Issue and Options 2023
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Results for A C Lloyd Homes search
New searchQ-V3.1 - Yes we agree with the overall vision to meet housing and economic development needs for South Warwickshire to 2050, including where appropriate and agreed, unmet needs from neighbouring authorities. Although we note that the HEDNA evidence base has been prepared up to 2050, we would question whether the Council should consider a longer period given that the NPPF advises that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead to at least 30 years. - Providing land for homes and jobs in the right places is critical to addressing housing shortfalls and economic needs, and ensuring South Warwickshire is an attractive and dynamic place to live and work. The principles are laudable and should wherever possible and feasible underpin the delivery of the vision. - We also generally agree that the strategic objectives are appropriate.
The one aspect of the Sustainability Appraisal we wish to comment on is the ‘Evaluation of Broad Locations at the Main Settlements and Small Settlement Locations’. This has identified 32 ‘Broad Locations’ around various main settlements and 22 ‘Small Settlement Locations’. Our concern is that there is a significant flaw with the approach being taken in that both the Broad Locations and Small Settlement Locations cover quite large areas. For example, the SA deals with all of the land around Small Settlements as one option. In many cases, this will result in failing to consider individual smaller parcels of land within such areas that may in fact be appropriate for development in isolation, or in combination with other parcels put forward for consideration for development, within the identified wider areas. Whilst we understand that this approach is a starting point, it is critical that this does not result in smaller parcels within the various Locations being omitted or discounted without due regard to the assessments and the full SHELAA process.
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In regard to Issue I3 relating to CIL, whilst we understand the logic of a South Warwickshire CIL, we do not have a fixed view at this stage. What is most important is that the required infrastructure is provided for developments at all scales, types and locations. The Council must also ensure that it adopts an approach which balances the deliverability of infrastructure and viability. We feel that CIL has not been equitable in its implementation to date so would raise concerns about it going forward although it depends very much on what and where development allocations are proposed. The current system results in smaller (non-strategic) residential development sites effectively being charged twice through both the levy and s106 agreements. In terms of the options going forwards, it is difficult to see how CIL could be agreed separately under a joint Local Plan and therefore a South Warwickshire approach seems sensible. However, it is critical that it includes different zones within the levy to take account of different market areas and the levels of growth and therefore the infrastructure needs within each area.
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It is considered that the urban capacity study it too optimistic in the number of dwellings to be located within existing urban areas. and is not supported by the historic evidence of windfall trends or the availability on the brownfield land register.
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Our main comment at this stage about the settlement analyses is that there appears to be inconsistencies in some of the analyses particularly relating to connectivity. Some of the analyses have far more subjective comments than others, which suggest a certain outcome/conclusion. Consistency of approach and objectivity is important.
We are not against the principle of new settlements but the history of most of those that have been delivered, are being delivered are yet to be delivered, shows that they require significant levels of upfront investment and take a long time to commence and be delivered. New settlements are normally only successful where there are a very small number of landowners and so issues with land assembly do not prevent sites being delivered. It is critical that if new settlements are going to be part of the strategy, they must be proven to be viable, deliverable, accessible and sustainable. We would only support the inclusion of a new settlement(s) as part of the preferred option if combined with the growth of existing settlements. Existing settlements are supported by existing infrastructure and are inherently more sustainable and can be delivered quicker than new settlements, thus securing the delivery of housing, jobs and infrastructure in the earlier stages of the Local Plan. If a new settlement is proposed it is critical that it is rail served.
