Issue and Options 2023
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New search2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns.
Q-V3.1 and Q-3.2 3. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 4. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
5. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 6. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. There are other settlements, such as Stockton, which should be included on the list. 7. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 8. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 9. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 10. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
11. Viability is a critical issue and should not be underestimated, especially for new settlement proposals where the infrastructure required is both significant in scale and cost. However, it is not just infrastructure costs which affect viability but the increasing cost of construction whether caused by inflationary pressure or regulations. There are also costs associated with, for example, providing on-site Biodiversity Net Gain, not just monetary but also reducing the extent of built development which affects the value of the overall site. Further, there may be additional cost burdens for all development associated with policies which will be included in the Local Plan or there is an unreasonable expectation about the proportion of affordable homes provided as part of allocated housing schemes. 12. In addition, there is an increasing desire at national and local level to push the infrastructure cost burden onto the landowner to mitigate all impacts and for a proposal to make an ever greater contribution, in whatever form, to the wider community. Alongside any Planning Obligations (assuming this regime remains in its current form), there also is the payment of the Community Infrastructure Levy. All these costs, combined with capital gains tax being paid on land transactions (which may well increase), is increasingly raising a question with landowners about whether it is worthwhile for their land to be developed for much needed housing or employment rather than retain a long term income for the current use? 13. For clarity, through this response Richborough Estates recognises that a fair and reasonable contribution should be paid towards appropriate infrastructure, but the Councils equally need to recognise that there are increasingly significant cost burdens associated with the development of land, whether inside or outside the control of the Councils.
Q-S4.1 and Q4.2 19. As part of a sound spatial strategy there will inevitably be a need for growth to occur at existing settlements, including Smaller Settlement Locations and other settlements, which possess a range of local facilities and connectivity by sustainable/active modes of travel to other locations. Such settlements represent the most sustainable locations for growth. 20. Concerns about the settlement analysis and the SA have already been raised and are not repeated. However, it is worth noting that here is a balancing act required whereby some environmental concerns may need to be managed to deliver sustainable growth. Not everything needs to be fully protected provide suitable and appropriate mitigation is available. A finer scale settlement analysis is required than currently undertaken
Q-S2 15. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 16. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 17. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 18. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 21. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 22. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 23. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 24. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at other settlements because of the level of facilities and services available. 25. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Q-S8.1 33. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In is context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy, including Stockton. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans.
