Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2?
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Persimmon therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Chapter 8: A well designed and beautiful South Warwickshire. Issue D1: Strategic design Principles: The MOD has no comments or concerns with the topic headings that have been identified in this consultation for inclusion in a strategic design policy. It should be noted that it is possible that development undertaken in accordance with any strategic design policy that is defined may be relevant to MOD explosives safeguarding requirements should relevant development occur within the area contained within the MOD statutory explosives safeguarding consultation zones surrounding DM Kineton. Chapter 8: A well designed and beautiful South Warwickshire: Issue D2: Design Codes and design guides: The MOD has no preferences or requirements with respect to the approach taken in how design guidance is organised. The MOD would wish to be consulted on the preparation of design guidance for inhabited buildings that would be applicable to those settlements or types of development that are assigned to occur within the area contained within the MOD statutory explosives safeguarding zones surrounding DM Kineton. Chapter 8: A well designed and beautiful South Warwickshire: Issue D3: Designing adaptable, diverse and flexible places: The MOD has no preferences or requirements with respect to the approach taken in relation to defining density ranges. The MOD would wish to be consulted on the preparation of design guidance that would be applicable to inhabited buildings which would be relevant to development that is assigned to occur within the area contained within the MOD statutory explosives safeguarding zones surrounding DM Kineton.
QD1.1 Do you agree that this is an appropriate range of topics for a strategic design policy? Claverdon supports proposals to protect and enhance the historic and environmental quality of the village; however, some of the scope of this consultation should be undertaken at NP level. QD 2 Please select all options which are appropriate for South Warwickshire Claverdon supports option D2c i.e., develop design guides/codes for strategic development sites/locations. Like the existing policies within Warwick District, this would seek to produce specific briefs for individual large scale development sites. These could be produced or led by the respective Local Planning Authority and/or by the developer(s) bringing forward the site. QD.3 Please select all options which are appropriate for South Warwickshire Claverdon supports options D3b and D3c i.e. Include a policy which specifies a minimum density requirement across South Warwickshire, whilst emphasising that the minimum may be exceeded. This minimum could for example be set at a similar level to the existing policy in Warwick District - i.e. minimum 30d.p.h. This would be similar to the approach of the current Warwick District Local Plan. It would set a minimum expectation across the whole of South Warwickshire irrespective of context, but in anticipation that this minimum is likely to be exceeded where context allows, for example in more urban areas. This approach would not prevent specific design guides, codes or masterplans from guiding the NPPF and, the NPPF.
Heritage Considerations affecting land South of Rogers Lane (middle) The only constraint affecting our client’s land at Ettington is a heritage consideration. Four heritage assets have been identified as being potentially affected by development of the site: 1. Rye Piece Barn (Grade II Listed Building); 2. Manor House including attached barn and stables (Grade II Listed Building); 3. Iron Age Pits and Ditches (Non-designated heritage asset); and 4. Medieval ridge and furrow (Medieval ridge and furrow). Previous planning application and appeal processes have demonstrated that heritage assets 2, 3 and 4 would not be impacted by development of our client’s land. Regarding Rye Piece Barn, a past appeal decision found that development of the site would cause “less than substantial harm” to the asset. If a comparable setting for the barn can be established as part of a scheme for the development of the land at Roger’s Lane, the site could be brought forwards with suitable mitigation of the heritage impacts. A scheme which accommodates a lower quantum of built development and takes into consideration the setting of the nearby heritage asset could therefore be acceptable in heritage terms. Our clients are committed to bringing forward a scheme which can deliver this mitigation. We also note that planning permission was granted in 2017 (ref. 16/03972/FUL) for 6 houses immediately to the west of Rye Piece Barn. In terms of heritage impacts, the Planning Officer’s delegated report stated: “The applicant has in the current proposal aimed to address the identified harm by reducing the amount of properties proposed and increasing an undeveloped buffer zone immediately adjacent to Rye Piece Barn. These changes are assessed as having have made the proposed development less intrusive in relation to views across to the barn and retaining an open rural character to the area to the south-west of the application site. The proposed development is less intensive and leaves sufficient open space surrounding Rye Piece Barn to largely preserve the semi-rural context and the way that it is experienced. The substantial wild flower planting buffer zone is important in preserving the setting of the heritage asset and should be left open and unimpeded to ensure that there is no additional harm caused. The changes made to the proposed scheme would reduce the previously identified harm to a level below ‘less than substantial’. The test set out in the NPPF is therefore not triggered and the impact on the setting of the listed building is considered to be acceptable”. Immediately adjacent to Rye Piece Barn, the recently approved housing development shows that it is possible to accommodate development on neighbouring land, whilst respecting the setting of the listed barn. This principle would also apply to Land at Rogers Lane, whereby new development incorporating a suitable buffer to respect the setting of the listed building could be designed in such a way that any potential harm is below ‘less than substantial’ harm to the heritage asset, compliant with NPPF policy. Our clients would be pleased to offer examples of how these principles could be demonstrated in relation to development options on the Land at Rogers Lane.
Q-D2: A single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. Q-D3: The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitates schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area.
Need to retain Heritage assets but not allow these to become a barrier to change and innovation. The two do not have to be exclusive
2.25 Design Guidance (D1 and 2) 2.25.1 The I&O identifies three approaches to the use of design guides (D2a – a comprehensive guide for the whole area, D2b – guidance for specific places, D2c – guidance for strategic locations / sites). Of the options presented, option D2c is considered the most appropriate and proportionate. The character of the plan area is far too varied to warrant a single guide for the whole area and bespoke guidance for settlements would also be a huge undertaking given the number of settlements that might be included. 2.26 Density (D3) 2.26.1 Various approaches to density are set out. D3a is a general policy, which does not identify specific density requirements, D3b-d outline different approaches to identifying density at the settlement level. It is considered that the plan area is too diverse to be prescriptive about densities. The approach set out in D3a is considered proportionate. Any policy should highlight the need to optimise density, having regard to the existing character of an area, open space requirements and other development considerations.
On this basis, it is considered that there will be no impacts to the setting or significance of any designated or non-designated heritage assets from development in this part of the Southwest and south sub-area in Shipston-on-Stour. RPS broadly welcomes the conclusion that development has potential in the Southwest and south sub-area (subject to confirmation that Land at Hanson Avenue being promoted on behalf of Taylor Wimpey is located within this sub-area) and that any potential impact on any designated or non-designated heritage asset can be suitably mitigated as part of the planning application process.
Q-D2 51. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 52. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 53. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-D2: Please select all options which are appropriate for South Warwickshire In principle, the introduction of design codes and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Catesby Estates therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site specific design code/guide that goes beyond the detailed guidance in the National Design Code. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies.
Q-D2 53. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 54. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 55. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-D2 53. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 54. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 55. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-D2 50. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 51. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 52. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-D2 51. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 52. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 53. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-D5: MAOL agrees that the SWLP should include a high-level strategic policy that seeks to conserve and enhance heritage assets. We have explained that there is a close connection between the historic environment and economic activity and that the historic environment’s potential for investment should be supported in order to secure sustainable growth. Any policy should, therefore, recognise that: 1 Historic assets play a key role in promoting a strong tourism/cultural offer, which is an important part of the South Warwickshire economy. 2 Historic assets should be supported to grow and improve to maintain their attractiveness and integrity. 3 At the same time, any development must ensure the conservation and enhancement of heritage assets and their setting in a manner appropriate to their significance. We do not comment on the use of Heritage and Settlement Sensitivity Assessments to determine the impact development may have on the heritage assets within various settlements.
Q-D2: Hill Residential support the development of a design code for development sites such as Hatton New Community. Hatton New Community offers an exciting opportunity to adopt a different strategy to invigorate and empower the manner in which new homes are brought forward. With identity, character, beauty and the right level of infrastructure to support the community and meet the needs of the region. A design code will assist in capturing this design ethos and ensure that the place is delivered as expected.
Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? 7.1 The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage. Whilst the IO document has not requested any responses specifically on the HSSA, RPS has nonetheless reviewed the assessment with respect to Bidford-on-Avon, which is set out below. Identifying potential impacts of development – Bidford-on-Avon 7.3 Bidford-on-Avon has been sub-divided into five sub-areas (North-west, North-east, East, South and West). The HSSA provides a table (not numbered in the report) which summarises the scores, based on a ‘RAG’ rating system, broken down by these sub-areas. The full assessment is provided at section 10.21 of the HSAA, alongside a number of supporting plans. 7.4 In summary, the HSSA scores the North-west and South sub-areas as ‘Red’, and the other three sub-areas as ‘Green’. According to the HSSA commentary, for the North-west this is largely related to concerns regarding the potential impact of large scale development on the conservation area and listed buildings at Broom. However, the assessment was undertaken on a desktop basis as set out in section 4 of the report under ‘Data collation’. Furthermore, the urban extent that has been used to apply the buffer does not include the phase 1 Kings Meadow development, despite this being located within the Bidford-on-Avon Village Boundary as defined in the Bidford-on-Avon Parish Neighbourhood Plan, and the report stating that Neighbourhood Development Plans were included in the information sources that informed the assessment. 7.5 It is clear that a very simplistic approach has been taken, without consideration of land form beyond a very cursory reference to the general character of the landscape. Furthermore, what constitutes ‘large-scale’ development is not defined in the report. 7.6 RPS suggest that very little weight should be attached to the findings of this assessment in relation to identifying the development capacity of Bidford-on-Avon. It is also recommended that that when non-strategic scale development opportunities are considered at Bidford-on-Avon in due course as part of the part 2 SWLP, that a more detailed assessment is undertaken. RPS note that the emerging Site Allocations Plan has not identified any heritage concerns in relation to the development of Kings Meadow Phase 2.
QD5: Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
Q-D2: Please select all options which are appropriate for South Warwickshire L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Land South of Allimore Lane, Alcester development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Therefore, L&Q Estates are supportive of Option D2c: Develop design guides/codes for strategic development sites/locations, particularly as the planned public engagement will ensure the design of spaces and buildings will be appropriate and will respond to local context and identified needs in terms of size, type and tenure. The Vision Document demonstrates that much work has already been undertaken into achieving a welldesigned neighbourhood. Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? L&Q Estates agree that a high-level strategic policy that seeks to protect and enhance existing heritage assets should be included within the Part 1 plan, in accordance with Paragraph 190 of the Framework. Detailed heritage policies should be deferred to Part 2. The Site is not adjacent to any designated heritage assets. A Heritage Appraisal has been undertaken to inform the Concept Masterplan and Vision Document for Land South of Allimore Lane, Alcester. The deliverability of development on the site with reference to the historic environment constraints has been assessed. There are distant views towards the Grade II* Listed Church of St Nicholas, located within the Alcester Conservation Area, from the eastern area of the Site. Currently, it is anticipated that this area of the site would remain as open space. The Heritage Appraisal considers that residential development in the northern area of the Site would not adversely impact the Church of St Nicholas or any other designated heritage assets. An initial review of the archaeological resource has also been undertaken. Allimore Lane, which bounds the Site to the north, follows the route of The Saltway Roman road. Grunthill Roman cemetery is recorded to the east of the Site. The full extent of the cemetery is not known. The Heritage Appraisal considers there is potential for burials to have extended into the Site, particularly at the south east, and it is anticipated that this area will be proposed as Public Open Space. There is also potential for prehistoric and Roman period archaeological remains to be present elsewhere within the Site. However, it is anticipated these would be addressed by an appropriate programme of archaeological works.
Issue D2: Design Codes and design guides Q-D2. We consider that the high level principles of good design could be contained within a suitably worded policy within Part 1 of the Plan which could relate to the whole of the South Warwickshire geographical area – there may be limited merit in doing so however, as expectations are already set out within the National Design Guide and National Model Design Code – for part 1, generally then, it may be sufficient to refer to the Framework and the National Design Guide requiring applicants to demonstrate compliance with. To ensure that design guides/design codes respond to local characteristics, it is essential in our view that these are prepared on an area (if a group of settlements share common features) or individual settlement basis. The design codes/guides should ideally be formulated over time, with input from all key stakeholders including local residents and business owners as well as technical and environmental personnel from both the private and public sector to ensure that these guides will be robust in their assessment of the character and what would be acceptable in terms of visual and environmental (to capture effects of climate change and so on) and deliverable from a developer point of view. Due to the nature of the above; being a collaborative exercise, which will take time, it is considered that the finer detail required to produce such codes, should be required at a later stage of the local plan – either within Part 2, and specific to new allocations proposed, or following adoption, when new sites are confirmed, where a site specific design code/guide could be required. The use of site wide design codes for new allocations is supported, provided there is proper consultation with relevant council departments at both District and County to avoid problems post adoption. We have experience with a site in Warwick which has an adopted site wide design code (which was prepared following a series of workshops with key stakeholders and relevant officers from both the District and County, submitted and approved via a discharge of condition attached to the outline consent). It was very prescriptive in terms of layout, design, materials, car parking spaces, public open space, connectivity and so on, even down to the widths of roads and pavements which would be expected for the main spine road, primary, secondary and tertiary roads. Whilst this code enabled the applicants to prepare reserved matters applications to a set of agreed principles, which the District (planning officer) confirmed they were supportive of; we were significantly delayed by the repeated objections from the County Highways officer who maintained concerns over highway safety and general layout of tertiary roads. This was despite apparently having provided comments on the proposed design code before it was approved. This situation left the District in a difficult position - the Code has been approved and therefore has considerable status in planning terms – to satisfy highways, tertiary roads were re-designed – to appear more engineered and to have footways on both sides – which is contrary to the design code – the engineered appearance significantly detracts from the intended character of these streets. Despite many discussions to try to persuade Highways and to remind them that they were involved with the production of the Code – it was easier to amend the proposals than to continue to argue. In addition to this, tertiary roads have been approved (as per the Design Code) with block paving. We have now received objection to use of block paving and a particular kerb height (again specified within the code) from the Technical Team. We are categorically being told that these materials will NOT receive technical approval. Initial discussions with the District (to try and resolve) have not progressed as the technical team have suggested the use of black tarmac and high kerbs is the only solution – this would fundamentally change the nature of the tertiary roads and character areas in which they are located. This would be across the whole development consisting of 900 dwellings. The planning officer is not keen to support as cumulatively, this change would adversely impact on the appearance of the whole of the development – contrary to the adopted Site Wide Design Code. For any design code to be acceptable therefore, it is critical that the correct officers, statutory and non-statutory consultees and other key stakeholders are consulted on and their views properly taken into account before adoption to avoid similar problems again. Whilst laudable, if any document is adopted without concerns or objections being addressed, it can cause a significant delay to the granting of permission for schemes which will ultimately affect their deliverability. Issue D3: Designing adaptable, diverse and flexible places Q-D3a. We consider that option a – to include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire is the most appropriate option. This would allow a greater flexibility to be considered for individual sites as they come forward for development. There will be a need to take into account the character of the surroundings and density is just one element of this. Issue D5: Yes. The NPPF advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment.
The most appropriate option is considered to be D3a which includes a policy underlying the importance of density, but does not identify an appropriate minimum density or range of densities across South Warwickshire. It is important that densities are considered on a site by site basis, relative to their context. It may also be appropriate to consider different densities across a single site.
Q-D2: Please select all options which are appropriate for South Warwickshire Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. We agree that it would be difficult to produce a meaningful Design Guide that covered the entirety of South Warwickshire, however, we recognise that there is a national policy requirement to prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code. We therefore consider that design guides and/or design codes produced on smaller geographic scale would be more beneficial in terms of their ability to reflect local character and design preferences. Q-D3: Please select all options which are appropriate for South Warwickshire Option The most appropriate option is considered to be D3a which includes a policy underlying the importance of density, but does not identify an appropriate minimum density or range of densities across South Warwickshire. It is important that densities are considered on a site by site basis, relative to their context. It may also be appropriate to consider different densities across a single site
Q-D2: Option D2a: Develop a South Warwickshire Design Guide We would support this approach although, at present, there is a tendency for planners applying design guidance too rigidly to developments and there is a lack of consideration as to whether (regardless of any deviation from the guidance) the development looks appropriate and/or adds value to its surrounding and functional for its needs. Any Design Guide/Code should not be overtly prescriptive or rigidly applied but, provide guidance and/or performance criteria – there is a real danger that this could prevent innovative and creative designs that are different but still appropriate and create interest. Designs should be considered on their merits in meeting performance. Option D2c: Develop design guides/codes for strategic development sites/locations. We would support this approach. Q-D3: We consider a flexible approach that considers the site context, local character and the efficient use of land, and ultimately the creation of high quality development, would be more appropriate. Q-D4.1: Yes Although we remain unconvinced by the 20-minute neighbourhood concept. Q-D6: Please refer to earlier comments regarding unnecessary and too rigid application of design guidance.
Chapter 8 – Design The word ‘complimentary’ is used several times in this chapter and should be spelt ‘complementary’ The wording in the design section generally follows the guidance in the NPPF, so is justified. Issue D1- Strategic Design Principles: P138 says: “A strategic design principles policy is expected to cover the following: • Comprehensive development - ensuring development is designed and delivered in a coordinated way, and avoiding piecemeal schemes. This is not in the NPPF but we support this. • Attractiveness – creating a pleasant environment to live and work. Wording from NPPF so supported. • Sensitive to context – responds to its surroundings. We propose that NPPF wording is used, as follows: “sympathetic to local character and history ...whilst not preventing or discouraging appropriate innovation or change (such as increased densities)” • Distinctiveness – builds upon the unique characteristics of its surroundings and/or creates a unique sense of place in itself. Wording from NPPF so supported. • Connectedness (also tackles aspects of ‘healthy’) - weaves into existing networks of different scales. This wording is not in the NPPF and is not clear. We suggest the wording in the existing Stratford Core Strategy should be followed, as follows: “Connected: Proposals will be well integrated with existing built form, enhancing the network of streets, footpaths and green infrastructure across the site and the locality, and retaining existing rights of way. “ • Safety – ensures layout and orientation create spaces and overall environment that feels safe and secure to be in. Wording from NPPF so supported. • Environmental sustainability and adapting to climate change (links to policies in ‘A climate resilient and Net Zero Carbon South Warwickshire’ section) This is not in the NPPF but we support this. • Mix and amount of development (links to D3 below) - getting the right range of complimentary uses Similar to wording in NPPF, so supported. ‘Complimentary’ should be ‘complementary’ Issue D2 -Design codes: The wording in this section is fine, as it refers to the use of National Design Guide and National Model Design Code. We support the proposed policy. Question D2: options for format of design guide: Separate guides or codes for each district or area would seem to be the most appropriate, manageable and practical. However, when combined it is essential that they cover the whole plan area. Issue D3 – Adaptable Places The wording in this section is fine. It refers to ‘strategic design principles set out in DS1’ – this should read D1 We agree that the approach to density should be addressed or bottomed out at this stage as it will influence the amount of development land which needs to be allocated. Question D3- density: There is no reason why the minimum density should not be the same in both Warwick and Stratford districts. Designs for new sites should take into account the current densities of nearby areas, but these existing densities on their own should not dictate the design of the new development.
QD5Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? The JPC supports heritage assessments. QD6 Please add any comments you wish to make about a well-designed and beautiful South Warwickshire Not at this stage.
Q-D2 52. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 54. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
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.
I have found the information on the forthcoming plan completely impenetrable, with no detail on what will happen to Studley. What I have found implies that building on land to the south of Mallard Road, off Gunners Lane, in Studley will be proposed. I object to this in the strongest terms, the information about access is flawed, the access is narrow. The 15 minute work is also flawed, this part of Studley is downhill and most shops are across a busy main road. Nobody walks to do a weekly shop in Studley, it's a car to Aldi or out of the village as the Co-op is far too expensive- Waitrose in Alcester is cheaper! Studley has no post office, if it does get one it'll be a very steep hill less able people will need to climb if walking to it. The doctors is already bursting and road infrastructure can't cope. On this side of the village we rely on The Park for recreation - walking dogs and relaxing. We have no playgrounds and the nature reserve is at least 20 minutes walk away across the village. But specifically, land south of Mallard Road - The Park - should remain in Green Belt and protected, gardens of existing long established development forms a clear boundary to what is very open areas of countryside - ANY chipping away at Green Belt here will open the floodgates and destroy Studley as village forever. The rural setting of the village is really only appreciated from the fields along the river here, and rural setting for our only intact heritage buildings and landscape which deserves better recognition and protection, not destroying. Visitors often comment that going into the field through the gate off Wickham Road is like going into a completely separate world, and marvel how magic that feeling is. Please do not destroy it. If the village is forced to have new houses, perhaps concentrate in a less sensitive location away from the river meadows and over the brow of the setting of the river valley and its sweeping views - perhaps with a new (much needed) roundabout at Spernal Ash/A435 junction and houses clustered towards the sewage works, out of the way of existing homes and well-loved open spaces that are extremely well used (for informal recreation) by many villagers and visitors.