Issue and Options 2023

Yes

Nurton Developments (Loes Farm) Ltd supports that the growth of some of the existing settlements should be part of the overall strategy and supports in particular that Warwick is included in the list of settlements considered for development potential. However, it will be highlighted in representations in response to Q-S10 that, other than Warwick Parkway, Warwick has not been listed in any of the growth options as a settlement that would receive growth. We would submit that Warwick should be looked at as a whole settlement, not least because development to the west of the settlement, in the vicinity of Warwick Parkway, has been identified as harmful in the Heritage and Settlement Sensitivity Assessment. That assessment recommends that development to the west of Warwick should be avoided. Also, as will be discussed in our response to Q-S4.2, the area to the north of Warwick has the best connectivity (in terms of local facilities within 800m) and accessibility of any sector around Warwick, whereas the area to the west has the worst connectivity of any of the Broad Locations and development there would lead to a major adverse impact on transport. Nurton Developments (Loes Farm) Ltd both supports and objects to different elements of the settlement analysis in respect of Warwick and comments as follows on each element of the assessment. SOUTH WARWICKSHIRE SETTLEMENT ANALYSIS – JANUARY 2023 The Connectivity Analysis for Warwick North identifies that Sector 2 has fairly poor connectivity, since the access route along the Coventry Road is on a fairly steep incline, rising to a very steep incline. For some reason the access route along Woodloes Lane, where pedestrian access could be taken to connect to the residential area to the south, from an existing Public Right of Way, is not assessed in the Connectivity Analysis. If it were, then it would offer excellent connectivity. It is more likely that pedestrians would use this route for connections into Warwick than the access along Coventry Road, so the area north of Warwick, enclosed by the A46 and Coventry Road, could offer very good connectivity overall. The Connectivity Analysis should be amended to take this into account. It is noted that the assessment for Warwick North in terms of local facilities within 800m identifies Sector 2 as having the best connectivity. The only item not within 800 metres is ‘open space, leisure, recreation – wellbeing’. This is questionable because both the Canalside Recreation Area and Millbank Park are within 800 metres, but in any case we would highlight that proposals for Sector 2, as identified in the Loes Farm vision document submitted to the previous consultation, have proposed that the Historic Park & Garden designated area within this sector would deliver an extensive area of Public Open Space as a new country park.

Nurton Developments (Loes Farm) Ltd objects to the fact that, other than Warwick Parkway, Warwick has not been listed in any of the growth options as a settlement that would receive growth. This is an inappropriate strategy which fails to consider one of the main settlements of the area as a whole, in terms of its sustainability and potential for growth. Instead it just focuses on one side of the settlement. Warwick Parkway lies to the west of the settlement, in an area that has been identified as harmful in the Heritage and Settlement Sensitivity Assessment, and that assessment recommends that development in that area should be avoided. Therefore, alternative options to developing to the west of Warwick must be considered. The Sustainability Appraisal (SA) paragraph 4.16.33 identifies that Warwick as a settlement performs well against SA Objective 13, due to all Broad Locations having good access to employment opportunities. It finds that this would have a minor positive impact on the local economy as it is within the sustainable target distance to various business and employment opportunities. Therefore, Warwick should be considered as a whole to ensure that such positive impacts are maximised where possible. As discussed in our response to Q-S4.2, the area to the north of Warwick has the best connectivity (in terms of local facilities within 800m) and accessibility of any sector around Warwick. Conversely, the area to the west of Warwick has the worst connectivity of any of the Broad Locations and development there would lead to a major adverse impact on transport. Therefore, limiting the consideration of growth potential for Warwick to the area west of Warwick would fail to take advantage of the best connectivity and accessibility and would lead to unsustainable outcomes. While all opportunities and constraints must be looked at in the round, it is submitted that connectivity and accessibility should be given particular priority if the climate change emergency is to be addressed and 20-minute neighbourhood principles are to be pursued.

SUSTAINABILITY APPRAISAL OF THE SOUTH WARWICKSHIRE LOCAL PLAN REGULATION 18: ISSUES AND OPTIONS STAGE – NOVEMBER 2022 First and foremost, Nurton Developments (Loes Farm) Ltd objects to the geographical extent of the ‘Warwick Northwest’ Broad Location that has been selected for assessment. This includes a broad area outside the A46 boundary, divorced from the settlement, containing Grade II* and II listed buildings. Including this area outside the A46 boundary unfairly influences the assessment of what would be a much more appropriate location for development, inside the A46 boundary. Nurton Developments (Loes Farm) Ltd has promoted this location (Loes Farm) for development and made representations to the previous consultation and Call for Sites to support this. The representations were supported by Heritage Assessment and Landscape and Visual Assessment to demonstrate that a masterplan for up to 260 dwellings could accommodate development while taking into account site constraints and sensitivities. The Sustainability Appraisal (SA) confirms at paragraph 4.16.15 that a Heritage and Settlement Sensitivity Assessment has been undertaken which will provide further evidence to inform the appraisal of potential impacts on cultural heritage, but the assessment was not available for use at the time of undertaking the assessment of Broad Locations. Therefore, the SA has failed to consider important evidence in arriving at its conclusion that there would be a ‘Major Negative’ impact on the adjacent Guys Cliffe RPG. Please refer to our representations below where it is discussed that the Heritage and Settlement Sensitivity Assessment actually finds that there may be scope for development in this area. Furthermore, the inclusion of the area outside the A46 boundary and including Grade II* and II listed buildings leads to the conclusion that there would be a Major Negative impact on two other sustainability objectives, whereas if just the land within the A46 were considered then there would not. Paragraph 4.16.26 of the SA says that “only Warwick NW doesn’t meet the sustainable target distance for access to a GP Surgery”. However, this is not borne out in the technical appendix where at table B.31.10 it states that the Broad Location is within the target distance to a GP Surgery and a Minor Positive impact would be expected under this sustainability objective. In relation to SA Objective 11: Accessibility, it is noted that the Broad Location scores very well in terms of accessibility. It performs best out of any of the Broad Locations. This should be given significant weight in the selection of Broad Locations for development, since it has the greatest potential to address the climate change emergency through reducing car trips. At paragraph 4.16.30 of the SA it is concluded that only the Warwick Northwest Broad Location meets the target distance criteria for a local food shop. As such, this Broad Location has the potential to contribute to 20-minute neighbourhood principles. Conversely, in terms of the other Broad Locations, at paragraph 4.16.31 of the SA it is noted that connectivity is very poor in the Warwick West Broad Location predominantly ranking as Grade E, which will present a major adverse impact on transport for site end users. Therefore, although this location was ‘best’ in terms of some of the other sustainability objectives, a decision to locate development here could lead to some very unsustainable outcomes. Building on the very good accessibility of the Warwick Northwest Broad Location and limiting and impacts through the selection of an appropriate area for development, inside the A46 boundary, would therefore present a highly sustainable option that should be given further consideration.

Nothing chosen

HERITAGE AND SETTLEMENT SENSITIVITY ASSESSMENT FOR WARWICK AND STRATFORD-ON-AVON LOCAL PLAN (SWLP) – SEPTEMBER 2022 This assessment identifies the following heritage sensitivities within the ‘Warwick North’ area: “On the eastern side of the area beside the Avon is the Registered Park and Garden, Scheduled Monuments and Listed Buildings that make up Guy’s Cliffe. The site is already on the Heritage at Risk register and is vulnerable to further incremental damage to its historic fabric and surroundings. However, there may be scope for development within this area, subject to careful master-planning and appropriate mitigation of the designated assets”. We support the finding that there may be scope for development in this area, subject to careful master-planning and would highlight that we have already submitted a masterplan for 260 dwellings, supported by Heritage Assessment, to the previous consultation. In particular, given that the Guy’s Cliffe RPG is on the Heritage at Risk register, there would be scope for conservation and restoration of this historic landscape as a country park in association with the proposed development. Indeed, the assessment notes that opportunities should be sought to address the needs of Heritage at Risk sites in the ‘Potential Enhancement’ section of the document.