Issue and Options 2023

Yes

Crest Nicholson welcomes the focus in the Vision on the delivery of homes and jobs and that this will include, where appropriate, unmet need from neighbouring authorities. The inclusion of reference to a ‘Net Zero Carbon South Warwickshire’ is noted and, as set out in the accompanying Vision document for the ‘Land South of Westwood Heath Road’ site, Crest Nicholson is the first UK housebuilder to have its net-zero target validated by the Science Based Targets initiative (SBTi), reflecting its commitment to reducing greenhouse gas (GHG) emissions across its value chain and reaching net-zero GHG emissions by 2045. Crest Nicholson will engage with the Local Plan process as it progresses, in order to assist with ensuring that the policies relating to zero / low carbon development are deliverable.

Having reviewed the sustainability appraisal, Crest Nicholson wish to make comments in relation to small settlement C.17 South Coventry. This area contains our client’s existing committed development to the south of Westwood Heath Road and some of the proposed expansion area for this development (as set out in the Vision Document accompanying the representations). Firstly, Crest Nicholson support the inclusion of this area as a potential option for the consideration of development in the future, given its location on the southern boundary of Coventry and the development approved and under construction on the Crest Nicholson site to the south of Westwood Heath Road for 425 dwellings (W/22/0055) at the western end of the C.17 area. We however query why, when considering reasonable alternatives, the ‘South Coventry’ area is being classified as a ‘small settlement location’ and not a ‘broad location at the main settlements’ due to its location on the edge of Coventry. It is maintained that, whilst Coventry is outside of the Local Plan area, the South Coventry location is more akin to the ‘broad locations’ identified around settlements such as Leamington Spa, Warwick and Kenilworth, particularly given the commitment in the Local Plan Vision to meet, where agreed and appropriate, unmet need from neighbouring authorities. In relation to the boundary shown for the Coventry South location, it is noted that this omits land that has previously been removed from the Green Belt and forms part of the adopted Warwick Local Plan housing allocation H42. To maximise the potential capacity in this sustainable location adjacent to an existing committed development, and assist with reducing the amount of land that might need to be removed from the Green Belt through this new Local Plan, it is requested that the entirety of the H42 non Green Belt land is included as part of the Coventry South location. The additional land to be included is highlighted in the plan below. A Vision document is being submitted alongside these Issues and Options representations, which shows the potential of this blue land for accommodating additional residential development in a way which can be assimilated into the landscape context whilst not resulting in significant harm to the nearby Scheduled Monument. There is also currently considered to be capacity within the local highway network to accommodate the expansion of this existing committed site in the manner suggested. We have reviewed the assessment undertaken by the Sustainability Appraisal in relation to C17, and have the following comments: • Table C.17.1 ‘SA Objective 1: Climate Change’ refers to the assumption that this location could deliver a maximum of 500 dwellings. Clarification is sought that this is in addition to the already approved 425 dwellings (W/22/0055) in this location. • Table C.17.11 ‘SA Objective 11: Accessibility’ shows scores for a number of receptors, including a negative score for ‘Local Services’. However, the methodology set out in Chapter 2 of the SA refers to ‘Food Stores’ as opposed ‘Local Services’ and states that a positive score will be given where a location is within 800m of a food store. It is noted that the approved residential scheme at Westwood Heath will deliver a food store on site and therefore the entire South Coventry location will be within 800m of the store. This accordingly ought to be given a positive score. This is of particular relevance to SA Objective 11, where the South Coventry location has a positive score in relation to all other accessibility categories. However, due to the SA taking only the lowest score into account for each objective, the ‘Local Services’ negative score is the only one included in the summary table for the Small Settlement Locations (Table 5.1).

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Q-I2: Please select the option which is most appropriate for South Warwickshire Crest Nicholson supports option I2a. Infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire, are key for the Local Plan. At an early stage this should be considered in relation to all proposed / potential growth areas and allocation sites (irrespective of whether these will be included in Part 1 or Part 2 Local Plans) in a joined up fashion, to ensure that there is clarity in relation to how infrastructure is being planned for across the Local Plan area. 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. Crest Nicholson considers that the most efficient way for the South Warwickshire LPAs to achieve this would be to progress a single Local Plan, as opposed to a plan in two parts. This would ensure that there is suitable confidence that the infrastructure to deliver all housing supply is available and has been suitably planned for. It is not considered to be either necessary or efficient for the emerging Local Plan to be split into two parts. It should also be noted that the proposals being mooted through the Levelling Up and Regeneration Bill seek to speed up the Plan-making process and do not align with the sort of two-part approach being sought by the South Warwickshire authorities. The production of a single Local Plan would therefore be the simplest and most transparent option for enabling the South Warwickshire authorities to provide certainty and demonstrate at the earliest opportunity that it has an up-to-date deliverable Development Plan that can achieve the NPPF allocation and land supply requirements, backed up with a robust plan for the delivery of infrastructure. Crest Nicholson understands that the approach jointly proposed by the Councils to prepare the Plan in two separate parts, to first set out a Vision, Objectives and Growth / Strategic Policies (Part 1) followed by Detailed Policies and Strategic and Smaller Site Allocations (Part 2), is intended to enable the first part of the Local Plan to be prepared more quickly. However, this is likely to lead to specific site allocations taking longer to be adopted. The plan will only become effective once specific locations for development are identified. Without these, unplanned development may come forward and unsustainable patterns of development are at risk of being perpetuated. Q-I3: Please select the option which is most appropriate for South Warwickshire At present both Warwick and Stratford-on-Avon district Councils have a CIL charging schedule in place, which have different charges payable for residential development. Our initial analysis has shown that for general residential development at present this CIL charge can vary from £82.01 per sqm. in Warwick town, to £168.51 per sqm. in the wider Stratford on Avon area. Therefore, Crest Nicholson consider that market characteristics are important when deciding on appropriate level of CIL levy (as evidenced by the vastly differing rates between the LPAs at present). These area-based characteristics could either be picked up through the appropriate use of zoning across this wider area under a single South Warwickshire CIL, under a joined up approach to charge and collect funds for delivering infrastructure that served this Local Plan area, or through separate CILs for each LPA as long as there is a suitable mechanism to ensure that the funds are spent in a way that reflects the joined up nature of the wider development strategy. Under whichever option is pursued, it is important to consider the viability of individual sites when determining the CIL levels to charge (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 South Warwickshire Local Plan. 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 Council should undertake a detailed viability assessment to inform the preferred options consultation due to take place later this year. To ensure that the plan is consistent with national policy, as required by NPPF paragraph 35, any requests for contributions could 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.

Yes

Q-I4.1: Should we include a policy to safeguard specific infrastructure schemes within the SWLP? It is noted that the SA location plans include the safeguarded land areas identified as part of the High Speed Rail 2 (HS2) project. It is considered appropriate to include a policy within the Local Plan to safeguard this land. The need for such policies should however be kept under review during the course of the production of the Local Plan to respond to the need / opportunity for the delivery of specific infrastructure schemes (e.g. A46 Strategic Link Road) to ensure that the Local Plan is appropriately planning for, and mitigating the delivery of, development requirements and impacts from both within and adjacent to the Local Plan area. Q-I4.2: Please add any comments you wish to make about these specific safeguarding provisions Any safeguarding policy for HS2, or other identified infrastructure schemes, should include a mechanism for safeguarded land to be considered for an alternative use once it is no-longer required, subject to the requirements of other Local Plan policies.

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The limitations of the Urban Capacity Study (Arup 2022) are highlighted in the report. The study is a theoretical exercise only. It is not intended to conclusively establish the urban housing capacity of South Warwickshire over the period to 2050. Instead it simply indicates potential urban housing capacity. More detailed work is required to confirm actual capacity. It is important to note that the study has not been informed by the outcome of an area-wide HELAA. The Urban Capacity Study concludes that there is a potential 19,950 dwelling supply (including windfall sites) and states that there is an additional potential up to 3,400 dwellings capacity that could be delivered on car parks. This means that in total up to 23,350 dwellings may be able to be delivered in urban areas in South Warwickshire. This assumes that all sites identified in the urban capacity study are deliverable and viable, and that the upper number of dwellings to be delivered on car parks is achievable. All of these assumptions require further testing, including on a viability basis, once the HELAA has been published. This identified capacity compares to a total baseline housing need in the area of 41,975 dwellings as calculated from the trend based calculation in the HEDNA, assuming a plan period from 2025-2050. This results in a c.18,625 dwelling shortfall (which could be higher once any cross-boundary apportionment of development from Coventry and / or Birmingham have been taken into consideration). The study concludes that it is unlikely to be possible to meet current development needs without significant greenfield development. However, in light of the figures set out above, the study should categorically conclude that a significant amount of greenfield development in sustainable locations will be required.

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Yes

In relation to the settlement analysis, and having reviewed the sustainability appraisal, we wish to make comments in relation to small settlement C.17 South Coventry. This area contains our client’s existing committed development to the south of Westwood Heath Road and some of the proposed expansion area for this development (as set out in the Vision Document accompanying the representations). Firstly, Crest Nicholson supports the inclusion of this area as a potential option for the consideration of development in the future, given its location on the southern boundary of Coventry and the development approved and under construction on the Crest Nicholson site to the south of Westwood Heath Road for 425 dwellings (W/22/0055) at the western end of the C17 area. Crest Nicholson however queries why, when considering reasonable alternatives, the ‘South Coventry’ area is being classified as a ‘small settlement location’ and not a ‘broad location at the main settlements’ due to its location on the edge of Coventry. It is maintained that, whilst Coventry is outside of the Local Plan area, the South Coventry location is more akin to the ‘broad locations’ identified around settlements such as Leamington Spa, Warwick and Kenilworth, particularly given the commitment in the Local Plan Vision to meet, where agreed and appropriate, unmet need from neighbouring authorities. In relation to the boundary shown for the Coventry South location, it is noted that this omits land that has previously been removed from the Green Belt and forms part of the adopted Warwick Local Plan housing allocation H42. To maximise the potential capacity in this sustainable location adjacent to an existing committed development, and assist with reducing the amount of land that might need to be removed from the Green Belt through this new Local Plan, it is requested that the entirety of the H42 non Green Belt land is included as part of the Coventry South location. The additional land to be included is highlighted in the plan below. A Vision document is being submitted alongside these Issues and Options representations, which shows the potential of this blue land for accommodating additional residential development in a way which can be assimilated into the landscape context whilst not resulting in significant harm to the nearby Scheduled Monument. There is also currently considered to be capacity within the local highway network to accommodate the expansion of this existing committed site in the manner suggested. Appendix 3 of the Settlement Design Analysis (January 2023) includes design analysis for the ‘South of Coventry’ location. The Westwood Heath Road Connectivity Analysis identifies the residential area of Crest Nicholson’s committed residential development to the south of Westwood Heath Road. The connectivity of land immediately to the south and west of this (2(C) and 1(D)) should be more positively scored than it is on the basis that connections can be delivered into the road, walking and cycling network being brought forward as part of the existing committed residential development area through an amendment to the layout to this development. The opportunities for this are shown within a Vision Document which is being submitted alongside these representations.The Westwood Heath Road Density Analysis should be updated to reflect the density of residential development that is being delivered at the committed Crest Nicholson residential development to the south of Westwood Heath Road in order to ensure that the context is being most appropriately represented.