Issue and Options 2023
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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Richborough Estates consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Kenilworth given its rail and bus links.
The following comments are made in respect of the SA for Warwick. The site promoted by Richborough Estates forms part of Warwick West (Broad Location 32). In assessing the three Broad Locations (BL) identified against the SA Objectives, the SA concludes that parcels to the east and west of Warwick perform better overall. It should be noted that Warwick Northeast falls within the Green Belt and so should only be considered where all other reasonable options (such as Site 214, the part of Warwick West that falls outside of the Green Belt) have been fully examined. It also should be noted that the boundary of Warwick West can be extended to include land available to the north that falls between the racecourse and the A46 (as illustrated as site 214). This land to the north has a role in mitigating any adverse impacts arising from the SA, for example in relation to ecology, and so should be included within the next iteration of the SA. The following specific comments are made in relation to the SA and Warwick West. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. However, the conclusion that Warwick West performs best is agreed, particularly in respect of the part of the Broad Location that falls to the east of the A46 and thereby contained within the urban area. Reference is made to increased risk of coalescence with Hampton on the Hill to the west, although this would be avoided if development is limited to the eastern side of the A46. SA Objective 5: Cultural Heritage notes the potential negative impact of Warwick West on the setting of the Warwick Conservation Area. This is identified in the Heritage and Settlement Sensitivity Assessment, where it considers there is ‘little scope for development within the bypass without causing harm to the asset’ and accordingly the site is assessed as ‘red’. It is recommended to the Councils that this Broad Location is not dismissed on the basis of this evidence alone for the following reasons. Firstly, the Assessment itself acknowledges this is a ‘high level’ assessment undertaken without the benefit of a site visit. Richborough Estates have undertaken a more detailed assessment, including site visits, to arrive at an illustrative masterplan for the area within the bypass. This masterplan retains views across the area from St Mary’s Church and the town centre to the countryside beyond the A46, sets any development back from the Racecourse Conservation Area to ensure a sense of openness around the asset, and retains field patterns to the north of the site filtering any views of development from the Canal Conservation Area. These three components of any masterplan avoid harm to the setting of the assets. These components are illustrated within the Vision Document submitted with the call for sites form by Richborough Estates. Secondly, the Assessment appears to have incorrectly identified the area as ‘red’ and as it does not identify any potential major impacts within the report. Any major impacts could be avoided and so the area should not be classified as ‘red’. Richborough Estates fully acknowledge that this is a sensitive area in heritage terms, and that careful masterplanning is necessary to avoid or limit harm to the setting of the Conservation Area. This requires a more detailed assessment than the high level assessment undertaken, and Richborough Estates would be happy to work with the Councils in undertaking their more detailed assessment as part of the next iteration of the Plan. SA Objective 11: Accessibility concludes that Warwick Northwest is the best performing BL due to its connectivity score. Warwick West performs equally as well in the connectivity assessment within the Settlement Design Analysis, save for the Analysis has concluded that the land north of the existing racecourse straight within the bypass has the poorest connectivity (E). It is not clear from the text why this part of the area has been assessed differently to land to the south of the straight. Access to the land to the north can be provided around the racecourse straight as illustrated within the Vision Document submitted with the call for sites submission by Richborough Estates. This parcel of land therefore has the same connection to the town as the remainder of the broad location assessed as (D). Warwick West is therefore the equal best performing option, and the SA should be amended accordingly in the next iteration. Further comments are made on the Settlement Design Analysis under Q-S4.2. SA Objective 12: Education concludes Warwick Northeast is the best performing option, however this does not reflect the analysis in Appendix B which places them as equal with Warwick West. Moreover, Warwick West is within 1.5km of Aylesford School, Warwick and therefore within the target distance. Warwick West has therefore been incorrectly scored, and is therefore the best performing option and this should be amended in the next iteration of the SA. 18. Warwick West performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, what is evident from the SA is that where adverse impacts are identified they can be mitigated or avoided. 19. The key constraint to growth at Warwick is the A46 which is a strong barrier to the west. The most logical location to therefore extend Warwick is on land between the town and the A46, and to do this in a way that avoids and minimises any harm to the heritage assets. Richborough Estates have put forward proposals to the Council as to how Warwick West (within the bypass) could come forward in a comprehensive and sensitive manner, and we would request the Councils allocate site 214 for strategic development.
The following comments are made in respect of Richborough Estates site (reference 214), which is Areas 2 and 3 within the Warwick South area. In respect of Connectivity, the site has been assessed as (D) and (E). The land immediately adjacent to Hampton Road (Area 3) is assessed as (D), which is defined as having barriers which may be overcome but not easily. It is not clear from the supporting text what barrier exists to connectivity on Hampton Road, and access can be provided as illustrated in the Vision Document submitted with the call for sites form by Richborough Estates. Hampton Road is a multi-modal route within the urban area that provides for all forms of transport, and can be improved where necessary. Reference is made in the text to noise from the A46, areas of flood risk, and a slight incline. None of these factors impact on connectivity, and can be mitigated or avoided through careful masterplanning. This is demonstrated within the Vision Document submitted with the call for sites by Richborough Estates. It is requested Area 3 is re-assessed in the next iteration of this analysis, particularly as areas separated from the town by the River Avon (Area 1 in Warwick North) are considered to have better connectivity. Area 2 has been assessed as having the least potential for connectivity, and defined as having significant barriers which would be difficult to overcome. Again, it is not clear from the text what the barriers are to connectivity, or why this part of the area has been assessed differently to land to the south (Area 3). Access to Area 2 can be provided around the racecourse straight as illustrated within the Vision Document submitted with the call for sites submission by Richborough Estates. This parcel of land therefore has the same connection to the town as Area 3, and should be re-assessed in the same way. As above, reference to noise and flood risk are constraints that can be overcome through careful masterplanning. In relation to Connectivity, it is also worth remembering that one of the key benefits from the strategic allocation of this site is the ability to provide an active travel connection from the west of Warwick area, through the site and over the A46, and into Warwick Parkway Rail Station. This could provide a safe, direct, and convenient route for pedestrians, cyclists or e-bike users who are new residents or existing residents who live in Chase Meadow or the Shakespeare Estate. This would be a significant benefit, and assist the Council in seeking to achieve carbon reductions during the lifetime of the Plan. In respect of Landforms, it is noted there is reference to a slight incline on Area 3, but this is marginal and not a constraint on development. In respect of local facilities within 800m, it is noted that the report highlights the absence of retail/jobs/economy, healthcare, and education for Area 2. However, the area is within 800m of the Racecourse which is an employer in the area, and this should be recognised in the next iteration of the Analysis. The area is also only marginally just over 800m to the Chase Meadow Local Centre and Newburgh Primary School. It is noted that Area 3 has all facilities within 800m which shows how suitable this area for development given its proximity to facilities. When taking account of the evidence above, Areas 2 and 3 are a suitable location to accommodate a strategic allocation, as there are no barriers to connectivity to the town, and facilities are available within 800m.
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66. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Richborough Estates consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry and Birmingham’s unmet needs, this should include Warwick given its rail links.
Yes, growth of existing settlements in South Warwickshire is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the settlements.