Issue and Options 2023
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New search2.77. While Design Guides can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable in a local authority area, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design perspective since they can give rise to homogeny. 2.78. The Respondent would also caution against the preparation of design guides for numerous different areas, which would seem an overly complex approach. 2.79. If the Councils decide to proceed with the preparation of design guides or codes for specific places, then it is considered imperative that these are publicly consulted on. 2.80. If intended to be used as policy rather than flexible guides, then Design Guides must be brought forward as Development Plan Documents (DPD) and independently examined given the implications that they could have on the viability and delivery of 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. 2.81. The Respondent is not convinced that a policy that prescribes densities is entirely necessary and considers Options D3c and D3d to be unduly complex. However, it is acknowledged that density does need to be optimised in accordance with Paragraph 141 of the NPPF if Green Belt release is to be justified. Considering the options therefore, the Respondent would suggest the inclusion of a policy that is in line with Option D3a but which is perhaps supplemented with explanatory supporting text with regards to the sort of density ranges that developments should be aiming for depending on their location, accessibility and context.
No answer given
Q-T1: Please select all options which are appropriate for South Warwickshire Option T1b: Include reference to the principles of a 20-minute neighbourhood or other similar design approach (e.g. Building for a Healthy Life) within a broader overarching policy. 2.82. The Respondent is supportive of the maximisation of opportunities for people to meet their day-to-day needs near to where they live and are therefore supportive, in principle, of the 20-minute neighbourhood concept. Turning to Hampton Magna, the Respondent’s site to the west of Hampton Magna is compliant with the 20-minute neighbourhood principle and is considered an ideal candidate for allocation. Further information regarding the site is set out under Section 3.0 of this Statement and the accompanying Promotion Document. 2.83. The main issue with the application of the 20-minute neighbourhood concept is the predominant rural nature of South Warwickshire, where 20-minute neighbourhood principles will be difficult to translate. As noted elsewhere in this Statement, the Councils have an obligation to consider the vitality of rural settlements in accordance with Paragraph 79 of the NPPF. To adopt a strategy that plans solely on the basis of the 20-minute neighbourhood concept therefore is to potentially ignore large swathes of the plan area to the disadvantage of the vitality and viability of those settlements located within the rural hinterlands. The Council will therefore need to allow for flexibility in the way that 20-minute neighbourhood principles are applied should they proceed with such an approach. The same goes for alternatives such as Building for Healthy Life, which in the Respondent’s view should be presented as best practice as opposed to a specific policy requirement.
No answer given
Q-T2: Please select the option which is most appropriate for South Warwickshire Option T2a: Include a policy which takes a hierarchical approach in terms of prioritising transport infrastructure. 2.84. The Respondent is supportive of the inclusion of a policy that seeks to maximise opportunities for sustainable transport by taking a hierarchical approach. However, it should be recognised that opportunities to maximise sustainable transport solutions will vary between urban and rural areas as per Paragraph 105 of the NPPF. 2.85. The introduction of lower parking standards in areas that have good active/public transport links may be appropriate but only where there is robust evidence to suggest that such action is likely to achieve a change in travel habits. This will help to avoid issues related to insufficient parking provision once developments are occupied.
Q-B1: Please select the option which is most appropriate for South Warwickshire Option B1b: Remove Areas of Restraint designations 2.86. A disjointed approach between the two local authority areas should be avoided wherever possible. Of the options presented therefore, the Respondent would favour removal of existing areas of restraint, with open areas of land that serve to preserve the structure and character of settlements protected through more generic heritage and/or landscape policies. Q-B3: Please select the option which is most appropriate for South Warwickshire Option B3c: Discard Special Landscape Areas and bolster general landscape policy 2.87. A disjointed approach between the two local authority areas should be avoided wherever possible. Given that Special Landscape Areas are now a somewhat outdated concept the Respondent considers, in the interests of consistency across the plan area, that Special Landscape Areas should be discarded (rather than seek to establish such areas across the whole of South Warwickshire). Q-B4: Please select the option which is most appropriate for South Warwickshire Option B4a: Maintain the current policy approach, without the use of a buffer 2.88. Creating a buffer around the Cotswold AONB is superfluous to national planning policy that requires development within the setting of AONBs to be sensitively located and designed to avoid or minimise impacts. The Respondent therefore considers Option B4a, which seeks to maintain the current policy approach without use of a buffer to be sufficient in this case. Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these 2.89. Environmental Net Gain is an entirely new concept with no tried and tested approach to its delivery. It is therefore currently unknown how Environmental Net Gain would work in practice. The Respondent therefore reserves their right to make comment once more detailed information is available. Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? Y/N/ DK 2.90. No. Wildbelt is a highly aspirational concept with no statutory or national planning policy basis. Unlike other designations there is no tried and tested method for the identification or delivery of Wildbelt. It is therefore unclear upon what basis the Council would seek to justify such designations particularly in light of the absence of the Local Nature Recovery Strategy (LNRS), which is understood from the Consultation Document to be many years away. The Respondent therefore reserves their right to make comment once more detailed information is made available. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? Y/N/DK 2.91. No. Agricultural Land quality is only one of a number of factors that is taken into account when considering whether a site should be developed or not. While Paragraph 174b of the NPPF recognises the benefits of best and most versatile agricultural land this is expanded on in Footnote 58 on Page 50 of the NPPF which requires consideration of the issue only where ‘significant development’ of agricultural land is demonstrated to be necessary. In such instances, the Footnote considers that poorer quality land should be ‘preferred’ to that of a higher quality. However, this does not mean that it is mandatory to avoid the development of best and most versatile agricultural land. It is therefore highly inadvisable to promote a policy that looks to avoid the development of or seeks the retention of best agricultural land as suggested.
