of new homes and this would have a drastically negative effect on all current residents.