Issue and Options 2023
Search form responses
Results for Hallam Land Management Limited (HLM) search
New searchHLM consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and HLM consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
The following comments are made in respect of the SA for Southam. The Site promoted by HLM forms part of Southam Southeast (Broad Location 22). In assessing the four Broad Locations identified in Southam against the SA Objectives, the SA concludes that Southam Southwest is the best performing. That is not the correct conclusion to draw from the Appraisal based on its findings as evidenced below, moreover Southam Southwest is heavily constrained by HS2 which splits the area into two, separating the majority of the Broad Location from the town itself. This site is not therefore a ‘reasonable alternative’ for up to 2,000 homes as part of a single strategic allocation as any new community would be divided by HS2, and therefore the site should not be carried forward in the SA process. Indeed, it is obvious from the assessment of Broad Locations against the SA Objectives at Table 4.1 of the SA that Southam Southeast is the strongest performing Broad Location in the town. The following specific comments are made in relation to the SA and Southam Southeast. SA Objective 2: Flood Risk identifies Southam Northeast as the best performing Broad Location in Southam as it has the smallest proportion of land coinciding with Flood Zone 3. However, and as set out in the SA, Southam Southeast has only a small proportion of land within Flood Zone 3 and indeed this is negligible given it can be easily avoided and mitigated through masterplanning. As such, HLM consider Southam Southeast should be considered equal best performing with regard to SA Objective 2. SA Objective 4: Landscape incorrectly concludes that Southam Southwest is the best performing Broad Location in Southam. The commentary in the SA (at Paragraph 4.11.9) concludes that Southam Southeast is the best performing parcel in terms of landscape sensitivity as it falls within an area of medium landscape sensitivity. The other three Broad Locations contain substantial quantities of high/medium and high sensitivity land parcels which will be more challenging to mitigate, with major adverse effects anticipated. This error should be remedied in the next iteration of the SA. Further, HLM endorse the evidence base that has informed the SA within the Landscape Sensitivity Assessment of Main Settlements including Areas of Restraint Assessment (White Consultants) - July 2011. HLM have supplemented this work with a more up-to-date Landscape and Visual Overview of the town which is appended to these representations. HLM would request the Council take this work into account if it chooses to update its Landscape Character Assessments. SA Objective 5: Cultural Heritage states that Southam Northeast and Southam Southeast are the best performing Broad Locations in Southam. However, in the conclusion Southam Northeast is singled out as the best performing Broad Location without further explanation. This error should be remedied in the next iteration of the SA. With regard to SA Objective 11: Accessibility, HLM acknowledge that connectivity of Southam Southeast would benefit from enhancement through investment in infrastructure and safe pedestrian/cycle crossings of the A423. HLM have submitted with these representations a Wider Connectivity Plan to demonstrate how it would improve and enable connections to the existing built-up area. These include links to the existing underpass under the A423 to the north, a new controlled toucan crossing of the A423 at grade connecting into Stowe Drive, links to the existing signalised crossing point adjacent to the junction of the A423 and A425, and proposed links across Banbury Road. We consider that insufficient account has been taken of accessibility issues elsewhere in Southam, for example school congestion concerns at Southam Northwest and Southam Southeast being effectively cut off from the main settlement because of HS2; this is should rectified in the next iteration of the SA. Given Southam Southeast is free from such accessibility issues, and considering the accessibility enhancements described above, HLM argue that Southam Southeast is the best performing Broad Location when assessed against SA Objective 11. With regard to SA Objective 12: Education, the SA summary suggests that Southam Northeast is the best performing Broad Location in Southam on the basis of having the largest proportion of land within 800m of an existing primary school. However, any strategic development of this scale will include on-site provision of primary education facilities. Therefore at the very least, the Broad Locations should be considered to perform equally in relation to this SA Objective. Southam Southeast also has advantage in education terms due to the willingness of HLM to accommodate a new sixth form centre within this area (as described within the Education Technical Note). This new facility would relieve pressure on the Southam College site, remove traffic generated by sixth form students from Welsh Road West, and improve facilities for students and staff. The new sixth form centre is proposed to form part of a wider Education hub which is to include a primary school, supporting the combination of administration and other facilities which will reduce running costs. As such, it is contended that Southam Southeast performs strongest in relation to Education and this should be reflected in the SA. Taking all of the above into account, it is clear that Southam Southeast does in fact perform best when assessed against the SA Objectives. Southam Southeast performs strongest compared to other Southam Broad Locations and this should be recognised in the next iteration of the SA.
selected
selected
selected
The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF. The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, HLM consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF. In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan, in particular as development proposals will need to show at least a 10% Biodiversity Net Gain from November 2023. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF.
No answer given
The following comments are made in respect of HLM’s site, which is referenced as Area 4 within the Southam Area. In respect of Connectivity, it is noted reference is made to the A423 as a barrier to the western edge. This is acknowledged however there are several points at which crossings can be safely made for pedestrians and cyclists. Firstly, the existing underpass which serves the Flying Fields development to the north of Area 4. This underpass provides a safe, secure, and direct route for pedestrians and cyclists into the town centre from Welsh Road East. The HLM site can access the underpass via Welsh Road East. Secondly, there is an existing public right of way for pedestrians that runs through the middle of Area 4 before crossing the A423 at grade and then connecting onto Stowe Drive and then along residential streets towards the town centre. This route can be improved through the provision of a controlled toucan crossing. Thirdly, there is an existing bridleway that runs through Area 4 and connects to an existing traffic light controlled pedestrian crossing adjacent to the junction with the A425. This route provides a safe and direct route to the Banbury Road and Sustrans National Cycle Route 48 which connects to the town centre and employment areas. Finally, there is the ability to connect with and across Banbury Road to the south of the A423/A425 junction to provide an alternative means of accessing the town from the southern end of Area 4. It is therefore considered that active and sustainable modes of travel from Area 4 to the town can be made across the A423 at four separate crossing points, and that connectivity is not a barrier that would prevent the area from being a strategic allocation. Further, enhanced connectivity between Southam Southeast and the main town will benefit existing residents east of the A423. In respect of Landforms, it is noted there are no physical constraints on Area 4. It is also noted that Area 4 has all local facilities within 800m. When taking account of this evidence, the comments above in relation to connectivity, and the evidence of the SA, it is clear that Area 4 performs best. This area is the most suitable location to accommodate a broad location of up to 2,000 dwellings, as it is the least environmentally constrained and yet the most accessible to the town and its facilities.
More generally, Southam was identified in the Sustainability Appraisal to the adopted Core Strategy as the most appropriate location for additional strategic growth amongst the Main Rural Centres based on the availability of suitable sites, lack of overriding infrastructure constraints, and the opportunity to support the existing facilities provided in the town. To deny any further growth of Southam in the SWLP to 2050, would not be consistent with the adopted Core Strategy or provisions of the NPPF. HLM have set out a Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions and be more climate responsive. This Vision can sit within and inform a wider Vision for the area, and HLM would be happy to meet to discuss this further with the Councils.
selected
selected
selected
selected
Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, HLM reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by HLM, whilst HLM support the housing need figures for South Warwickshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. On economic growth, whilst HLM agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons: - The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK; - CE are a robust source of job forecasts but a more recent forecast should be used; - Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics; - The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA; - Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period; - It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of; - The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. HLM also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness, which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, HLM consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
