Issue and Options 2023

Long Itchington Parish Council welcomes the opportunity to comment on the Issues and Options Regulation 18 consultation stage of the emerging South Warwickshire Local Plan (SWLP). The production of a new statutory development plan that includes the Stratford-on-Avon District Council area is a significant undertaking and the Parish Council commends the authors on the comprehensive nature of the plan. The resources available to the Parish Council make it difficult for us to be able to comment effectively on all aspects of the SWLP. We have therefore focused our comments on specific areas within the SWLP, in particular Chapter 4 (Meeting South Warwickshire’s Sustainable Development Needs), Chapter 6 (Delivering homes that meet the needs of all our communities), and Chapter 10 (A well-connected South Warwickshire). Where possible we have attempted to provide a more general response to other issues and questions within the plan. We have tried to directly address some of the questions highlighted within the consultation document. Where direct answers have been provided we have identified the specific question or section being responded to. However, we have also included some general text to highlight specific issues or concerns. Where possible we have identified the section of the plan (and supporting studies) to which our comments are directed. We acknowledge that this stage of the exercise is to set the overall policy framework at a strategic level and that the selection of individual sites will follow in the future. However, our previous experience of development planning leads us to seek reassurance that the process to select individual sites will take full account of all available evidence regarding those sites. We have identified a number of flaws in the supporting studies accompanying the SWLP itself and are concerned that these documents will be heavily relied upon for the justification for the future selection of specific development sites. We request the opportunity to provide comments (in particular our local knowledge) on any proposed development sites prior to their publication in the Preferred Options version of the development plan.

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Heritage and Settlement Sensitivity Assessment The Heritage and Settlement Sensitivity Assessment (HSSA) produced by Place Services at Essex County Council for the SWLP is clearly intended to be relied upon in the next stage of the process when individual development sites are selected. The HSSA study states that it is designed to assess the sensitivity to new development on the existing heritage and landscape character within a number of settlements within South Warwickshire. However, despite including the reference to “landscape”, the text of the HSSA consistently gives considerably more emphasis to “heritage assets” than to landscape. In places there is no mention of the landscape aspect at all. This is emphasised by the RAG rating definitions where the “green” rating states; “Green defines areas where there is little known heritage impact, or it is thought that the heritage assets present can be incorporated into any development proposal with appropriate mitigation resulting in no harm to their significance”. According to the HSSA definition a “green” rated area or zone may therefore contain sites that have high levels of landscape sensitivity but are nevertheless afforded little weight by the HSSA study. The HSSA includes a note highlighting; “This assessment is a high-level desk-based assessment. Once areas for development have been identified there will be a requirement for further in-depth assessment, including site visits, of the impact of each individual development on the heritage assets and their setting”. (Again, no specific reference to landscape impact). We fully accept that a statutory development plan should be policy led and not site-led. However, it is essential that, as highlighted by the above note, the selection of sites should take account of a wide range of relevant evidence and should not be over reliant on high level desk-based studies. The shortcomings of a desk-based study are highlighted in the detail provided for Long Itchington. The HSSA document states in section 10.7 (page 150) that the River Itchen; “flows into the Grand Union Canal 400m to the south of the village”. This is clearly an error resulting from misreading the relevant Ordinance Survey map. The River Itchen clearly flows under the Grand Union Canal and this error highlights that landscape impact can only be properly assessed by landscape experts who include site visits when undertaking their assessments. We therefore seek reassurance that the HSSA will not become a “tablet of stone” and used as a prime justification for the inclusion of proposed development sites. We expect that any sites included in the Preferred Options version of the SWLP are assessed on all evidence currently held by the District Council, including all previous landscape evidence.

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The South Warwickshire Settlement Analysis (SWSA) is a high-level desk-based analysis examining connectivity, accessibility and density. We acknowledge that such studies can provide useful comparative data when assessing and comparing different communities or settlements. However, we are also concerned that the study should not be over relied on as representing “hard evidence” when selecting sites for inclusion in the next stage of the SWLP process. The desk top nature of the SWSA inevitable results in a number of flaws. The study records two of the assessed areas in the Connectivity analysis (14 and 15) as having access to healthcare services. This is clearly not the case, there are no healthcare facilities in Long Itchington whatsoever. In the Landform Analysis map a large area in the centre of the map is shown as “green corridor” – which it is not. The identified area when viewed on Google Earth will appear as woodland, however, this is farmland that was planted 20 years with poplar trees under a subsidy scheme. The trees are able to be felled from 2025 and the land returned to general farmland. The model may provide comparative data regarding connectivity and accessibility; however, it contains no assessment of the relative levels of facilities that are being measured it terms of their connectivity and accessibility. Long Itchington is not very well served in terms of infrastructure and facilities and over recent years these have decreased in number (e.g. the closure of the newsagent in The Square and reduction in Post Office facilities). Since 2016 Long Itchington has experienced a significant increase in the overall number of dwellings, rising from approximately 900 in 2015 to the current total of over 1200, an increase of over 33%. The resulting increase in population has not been accompanied by any increase in either infrastructure/facilities or employment opportunities. The SWSA highlights the principle of the “20 minute neighbourhood” which is stated to be where residents can:- “Meet their regular day-to-day needs near to where they live (and/or work), and to do this within a reasonable distance of their homes (and/or workplace)” Residents of Long Itchington can meet some of their “day to day needs” within a 20-minute walk of their home (or workplace), however, many of their needs cannot be met without travelling to another community. The vast majority of such journeys are made by car. The infrastructure and facilities available in Long Itchington are in marked contrast to those available to other nearby comparable communities. Harbury and Kineton both have a significantly greater number of facilities, for example more general shops, doctors’ surgeries and libraries. In terms of population size all three communities are directly comparable. The 2011 census data reveals the population of Harbury as 2,420, the population of Kineton as 2,337 and the population of Long Itchington as 2,013. While all three communities have seen an increase in housing numbers since the 2011 census the increases in Kineton and Harbury are nowhere near the level of that in Long Itchington. Long Itchington currently has 2,100 voters registered on the electoral register and there estimated to be over 300 children within the community. Long Itchington therefore has a population approaching 2,500 and the limited infrastructure and facilities have not increased in line with the significant increase in population. There are very limited employment opportunities within the village and a significant number of residents commute by car to destinations outside the village. Given the current level of infrastructure and facilities available within the village the ”20 minute neighbourhood” model is not sustainable – and is unlikely to be so in the near future. This relative lack of infrastructure and facilities must be taken into account when assessing the allocation of further housing numbers for Long Itchington. The models proposing up to 350 additional houses would be completely unsustainable for the village and a much lower cap must be set for the number of additional dwellings to be built during the entire plan period to 2050. We are acutely aware that the current Core Strategy set an indicative target of 113 houses to be built during the lifetime of that plan (to 2031). By 2021 over 300 additional houses had been completed with 10 years of the plan period remaining.

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Question S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Answer: Yes – but adequate safeguards must be put in place regarding amount and phasing. We have highlighted in our overall response the issues that must be considered for any further growth in Long Itchington.

Appropriate strategy

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Inappropriate strategy

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Overall comments on the HEDNA Much of this analysis is based on the assumption that we move away from the 2014 analysis of household projections and adopt the HEDNA (https://www.southwarwickshire.org.uk/swlp/technical-evidence.cfm). We don’t feel enough evidence for the South Warwickshire Plan has been provided to make an informed decision on the validity of the HEDNA analysis. There are several points of confusion: 1. You state that “Coventry and Warwickshire can be regarded as a coherent housing market area,…… albeit that that there are differences in the economic characteristics between the north and the south of the area” We would say the differences have been under emphasised. 2. We are not sure why an analysis which includes Coventry is being so heavily relied upon to make housing projections for south Warwickshire. 3. One of your most compelling reasons for adopting the HEDNA approach rests on the belief that the 2014 analysis significantly over estimated population projections for Coventry. This may well be true but your figures then increase projections for Stratford and Warwick Districts. It is not completely clear what the justification for this is.

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You say “Certainly, there is a strong argument that if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel.” We are very concerned that Long Itchington is one of the closest northerly places outside of the West Midlands Green Belt and we could envisage that it is proposed to put the over-spill housing need from Birmingham and Coventry within our parish and/or Southam. This is particularly concerning as both Long Itchington and Southam are situated with good road links to Coventry and Birmingham. We urge you not to do this. Southam has experienced the second largest growth in a town (second only to Stratford itself) and Long Itchington has taken the largest proportion of housing of any LSV1.

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Issue H3: Providing the right size of homes We welcome the emphasis on and recognition of the need for inclusion of more smaller dwellings - 2/3 bedroom, and the acceptance of the need for specific housing types, such as bungalows, homes for the disabled and homes for an ageing population. However, we see no evidence of how you might achieve this when it is clear that developers prefer to build larger, more profitable dwellings on larger estates. In relation to bungalows in particular we urge you to consider a tighter definition so that developers cannot build dormer bungalows to fulfil this criterion. This has been a particular issue for Long Itchington. We ask that immediate thought is given to reduction in large scale developments which pay lip service to genuine housing needs. We urge you to make a more marked distinction between “affordable” homes – rented and shared ownership - and homes which are affordable (market homes of a smaller size). In our experience many young people want to get on the property ladder by buying small market houses, not shared ownership. Issue H5: Providing custom and self-build housing plots In our opinion it is not sustainable to allocate small plots solely for SCB housing because of the very real risk that, should they not be sold, they would revert to market housing. We favour the option of identifying plots within a larger development so that unsold SCB plots can more easily be absorbed. However, since we do not wish to see any more large-scale development plots in Long Itchington, we would only support single plot SCB housing endeavours.