Issue and Options 2023
Search form responses
Results for Mactaggart & Mickel search
New searchQ-B1: Please select the option which is most appropriate for South Warwickshire Option B1b: Remove Areas of Restraint designations 2.83. A disjointed approach between the two local authority areas should be avoided wherever possible. Of the options presented therefore, the Respondent would favour removal of existing areas of restraint, with open areas of land that serve to preserve the structure and character of settlements protected through more generic heritage and/or landscape policies. Q-B3: Please select the option which is most appropriate for South Warwickshire Option B3c: Discard Special Landscape Areas and bolster general landscape policy 2.84. A disjointed approach between the two local authority areas should be avoided wherever possible. Given that Special Landscape Areas are now a somewhat outdated concept the Respondent considers, in the interests of consistency across the plan area, that Special Landscape Areas should be discarded (rather than seek to establish such areas across the whole of South Warwickshire). Q-B4: Please select the option which is most appropriate for South Warwickshire Option B4a: Maintain the current policy approach, without the use of a buffer 2.85. Creating a buffer around the Cotswold AONB is superfluous to national planning policy that requires development within the setting of AONBs to be sensitively located and designed to avoid or minimise impacts. The Respondent therefore considers Option B4a, which seeks to maintain the current policy approach without use of a buffer to be sufficient in this case. Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these 2.86. Environmental Net Gain is an entirely new concept with no tried and tested approach to its delivery. It is therefore currently unknown how Environmental Net Gain would work in practice. The Respondent therefore reserves their right to make comment once more detailed information is available. SWLP Issues and Options Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? 2.87. No. Wildbelt is a highly aspirational concept with no statutory or national planning policy basis. Unlike other designations there is no tried and tested method for the identification or delivery of Wildbelt. It is therefore unclear upon what basis the Council would seek to justify such designations particularly in light of the absence of the Local Nature Recovery Strategy (LNRS), which is understood from the Consultation Document to be many years away. The Respondent therefore reserves their right to make comment once more detailed information is made available. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 2.88. No. Agricultural Land quality is only one of a number of factors that is taken into account when considering whether a site should be developed or not. While Paragraph 174b of the NPPF recognises the benefits of best and most versatile agricultural land this is expanded on in Footnote 58 on Page 50 of the NPPF which requires consideration of the issue only where ‘significant development’ of agricultural land is demonstrated to be necessary. In such instances, the Footnote considers that poorer quality land should be ‘preferred’ to that of a higher quality. However, this does not mean that it is mandatory to avoid the development of best and most versatile agricultural land. It is therefore highly inadvisable to promote a policy that looks to avoid the development of or seeks the retention of best agricultural land as suggested.
2.90. No. The Respondent has significant concerns regarding the preparation of a two-part plan. The Respondent’s main concern with regards to a two-tier system is the inevitable delay in plan-making that will occur as result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. 2.91. The current two-tier approach in Stratford-on-Avon District Council is a prime example of where significant delays in the preparation of second tier policy documents have occurred. In proposing a two-tier SWLP, the authorities are in danger of repeating the same mistakes of the Stratford on Avon Local Plan and putting in place a Plan that will genuinely not be reviewed every five years as required by national guidance. 2.92. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect any updated evidence needs. This is a particular concern given the projected end date of the plan. 2.93. While it is noted that the intention is to “allow for a flexible, robust and long-lasting framework” this can be difficult to achieve in practice and will need to be given very careful consideration when policies are drafted. 2.94. The South Worcestershire Development Plan has demonstrated that it is entirely possible for authorities to work together to produce a complex development plan covering all aspects of managing growth across three or four LPAs without recourse to a divisive and time-consuming two-tier approach. 2.95. On this basis, it is considered that a comprehensive local plan should be prepared that includes a full complement of allocations and development management policies; with Area Action Plans, Neighbourhood Plans, Design Codes and Design Briefs/Masterplans prepared in a timely, albeit subsequent, timeframe.
3.0 Land off Station Road, Bishop’s Itchington 3.1. This Section of the Statement seeks to promote land at Bishop’s Itchington, which the Respondent can confirm is under the unified control of Mactaggart and Mickel (Mac Mic Group) and is available for residential development. The Site 3.2. The Respondent’s site at Bishop’s Itchington is situated on the western edge of the village. The village contains a good range of facilities and services, all of which are within walking distance of the site. Such facilities include a Primary School, Convenience Stores, Doctors Surgery, Community Centres, a Takeaway, Pub and Church. 3.3. The Site itself comprises two agricultural fields totaling approximately 18.6 hectares (ha). The fields are enclosed by hedges and divided by a mature hedgerow running broadly north- west to south-east. The landform is generally flat with the highest area, approx. 125m above Ordnance Datum (aOD). Constraints & Opportunities 3.4. The village is relatively unconstrained in so far as it is not subject to any local or national designations (i.e., Green Belt, Special Landscape Area, AONB). 3.5. A comprehensive summary of the site’s constraints and opportunities is set out in the accompanying Vision Document which demonstrates that the site is free from technical impediment and is therefore capable of being delivered for housing early in the SWLP plan period. The Respondent also has adequate control of land to bring forward a comprehensive green infrastructure strategy and provide at least 10% Biodiversity Net Gain. Case for Additional Housing Development at Bishop’s Itchington 3.6. Bishop’s Itchington is defined as a Local Service Village under Policy CS15 of the adopted Stratford-on-Avon Core Strategy. In the context of the current Development Plan for Stratford-on-Avon the village is therefore considered to be a sustainable location for new housing development in principle. 3.7. It is noted that under Policy CS15 Bishop’s Itchington was identified as being a suitable location for approximately 112 dwellings across the plan period 2011-2031 (20 years) although significantly more has been permitted/delivered in the period since 2011 (see response to Q-S8.1). 3.8. Turning to the accessibility of the village, the now made Bishop’s Itchington Neighbourhood Plan (February 2023) states that: “The nearby conurbations of Warwick, Leamington Spa and Coventry are within easy reach for employment opportunities but, since the building of the M40 motorway in the early 1990s and the opening of Warwick Parkway station, there have been further changes to the nature of the village. Easy access to the motorway and rail networks makes the village attractive to commuters working further afield. Aston Martin Lagonda and Jaguar Land Rover operations at the former RAF Gaydon site have further increased the appeal of Bishop’s Itchington as a place to live.” (BINPD, Paragraph 5.5) 3.9. Bearing in mind the accessibility of the village and the magnitude of the housing need to 2050 it is considered that (despite the current Consultation Document identifying Bishop’s Itchington as a potential location for growth under Option 5 only) that the village could reasonably be included under any of the growth options as a potential location for new housing development. However, it is the Respondent’s fundamental position that the development of additional housing land at the village would be commensurate with the guidance in Paragraph 79 of the NPPF in terms of supporting the vitality of rural communities. The Vision for the Site 3.10. It is proposed that land off Station Road is brought forward on a comprehensive basis, although it is equally recognised that not all of the site needs to be developed. 3.11. The Vision Document that accompanies these representations, while it illustrates only one way in which the site could be developed, demonstrates that development off Station Road would be seen as a logical extension of the village. 3.12. Through comprehensive analysis of the contextual, planning and technical parameters it provides evidence that the site is an appropriate location for development, is available now and can deliver new homes within the next plan period without any technical impediment. 3.13. The document also demonstrates that while the site represents development moving further westwards and beyond the proposed BUAB, that through appropriate masterplanning and the use of peripheral boundary planting and landscaping, development could be accommodated in this location without compromising the settlement’s form or character, unlike other sites that are being promoted which seek to extend the village in linear form away from its general nucleated settlement pattern. Conclusion 3.14. It is clear from the accompanying Vision Document that the Respondent’s site at Bishop’s Itchington is not subject to any major constraints. The site’s unified control by a trusted and experienced land promotion company (Mactaggart and Mickel) and its non-dependence upon any major new strategic infrastructure means that the site is readily deliverable. 3.15. For the reasons explained above, it is the Respondent’s belief that the site is the superior option for the accommodation of new homes at the village and accordingly should be allocated for housing development for circa 200 new homes to assist in meeting the housing requirements of the SWLP in a positive and effective way in accordance with both Paragraph 79 of the NPPF and the tests of soundness set out under Paragraph 35 of the NPPF.
Q-P1.2: No. The Respondent has significant concerns regarding the preparation of a two-part plan. The Respondent’s main concern with regards to a two-tier system is the inevitable delay in plan-making that will occur as result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. The current two-tier approach in Stratford-on-Avon District Council is a prime example of where significant delays in the preparation of second tier policy documents have occurred. In proposing a two-tier SWLP, the authorities are in danger of repeating the same mistakes of the Stratford on Avon Local Plan and putting in place a Plan that will genuinely not be reviewed every five years as required by national guidance. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect any updated evidence needs. This is a particular concern given the projected end date of the plan. While it is noted that the intention is to “allow for a flexible, robust and long-lasting framework” this can be difficult to achieve in practice and will need to be given very careful consideration when policies are drafted. The South Worcestershire Development Plan has demonstrated that it is entirely possible for authorities to work together to produce a complex development plan covering all aspects of managing growth across three or four LPAs without recourse to a divisive and time-consuming two-tier approach. On this basis, it is considered that a comprehensive local plan should be prepared that includes a full complement of allocations and development management policies; with Area Action Plans, Neighbourhood Plans, Design Codes and Design Briefs/Masterplans prepared in a timely, albeit subsequent, timeframe. General comments: Section 1.3 of the Consultation Document confirms that the SWLP will become the Local Plan for both Stratford-on-Avon District Council and Warwick District Council up to 2050. Paragraph 22 of the National Planning Policy Framework (NPPF) requires that all strategic policies should have a minimum timeframe of 15 years from point of adoption. While the SWLP is compliant with Paragraph 22 there is concern that a plan period to 2050 may be too ambitious in so far as it may be difficult for the plan to adapt to change. A further concern is that in establishing a 25-year plan period, the SWLP will make decisions that are so long term that it could compromise meeting the development needs of the area. By way of example, the SWLP could allocate a site which would genuinely take 20 years to deliver as a key part of its development strategy and given the magnitude of such sites could lead to smaller sites, in deliverable locations, not coming forward to meet housing needs in the intervening period. Section 1.4 of the Consultation Document confirms that it remains the Council’s intention to prepare a two-part plan. The Respondent’s main concern regarding a two-tier system is the inevitable delay in plan-making that will occur as a result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans, there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect updated evidence needs. This is a particular concern given the projected end date of the plan being some 25 years hence. The suggested timetable for the SWLP’s preparation is also considered to be highly ambitious. Given that most Local Plans take more than a year to be Examined by the Secretary of State it is considered very unlikely that Part 1 will be adopted before 2027 and potentially beyond if there is slippage between the public consultation stages indicated in Figure 2 (Page 16) of the Consultation Document.
The Respondent is in general agreement with the vision and strategic objectives set out in the Consultation Document but considers that the delivery of market and affordable housing to meet housing needs, including unmet need arising from neighbouring authorities, should be given greater emphasis in the Council’s Vision for the Local Plan (V1). The respondent would suggest the following amendment: “The vision is to meet South Warwickshire’s sustainable development needs to 2050, including new market and affordable homes, while responding to the climate emergency. Where appropriate and agreed, this should include unmet need from neighbouring authorities. The plan will provide homes and jobs, to boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time. Five overarching principles will determine how this development is delivered:” With regards to V3: Strategic Objectives, the role that all current settlements can play in meeting housing needs should be recognised. Furthermore, in recognition that it may not be possible to fully off-set carbon emissions in all cases (see comments made later in this Statement), the Council should consider updating the strategic objective of “Contributing towards Net Zero Carbon targets” to refer to “Minimising net carbon emissions arising from new development as far as practicable” (or similar).
Q-I2: The Respondent considers Option I2a as being most appropriate to ensure a consistent approach across the plan area and avoid disconnect between the SWLP and current extant Local Plan policies. While the Respondent would not object to the utilisation of a combination of S106 Planning Obligations and Community Infrastructure Levy (CIL) as per the current system, any policy must reflect the provisions of the CIL Regulations 2010 (as amended) and particularly Regulation 122, which requires S106 obligations to be fairly and reasonable related in scale and kind to development. Q-I3: The Respondent considers that a single CIL for the whole of South Warwickshire is most appropriate since it will provide greater certainty to developers. While the Consultation Document indicates that separate levies could better respond to different conditions in different areas of South Warwickshire (i.e., the Stratford-on-Avon and Warwick Districts), in the Respondent’s view, this can equally be achieved through the implementation of different charging zones where these are justified. The Consultation Document confirms that an Infrastructure Delivery Strategy (IDS) will be prepared which will set out the key pieces of new infrastructure needed to deliver the Councils’ growth strategy and how such infrastructure will be delivered. The Respondent is supportive of this action and considers the preparation of an IDS to be an essential component of the evidence base. Q-I5: Completion of a robust and comprehensive Plan Viability Assessment will be essential to ensure that the SWLP is viable and deliverable in a timely manner. The Respondent considers that both an IDS and Viability Assessment should be prepared at an early stage and used to inform a preferred strategy. Any such documents should be made available for comment as part of the Preferred Options Public Consultation.
Yes. The Respondent considers it sensible to include a policy that safeguards land that will facilitate the delivery of key infrastructure projects where this is justified. The Respondent recognises that safeguarding would be difficult to achieve post adoption of the SWLP and is best considered at an early stage of the plan preparation process to ensure that the growth strategy is capable of being delivered.
