Issue and Options 2023

Land at Station Lane, Kingswood, as identified in the attached Site Location Plan, is being promoted by MacMic Group to the SWLP. The site was submitted to the Call for Sites exercise in June 2021 and has subsequently been identified as Site 169 on the Interactive Map. Kingswood is identified as a Growth Village in the adopted Warwick Local Plan. Kingswood has a range of local facilities, including a Primary School, surgery, public house, convenience store, post office, garage, community and sporting facilities. Indeed Kingswood was joint third highest in the Village Settlement Hierarchy Report with a score of 53, and had the highest total score of 64 in the subsequent revised report (V18PM). Kingswood also benefits from Lapworth Railway Station with direct connections to Birmingham, Leamington, London, Solihull, Stratford & Warwick, along with bus provision. Development in Kingswood will assist with sustaining the important facility, which had 84,716 passengers in 2019-20 . Kingswood is also accessible by a good highway network and is located within easy reach of the M42 and M40. Kingswood lies 2 miles (3km) south of Dorridge, 6 miles (10km) south of Solihull and 10 miles (16km) to the north west of Warwick. It is centrally located to other larger settlements such as Birmingham, Coventry, Redditch and Leamington Spa, which offer opportunities for employment, travel and education. Kingswood had an indicative apportionment of 95 dwellings during the previous Local Plan process but only 48 dwellings are allocated in the Local Plan, reflecting the availability of land deemed suitable and available at the time. Therefore, there has been an under provision in the village in the adopted Local Plan, which is likely increasing unmet local needs for housing including affordable housing. Kingswood has a strong functional relationship with the Greater Birmingham Housing Market Area, and growth here would be best placed to contribute towards unmet needs. Whilst Land at Station Lane, Kingswood is currently within the Green Belt, it is in a sustainable location and there are no options for further growth within Kingswood without amendments to the Green Belt boundaries. The NPPF is clear that where Green Belt release is necessary, first consideration should be given to locations that are well-served by public transport . The sustainable effects of attempting to allocate all development outside of the Green Belt, the lack of availability of non-Green Belt land, and the substantial housing need across the Plan area are the initial steps necessary to demonstrate exceptional circumstances in this case. A new permanent Green Belt boundary could be established along the edge of the development. The Site sits within parcel KG2 of the Joint Green Belt Study and performed relatively low to elsewhere, scoring 10/20. In particular the study notes that KG2 has strong boundaries: “The Grand Union Canal represents the eastern border of the parcel. The canal sits close to the existing urban edge of the village and therefore represents a significant boundary preventing encroachment of the wider countryside to the east of the parcel.” Submitted with these representations is a Landscape and Green Belt Study specifically for the Site, which confirms that it makes a limited contribution to the purposes of the Green Belt, and its removal would not undermine the fundamental aims of Green Belt in the wider area. A Concept Masterplan for the Site has been prepared; this details how Land at Station Lane, Kingswood responds to the opportunities and constraints and could deliver circa 125 dwellings, incorporating significant green infrastructure to retain the Site’s landscape character and historic environment setting. This is supported by a Vision Document which provides further detail on the context of the Site and how the emerging proposals respond to this, including the economic, social and environmental benefits to the local community. A suite of technical evidence base work has been prepared in support of the emerging proposals at Station Lane, Kingswood. This includes a Highways Technical Note which concludes that access to the Site can be achieved from Station Lane and that there is scope for the provision of a new footway link to the existing footway network to the south, finding that development can be brought forward without resulting in a significant impact on highway safety or the operation of the surrounding highway network. A Flood Risk and Drainage Scoping Study identifies areas at risk of flooding and realistic on site drainage requirements. The Landscape and Green Belt report considers how development of the Site can be developed whilst respecting the wider Arden landscape character, and will be limited in Green Belt impacts. A Preliminary Ecological Appraisal has assessed the Site’s habitat value and informed the Initial Concept masterplan, in order to ensure biodiversity is protected and enhanced. A Tree Survey has also been commissioned which demonstrates how the majority of trees can be retained in the creation of an access, with replacement trees able to be planted where there is a loss. Overall, there are no technical impediments or environmental characteristics that could not be addressed through sensitive masterplanning, to deliver a high-quality proposal in this location.

Kingswood is identified in the SA as one of 22 Small Settlement Locations (SSLs), considered for intermediate scale, primarily residential development for between 50 and 500 dwellings. Land at Station Lane, Kingswood falls partly within one of the potential SSLs on the outskirts of the settlement. A summary of the findings of the SA assessment of the SSLs is provided at Table 5.1 of the SA. It is clear that all SSL perform differently in different areas, with no one option standing out as the best performing option across all areas. Having said that, it is recognised that Kingswood is one only five SSLs which performs strongly against SA Objective 11: Accessibility reflecting the settlement’s public transport offer. It is noted and considered important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. The findings of the SA are important to guide decision making, but other matters such as the availability of land which meets the NPPF definition of Developable and the suitability of sites when considering the range of opportunities and constraints is most important.

The Heritage and Settlement Sensitivity Assessment details the range of historic environment assets in Kingswood and the ability for additional development to be brought forward in the settlement taking into account potential impacts. The Assessment finds that land to east of Kingswood has potential for development, with the historic environment limited to two Listed Buildings (both Grade II) and Conservation Area. The Concept Masterplan and Vision Document for Land at Station Lane, Kingswood detail how suitable consideration has been afforded to these historic assets. It is clear that further growth to the south of Kingswood is unlikely to be able to be accommodated without significantly impacting the local historic environment, including the Conservation Area and a series of Listed Buildings. Concerns are also raised with development potential of the west of Kingswood recognising the Listed Buildings (including Grade I Listed Packwood House) and Registered Park and Garden. Land to the north of Kingswood performs well in historic environment terms, however development to the north of Rising Lane would not be proximal to any of Kingswood’s local services and facilities and would extend the built form of the settlement contrary to the existing pattern of the settlement. This is also likely to be challenging for a Green Belt release perspective, with no strong identifiable boundaries. As such, whilst development of land north of Kingswood may be most preferable from a historic environment perspective, other factors suggest this location is not suitable for further growth of the settlement.

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3. Yes, MacMic Group consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities and MacMic Group consider it would be more appropriate to reference meeting unmet needs from the wider Housing Market Areas. 4. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Greater Birmingham and Black Country Housing Market Area with a strong interrelationship and connectivity, and therefore should not be excluded.

5. 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 NPPF1 6. 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. 7. On the basis of the above, MacMic Group consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period, in accordance with the HEDNA and should therefore represent the minimum housing requirement for the SWLP. 8. In relation to capacity, the UCS considers housing supply, including sites with planning permission and outstanding allocations without planning permission across South Warwickshire, and other sources of potential supply within the urban areas. As the UCS assumes a Plan period from 2025, it is only sites with planning permission and outstanding allocations without planning permission which are scheduled to deliver in the period from 2025 onwards in the respective Housing Trajectories (at April 2021) which are included within the supply. Given MacMic Group consider a more appropriate Plan period commencement date is 2022, and given the respective April 2022 Housing Trajectories are now available, 20,695 dwellings is considered the accurate figure to be incorporated (on account of taking into consideration an additional three years of supply). The UCS incorporates a non-implementation deduction to be applied to site with planning permission at 5%, which is considered appropriate. 9. With regard to outstanding allocations without planning permission across South Warwickshire, a comprehensive review is required to ensure that such sites meet the definition of Developable as set out in the NPPF2. One such outstanding allocation which requires review is Long Marston Airfield which is allocated in the adopted Stratford-on-Avon Core Strategy (July 2016) for circa 3,500 dwellings (2,100 in the Plan period to 2031) and associated development. There are known issues with the delivery of the south-western relief road required to support the delivery of the new settlement at Long Marston Airfield, which combined with other infrastructure requirements is likely to be mean there is a significant lead-in time before development commences. 10. The UCS seeks to increase the level of supply on four outstanding allocations without planning permission in Warwick District at Kenilworth and Whitnash by 323 dwellings, however this is considered to be questionable. There is the potential for these outstanding allocations without planning permission to come forward delivering a higher number of dwellings than is set out in the adopted Warwick Local Plan (September 2017). However, until such a time as planning permission is granted, there is insufficient certainty to make assumptions around level of delivery. In addition, it is noted that the Warwick Housing Trajectory (at April 2022) already incorporates increases in projected delivery on some outstanding allocations without planning permission, and thus this could constitute double counting. 11. The UCS also seeks to include 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. It is noted that, to date, no formal assessment of these Call for Sites submissions has taken place in the emerging Housing and Economic Land Availability Assessment (HELAA). As such, the inclusion of these sites as potential supply in the UCS is unjust and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP. 12. Further, the UCS identifies an additional five sites on vacant land in the urban areas across South Warwickshire which have not yet been submitted to the Call for Sites process, but are considered potentially suitable in the UCS for 328 dwellings. Clearly there is insufficient certainty around the availability and deliverability of these sites which brings into question their potential for residential development. Further, on assessment of these sites there are some serious concerns around the suitability of these sites in any case. One example is Jephson’s Farm which is located north of the railway and Griffin Road in Leamington Spa, and is identified in the UCS as potentially suitable with a capacity of 171 dwellings. This land forms one of the last remaining gaps between Leamington Spa and Warwick so development is unlikely to be desirable, and further the site is highly constrained by flood risk and access limitations. As such, these five sites should be removed from the potential supply in the UCS as no evidence of their availability or deliverability has been provided. 13. 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, but are considered potentially suitable in the UCS, again raising concerns around availability and deliverability. Talisman Square is subject to a current planning application for 44 dwellings on a larger site than identified in the UCS, but Westgate House has no planning history. As such, the inclusion of these two sites as potential supply in the UCS is unjust, and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP 14. Finally, the UCS considers the level of windfall allowance to be included in the supply in the SWLP. An assessment is provided showing level of windfall allowance in the respective adopted Local Plans and 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 likely sources/types of windfall supply (based on past trends) nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is considered likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF3. 1 Paragraph 119 of the National Planning Policy Framework (July 2021) 2 Glossary of the National Planning Policy Framework (July 2021) 3 Paragraph 71 of the National Planning Policy Framework (July 2021)

Yes

17. The SWLP Issues and Options consultation evidence base includes a Settlement Analysis which reviews existing settlement structures across South Warwickshire with a view to guiding future development, assessing connectivity, landforms, accessibility to local facilities and density. 18. Kingswood is broken up into 12 Areas, with MacMic Group’s interest at Land at Station Lane, Kingswood forming a large proportion of Area 7. The assessment of Area 7 in the Settlement Analysis with associated commentary is provided below. 19. Connectivity – Area 7 is graded B in recognition of its accessibility to key routes in the settlement, including Station Lane and the canal towpath. Area 7 is one of only four Areas in Kingswood graded B on connectivity, with the remainder achieving C, D or E. 20. Landforms – Area 7 is clear of any constraints aside from Flood Zones 2 and 3 on the eastern boundary of the site, which can be appropriately avoided and indeed enhanced in bringing forward residential development on Land at Station Lane, Kingswood. 21. Local Facilities – Area 7 scores 2 out of 5 with regard to accessibility to local facilities, being within 800m of categories: Places to Meet and Education. In terms of Retail, Jobs and Economy, it is recognised that Area 7 falls outside the 800m limit, however this is marginal with the convenience store, post office and other retail and employment generating uses falling around 850-900m of Area 7 and thus still considered generally accessible. With regard to Open Space, Leisure, Recreation – Wellbeing, the Concept Masterplan demonstrates how significant green infrastructure provision and associated access to the canal towpath is to be incorporated into the development. On Healthcare, it is recognised that Area 7 falls outside the 800m limit, however again this is marginal with the surgery falling within 1km and thus still considered generally accessible. Connections with local facilities are supported in the emerging Concept Masterplan through maximising existing links and providing additional accessibility where appropriate. 22. Density – Kingswood is covered entirely by residential development classified as ‘Outer Suburb (approx. 20-40 dph)’. This has been taken account of in the emerging Concept Masterplan for Land at Station Lane, Kingswood, with residential development proposed at an average of 36 dph. 23. In conclusion, Area 7 performs well in the Settlement Analysis for Kingswood, particularly with regard to Connectivity and Landforms. With regard to access to Local Facilities, whilst some of these fall outside of the 800m threshold, this is marginal and generally the range of facilities on offer in Kingswood are considered to be accessible. This will be supported through significant green infrastructure provision on Land at Station Lane, Kingswood, along with improved connectivity from the Site. The density mapping has been considered and is reflected in the Concept Masterplan for Land at Station Lane, Kingswood with residential development proposed at an average of 36 dph. MacMic Group consider that more weight should be afforded to accessibility to rail in the Settlement Analysis and indeed wider consideration of the development strategy and site selection.

Q-S4.1 Growth of Existing Settlements 15. Yes, growth of existing settlements in South Warwickshire is considered to be imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. Further, growth of existing settlements will support the sustainability and vitality of existing services, providing support to existing communities, which in turn has the potential to enhance placemaking and sustainability. 16. Whilst the potential for new settlements in South Warwickshire is recognised, they will not ensure delivery of growth in the early part of the Plan period or sustain and enhance the vitality and sustainability of existing settlements. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages; those needs cannot be directly met sustainably in isolated settlements.

No

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No answer given

Q-5.2 The Potential for New Settlements 24. No, MacMic Group are of the view that new settlements should not form part of the strategy for dealing with South Warwickshire’s development growth needs, due to concerns regarding lead-in terms, infrastructure requirements, viability and market attractiveness. However, the expansion of existing settlements where there are opportunities to capitalise on existing benefits that new settlements are striving for should be considered. This would need to be supported by the allocation of sites which are deliverable in the short-term in sustainable locations, such as adjacent to Kingswood. This will help maintain and enhance the vitality and sustainability of existing settlements and deliver the need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure within the towns and villages where such needs exist. 25. With regard to the potential new settlement C1 south of Kingswood, it is considered that this site is too close to Lapworth Railway Station to warrant growth of 6,000 dwellings to facilitate a new Railway Station. Whilst potential new settlement C1 could come forward and deliver significant infrastructure including a Primary School and Secondary School, MacMic Group consider that a standalone new settlement south of Kingswood would not maximise the significant benefit that the existing Lapworth Railway Station has to offer. 26. As such, MacMic Group consider that, should significant growth in this location be considered appropriate, the focus should be the existing settlement of Kingswood and a significant expansion of the village in order to maximise the offer of Lapworth Railway Station. This would allow the delivery of significant growth to meet the needs of South Warwickshire in a location well related to conurbation with unmet needs supported by the provision of significant new infrastructure, whilst maximising the potential and also sustaining the existing Lapworth Railway Station.

Issue S6 A Review of Green Belt Boundaries 27. MacMic Group strongly agree with the proposal to review Green Belt boundaries, in order to ensure that the most sustainable growth strategy in South Warwickshire can be achieved. To avoid Green Belt release in the SWLP would limit the potential for growth of a number of South Warwickshire’s more sustainable settlements, including Kingswood. 28. The SWLP should be supported by an up-to-date Green Belt Study which assesses individual land parcels and, in association with a development strategy which supports growth in the most sustainable locations including on the edge of sustainable settlements such as Kingswood, recommends removal of land currently within the Green Belt which least serves the five purposes of the Green Belt, and can define a defensible boundary.