Issue and Options 2023
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New searchYes - the focus for the Vision is considered to be appropriate. It is appropriate for the focus in the Vision to be on the delivery of homes and jobs and to identify that this will include, where appropriate, unmet need from neighbouring authorities. The 5no. elements of the Vision are considered to be relevant and valid. The site BDWH is promoting to the north west of Warwick Parkway Railway Station is an example of a site that will fully address each of the 5no. main areas set out within the collective Vision. However it is noted that the vision is set out up to the year 2050. The current National Planning Policy Framework (NPPF) para. 22 states that strategic policies should look ahead over a minimum 15-year period from adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055.
Having reviewed the Sustainability Appraisal, we wish to make comments in relation to Broad Area B.30 Warwick Northeast. The southern end of this broad area contains the land that BDWH is promoting to the north west of Warwick Parkway Railway Station (as set out in the Vision Document submitted to the Call for Sites process accompanying this letter). These comments are set out in Appendix A of this letter. Firstly, it is entirely appropriate to include this broad area as a potential option for the consideration of development in the future, given its location on the western edge of Warwick, which is one of the largest and most sustainable settlements within the SWLP boundary. The proximity of this broad area to the Warwick Parkway Railway Station, which provides public transport connectivity within the District and beyond, makes it a highly sustainable location. However, the approach taken to assess the Broad Areas within the Sustainability Appraisal process results in the overgeneralisation of some of the impacts due to the size of the areas being assessed. The review of reasonable alternatives ought, therefore, to assess specific opportunity sub-areas within these Broad Areas. One of these specific opportunity sub-areas that should be assessed needs to be the land to the north west of Warwick Parkway Railway Station on the basis that this is a self-contained area which is separated from the remainder of B.30 by the Birmingham Road (A4177). The site is bound by the Birmingham Road (A4177) to the north, the Grand Union Canal to the south, the Old Budbrooke Road to the east and an existing hedgerow to the west. In this regard we have re-appraised this sub-area on its own merits against the criteria used within the Sustainability Appraisal. The output from this process, included in Appendix A, highlights that the appraisal outcome for this sub-area is more positive than the appraisal outcome included within the Sustainability Appraisal for the Broad Area as a whole, notably in relation to: Ancient Woodland; ecological designations; access to leisure, food store and PROWs; and potential for delivering some employment floorspace. The Vision Document which is being submitted alongside these Issues and Options representations demonstrates the potential that the BDWH land to the north west of Warwick Parkway Railway Station offers for delivering residential development and green infrastructure in a way which connects and assimilates development into the wider landscape context.
Q-I2 Option I2a: Set out infrastructure requirements for all scales, types and location of development Infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire, are key for the Local Plan. The NPPF requires Local Planning Authorities (LPAs) to plan for, and allocate, sufficient sites to deliver the strategic priorities of the area (see NPPF paragraph 23). The extent and costs for the supporting infrastructure required should be understood at an early stage.
Q-I3 Option I3a: Establish a South Warwickshire CIL (or emerging new Infrastructure Levy) to support the delivery of the Plan Whilst it would be simpler to have a single levy for the whole of South Warwickshire, market characteristics are important when deciding on an appropriate level of CIL levy (as evidenced by the different rates between the LPAs at present). These area-based characteristics could be picked up through the appropriate use of zoning across this wider area under a single South Warwickshire CIL. It is important to consider the viability of individual sites when determining the CIL charging rates (see PPG Paragraph: 021 Reference ID: 25-021- 20190901).
Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability Infrastructure, viability and deliverability are all key considerations in the production of the SWLP. At this stage, key documents such as the Infrastructure Delivery Plan (IDP) and Housing and Economic land Availability Assessment (HELAA) are yet to be produced, and therefore the key underlying assumptions of any viability work are unknown. Once evidence base documents such as the IDP and HELAA are available, the Councils should undertake a detailed viability assessment to inform the preferred options consultation. To ensure that the SWLP is consistent with national policy, as required by NPPF paragraph 35, any requests for contributions should be made in compliance with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010, and confirmed at paragraph 57 of the NPPF. As identified in NPPF paragraph 34 the policies and levels of contributions included within the Local Plan should not undermine the viability and deliverability of the Local Plan.
Q-S2: Option S2b: Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes Chapter 11 of the NPPF encourages effective use of land, including: taking into consideration the need for different types of housing; the desirability of maintaining an area’s prevailing character and setting; and the use of minimum density standards for city and town centres and other locations that are well served by public transport. There is role for the intensification of development in certain areas of the SWLP area as part of the wider strategy. However development site character and context will vary significantly across the SWLP area, both within town centres and outside of the town centres. Planning policies will need to be sufficiently flexible to be able to accommodate this. Accordingly option S2b will enable a well-planned best use of available land, incorporating intensification where appropriate but without prejudicing the need to reflect context and character on a site-by-site basis, particularly on the rural fringes of settlements. The PPG1 cautions that measuring ‘dwellings per hectare’ can: “encourage particular building forms over others, in ways that may not fully address the range of local housing needs… It is therefore important to consider how housing needs, local character and appropriate building forms relate to the density measures being used.” Therefore it is important that future policy wording should allow for density and the approach to intensification to be determined on a site by site basis. 1 Planning Practice Guidance: Paragraph: 005 Reference ID: 66-005-20190722.
