Issue and Options 2023

Stratford-on-Avon Site Allocations Plan (SAP): Sustainability Appraisal (SA) Our client’s site was assessed as part of the Stratford-on-Avon Site Allocations Plan (SAP): Sustainability Appraisal (SA). In Appendix VIII: SA of Options for Reserve Housing Sites by Settlement, the site is assessed in some detail. This confirms that: a. There are five ‘neutral’ effects – i.e. impacts of the site which are neither positive nor negative when considered. b. There are six ‘minor positive effects’ – i.e., development of the site would have minor positive effects on Ettington. These include not resulting in the loss of public open space or green infrastructure, confirming that an existing footpath running through the site could be incorporated into any proposed development, being located within 400m of the nearest bus stop and within 400m of the nearest services/facilities (Post Office and Schools), not creating any conflicting neighbouring land uses, and largely following the existing settlement pattern. c. There are only 2 ‘major negative effects’ identified: the heritage issue discussed below, confirming that the concern relates to the Grade II listed building Ryepiece Barn on Rogers Lane; and the site’s location within the Feldon Parklands Special Landscape Area (SLA). However, on this latter point, it is notable that the 2021 SHLAA shows that every site in Ettington, including the site identified in the NDP, and the site identified in the 2022 SAP for Self-Build housing are affected by this designation. Both the SHLAA and the SA make the point that impacts can be mitigated through restricting development to the northern part of the site and through extensive landscaping. Finally, our client’s site was included as a reserve housing site in a previous iteration of the SAP, which demonstrates that officers recognised the future development prospects and suitability of this site in accommodating housing development. To summarise, Ettington is a Category 3 LSV with a number of sustainability characteristics which make it particularly suitable for some further housing development. Our client’s site, Land south of Rogers Lane (middle) (ref. ETT.11) has been assessed through iterations of the SHLAA, and the Sustainability Assessment of the SA as having many positive factors, and the negative impacts identified can be effectively mitigated.

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Heritage Considerations affecting land South of Rogers Lane (middle) The only constraint affecting our client’s land at Ettington is a heritage consideration. Four heritage assets have been identified as being potentially affected by development of the site: 1. Rye Piece Barn (Grade II Listed Building); 2. Manor House including attached barn and stables (Grade II Listed Building); 3. Iron Age Pits and Ditches (Non-designated heritage asset); and 4. Medieval ridge and furrow (Medieval ridge and furrow). Previous planning application and appeal processes have demonstrated that heritage assets 2, 3 and 4 would not be impacted by development of our client’s land. Regarding Rye Piece Barn, a past appeal decision found that development of the site would cause “less than substantial harm” to the asset. If a comparable setting for the barn can be established as part of a scheme for the development of the land at Roger’s Lane, the site could be brought forwards with suitable mitigation of the heritage impacts. A scheme which accommodates a lower quantum of built development and takes into consideration the setting of the nearby heritage asset could therefore be acceptable in heritage terms. Our clients are committed to bringing forward a scheme which can deliver this mitigation. We also note that planning permission was granted in 2017 (ref. 16/03972/FUL) for 6 houses immediately to the west of Rye Piece Barn. In terms of heritage impacts, the Planning Officer’s delegated report stated: “The applicant has in the current proposal aimed to address the identified harm by reducing the amount of properties proposed and increasing an undeveloped buffer zone immediately adjacent to Rye Piece Barn. These changes are assessed as having have made the proposed development less intrusive in relation to views across to the barn and retaining an open rural character to the area to the south-west of the application site. The proposed development is less intensive and leaves sufficient open space surrounding Rye Piece Barn to largely preserve the semi-rural context and the way that it is experienced. The substantial wild flower planting buffer zone is important in preserving the setting of the heritage asset and should be left open and unimpeded to ensure that there is no additional harm caused. The changes made to the proposed scheme would reduce the previously identified harm to a level below ‘less than substantial’. The test set out in the NPPF is therefore not triggered and the impact on the setting of the listed building is considered to be acceptable”. Immediately adjacent to Rye Piece Barn, the recently approved housing development shows that it is possible to accommodate development on neighbouring land, whilst respecting the setting of the listed barn. This principle would also apply to Land at Rogers Lane, whereby new development incorporating a suitable buffer to respect the setting of the listed building could be designed in such a way that any potential harm is below ‘less than substantial’ harm to the heritage asset, compliant with NPPF policy. Our clients would be pleased to offer examples of how these principles could be demonstrated in relation to development options on the Land at Rogers Lane.

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The South Warwickshire Local Plan is at a relatively early stage of production. The current consultation is the Issues and Options phase, and includes the publication of a number of options for the future policy direction of the plan set out in a Consultation Document. We have noted that it is now intended to bring forward the SWLP in 2 parts, and only Part 1 is currently progressing through the plan-making process. Part 1 sets out strategic policies, and will not set out detailed site allocations. It is unclear exactly what the scope and content of Part 2 may be, and how it will relate to other plan processes in the plan area such as the Stratford-on-Avon Site Allocations Plan. We have requested clarification of how it is intended that detailed site allocations to cover the plan period up to 2050 will be set out following the adoption of the SWLP Part 1. We have also provided comments on a number of the elements set out in the Consultation Document: a. The assessment of housing needs and the alternative method set out in the HEDNA. We support the alternative method and the level of housing need that the SWLP needs to make provision for. We have noted that the Consultation Document does not set out a housing requirement for the plan, nor has there yet been an agreed assessment of the amount of unmet need to be accommodated from the Birmingham and the Black Country HMA. We will comment on these matters at the next stage of plan making. b. We have commented on the options for the development of a spatial strategy to guide the distribution of development across the plan area. Noting that no strategy is yet proposed, we have noted that taking elements from each of the options presented would be likely to result in a strong spatial strategy that will be able to meet development needs and also sustain settlements of all sizes across the plan area. In particular, elements of the strategy which would enable the creation of networks of sustainable rural settlements, promoting the future sustainability and viability of rural communities, should be balanced against the need to ensure that strategic development is accommodated in locations well related to existing urban areas and transport routes, and/or in new settlements. c. We have commented on detailed policy matters including the policy elements looking at 20-minute neighbourhoods, settlement boundaries and Special Landscape Areas. We have set out the characteristics of Ettington and our client’s land at Rogers Lane, Ettington. The site is available, suitable, economically viable and achievable, and deliverable in the short term. The future development prospects and suitability of this site in accommodating housing development has clearly been recognised by Stratford-on-Avon District Council by virtue of officers previously supporting an application on the subject site for 80 dwellings and the site being included in the SAP previously as a future reserve housing site. We believe that the Council’s assessments show that Ettington has a number of sustainable characteristics which make it suitable for growth in the plan period to 2050, and it can be shown that the main heritage constraints affecting the site can be overcome.