Issue and Options 2023
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For detailed comments see Barton Willmore, now Stantec, letter dated 6 March 2023 and email dated 6 March 2023 with enclosures. Additional comments as follows: As noted above in our view there is a need for the SWLP to consider housing land supply and what the approach of preparing a Part 1 and Part 2 plans means for the housing trajectory. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. A review of settlement boundaries as part of Part 1 could form part of that approach.
We write on behalf of CEMEX UK Operations Ltd (CEMEX). CEMEX is a global supplier of construction materials. CEMEX has extensive land holdings within Warwickshire which include s land south of Stockton Road, Long Itchington. The site promoted for residential led development through the South Warwickshire Local Plan. The Long Itchington site is circa 2.08 ha and lies on the edge of Long Itchington (a Category 1 Local Service Village) and comprises an arable agricultural parcel. It is contained by hedgerow and trees to the southern (beyond which is the canal) and eastern boundaries, new residential development to the north and west and an agricultural parcel to the east. A site location plan is attached at Appendix 1. Proposals have been developed for the Long Itchington site, including previous submissions to the SWLP Scoping and Call for Sites consultation in June 2021, the Site Allocations DPD consultation in July 2022 and a pre-application submission in May 2022 and written response dated 6 September 2022. Engagement has also been undertaken with the Parish Council. To support the promotion of the Site through the emerging Development Plan CEMEX has undertaken an exercise to update the evidence base and respond to the amber and red issues identified in the SHLAA (dated 2021). An illustrative layout was also prepared to demonstrate how development can be brought forward on the site (see Appendix 2). The updated evidence base seeks to remove all technical impediments to delivering the site, it is therefore CEMEX’s view that the Long Itchington site is suitable, available and achievable in the short term for housing. The Case Officer’s Pre-application Response (copy enclosed at Appendix 3) suggested that further preapplication advice was required from County Officers in regards to Ecology, Landscape, Heritage, Transport, and Flooding. It should be noted that Stantec held pre -application discussions with Warwickshire County Council as Lead Local Flood Authority which informed the suggested approach.CEMEX has instructed this work and pre-application requests have been submitted seeking further advice. Responses are awaited from Ecology and Landscape. Vectos attended a pre-application meeting with County Highways Officers and the following points and actions were confirmed: • Traffic Generation and distribution - the Highway Authority considers the methodology presented in the Scoping Note, whilst not following the protocol, is acceptable. It is noted that further justification for the proposed methodology should be included within any Transport Assessment. • Traffic Modelling - the Highway Authority raised several points regarding the preliminary traffic modelling included within the Scoping Note. These issues would be resolved in a submitted Transport Assessment. • Site Location - given the proposed site is located immediately adjacent to two residential developments built in the recent past, it is concluded that the proposed site is easily accessible from the highway network and is in a sustainable location. • Access & Layout - The Highway Authority advised on several proposals, which should be incorporated within the proposals including access to the towpath, extension of a footway on Stockton Road and a new crossing facility on Stockton Road. As set out within the Scoping Note, we are keen to encourage sustainable travel and will investigate your proposals further. • Vehicle Access – The Highway Authority noted that their Design Guide indicates a minimum separation of 25 metres between junctions. I can confirm the distance between the proposed and existing junction is circa 69 metres. As such it complies with the guidance. Swept path analysis will be submitted as part of a planning submission. • Internal Layout – The Highway Authorities comments on the internal layout will be considered by the design team. In terms of Heritage, the issue to be discussed was setting of the listed building . We followed Officer’s advice and submitted a request for formal conservation pre-application advice, however the Conservation Officer has since advised that they would not comment on such a submission. We have sought further direction from Planning Officers, a response is awaited. The consultant team has prepared a further update to their reports as part of the evidence base and this is included as part of the Call for Sites submission.Long Itchington is a small scale residential opportunity that is able to contribute to a 5 year housing land supply. It is not strategic in scale, however it can make a contribution towards 5 year housing land supply whilst strategic sites are worked through. In our view there is a need for the SWLP to consider housing land supply in this context and the approach of preparing a Part 1 and Part 2 plans and what this means for the housing trajectory, achieving sustainable growth and meeting housing need . In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. These representations therefore consider the growth options in this context and the assessment of the site in the evidence base. The required Form has been completed on the Consultation Portal. An updated ‘call for sites’ submission accompanies this representation. Proposed Approach to Online Form and Consultation Portal We have completed the Online Forms on the SWLP Consultation Portal for the site as requested by the Council. However the Online Form is overly restrictive. For questions which require an option to be chosen, there is not always an opportunity to pick neither option. Therefore, we have artificially selected options in order to register an interest to comment, whilst cancelling out these choices, our detailed comments are set out in the covering letter below and we request that that they are considered by Officer’s in full, as well as the enclosures listed. In order to submit an answer to Question Q-S8.1, the Online Form requires you to pick an answer from the options provided for Q-S8.2. There is no opportunity to provide another answer or written comments. We have had to provide an answer however it does not represent our detailed comments set out in this letter below and we request that these comments are considered instead. Whilst we appreciate the Council’s desire to gather quantitative data, we would suggest that there needs to be the option to provide additional commentary otherwise the results of the consultation are not representative.
The strategic objectives are broadly supported, and we consider they will combine to promote sustainable development within South Warwickshire in line with the aims of the National Planning Policy Framework (NPPF). However, in our view there is a need for the SWLP to be more visionary and clearer in its objectives that relate to growth. For example, reference to ‘allowing for growth in new homes’ to meet needs should be strengthened to reflect Paragraph 60 of the NPPF which refers to the need to support the Government’s objective of ‘significantly boosting the supply of homes’.
Q-I2: Please select the option which is most appropriate for South Warwickshire Option I2a: Set out infrastructure requirements for all scales, types and location of development Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy Paragraph 11(a) of the NPPF makes clear that all plans should inter alia seek to meet the development needs of their area and align growth and infrastructure. Moreover Paragraph 34 also states that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. There is a need to understand the infrastructure requirements from the growth strategy set out across the plan area through the preparation of an Infrastructure Delivery Plan or such other similar report. This is needed to inform the approach to the SWLP. In respect of Option I2b the commentary notes that this option would mean that requirements in other locations would not be set until the Part 2 plan was adopted. In the interim, the existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two Districts. Part 2 of the Plan will need to be consistent with the growth strategy set out and adopted at Part 1 therefore the infrastructure needs would already be known to an extent. Moreover, the IDP i s a ‘live’ document that can evolve and be updated at Part 2. Q-I3: We consider that Option 13a is preferrable as it enables a consistent approach for the delivery of the sustainable growth and the required infrastructure across the whole plan area. Indeed, a similar approach was taken by South Worcestershire Councils (Malvern Hills, Worchester City and Wychavon) who prepared a joint Local Plan and then common CIL Charging Schedules. The CIL charging schedule was supported by an IDP as highlighted above. This provides a consistent approach across the plan area.