Issue and Options 2023
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New searchThe Vision for South Warwickshire includes five overarching principles which will determine how development will be delivered. The CEG and Mixed Farms proposals for South East Stratford-upon-Avon are considered against each of these principles to demonstrate how the site can contribute to achieving the Vision: • A climate resilient and Net Zero Carbon South Warwickshire – The proposed development at the site will contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking advantage of two key attributes, size (strategic growth) and location (on the edge of one of the most sustainable settlements in South Warwickshire), the site off Banbury Road will include numerous measures and strategies to encourage local living and support the initiative of 20-minute neighbourhoods. • A well-designed and beautiful South Warwickshire – Development at the site will provide for a mix of housing types and tenures to encourage diverse and intergenerational communities; it will deliver both physical and social infrastructure to benefit existing and future residents and support the growth of the town as a whole; create beautiful homes with gardens that combine the best of town and country to create healthy communities; and retain and enhance existing landscape features including hedgerows and tree belts . • A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable garden community, providing both a range of housing to meet identified needs, and community facilities, focused around a mixed use centre with primary school, convenience and community facilities, mobility hub and potential for live/work community hubs supporting both the development and surrounding villages. This will be set within a substantial green infrastructure network. • A well-connected South Warwickshire - The site will take advantage of the excellent existing facilities for travel choice into Stratford-upon-Avon by active travel and public transport modes and enhance these routes where needed through careful design and investment in sustainable infrastructure which will promote longevity. This means that the site can place walking and cycling at the highest priority, followed by travel by public transport, and develop a community where there is “little” reliance on the private car. • A biodiverse and environmentally resilient South Warwickshire – Biodiversity net gain will be taken fully into account in the proposals for the site. The conceptual framework for the site will retain existing landscape features including hedgerows and tree belts and, in addition, shows a considerable biodiversity parkland, public parkland, and a network of swales
Issue I1: Sustainability Appraisal 3.1 CEG and Mixed Farms have reviewed the SA and welcome its findings with regards to the consideration of the growth options around Stratford-upon-Avon. Five growth locations were considered, and, of these, Stratford-uponAvon East scored was the best performing, scoring the outright best on 4 out of 13 objectives and scoring broadly comparable or the same on the remaining 9 objectives. Furthermore, when the broad location of Stratford-uponAvon East is considered against all other broad locations, Table 4.1 of the SA would suggest that this location is one of best rated across the all the options in the Plan as a whole. It is noted that Stratford-upon Avon South benefits from a positive assessment overall with the SA albeit slightly worse than Stratford-upon-Avon East due to potential landscape impacts. We do not consider that such impacts would apply to land controlled by CEG and Mixed Farms to the north of Banbury Road for the reasons outlined below. 3.2 We would provide the following additional observations. 3.3 The positioning of boundaries that have used to define broad areas within the SA is questioned as with specific regard to the Stratford-upon Avon East (B.25) and Stratford-upon-Avon South (B.28), the rationale for the dividing boundary between these two areas does not seem entirely logical. The result is that the boundary transects land ownerships – namely that of CEG and Mixed Farms – rather than following existing features, namely Banbury Road.It is worth noting that these locations are outlined in the SA Appendices as areas B.25 and B.28, but when they are shown on Figure 4.1 of the SA Main Report, they are listed as locations 24 and 27. 3.4 The boundaries considered in the SA may have limited impact when considering broad locations, particularly so if both the south and east options are taken forward as locations for development in the Local Plan. However, as well as the important role physical features have in defining brad locations, ownership boundaries should also be a consideration for any eventual allocation as this can impact on deliverability. 3.5 As mentioned earlier based on the findings of the SA, Stratford-upon-Avon East is the least constrained option around the settlement – a conclusion we agree with - and should this be taken forward without Stratford-uponAvon South, the boundary of the eastern parcel should be reviewed so that it follows the built form of Banbury Road and reflects land ownership. Importantly, we do not consider that adding land to the boundary with Banbury Road would adversely affect the overall SA scoring for Stratford-upon-Avon East as it does not exhibit any materially different characteristics or constraints (including landscape sensitivity) meaning it would remain one of, if not the, most sustainable broad location for growth in the Plan. Indeed, it is worth noting that the relevant part of Stratford-upon-Avon South is proposed as a reserve housing allocation in the Draft Stratford Site Allocations Plan (site ref. STR.D), thus demonstrating its suitability for development. The image below is taken from the SA Appendices and shows the Stratford-upon-Avon South boundary but also includes green hatching to demonstrate the area which should be excluded from this option and incorporated into Stratford-upon-Avon East. 3.6 CEG and Mixed Farms has also reviewed the SA Appendices which provides the detailed scoring and commentary of each broad location against the 13 SA Objectives and the individual criteria within each objective. At this stage, we do not seek to challenge the scoring that has been given as there appears to be consistency in the way that scoring has been applied across the broad locations at Stratford-upon-Avon. However, we would make the following comments with specific regard the Stratford-upon-Avon East. 3.7 As outlined above, Stratford-upon-Avon East scores positively and is one of the best options across the plan area as a whole, and the best performing in Stratford-upon-Avon. Nevertheless, it is considered that this scoring could be further improved upon at the next stages of consideration and assessment against a conceptual masterplan. It is evident that for the scoring under SA Objectives 3 (Biodiversity), 4 (Landscape), 5 (Cultural Heritage) and 6 (Pollution), where a minor negative impact has been identified, it has also been identified that mitigation is possible against these impacts through the detailed masterplanning of the layout, design and landscaping of a scheme. Against each of these criteria, the mitigation is rated as either ‘A’ meaning that impacts could be avoided, or ‘M’ where the level of impact could be reduced – a position we agree with. As such, these minor negative impacts could be reduced to negligible/neutral. Indeed, the Site Constraints and Opportunities Plan and Conceptual Framework provide by CEG and Mixed Farms at Appendix 2 demonstrates how such impacts could be mitigated against. 3.8 In reference to Stratford-upon-Avon South, it is evident that it also scores well overall against each of the SA Objectives, with the main difference between it and Stratford-upon-Avon East being the major negative for Landscape Sensitivity criterion under SA Objective 4. This is as a result of the western part of the broad location including an Area of Restraint landscape designation. However, this impact would not apply to the eastern part of the broad location to the north-east of Banbury Road. As outlined above, were the boundary between the southern and eastern broad locations to be amended to more logically reflect physical features, such Banbury Road, the inclusion of the parcel of land east of Banbury Road within Stratford-upon-Avon East rather than Stratford-uponAvon South, would not negatively impact on the scoring that Stratford-upon-Avon East currently receives.
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Paragraph 72 of the NPPF notes that 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. As part of a range of considerations, the NPPF also states that such policies should ensure that the size and location of such development will support a sustainable community, with sufficient access to services and employment opportunities within the development itself, or in larger towns to which there is good access. In the context of residential led urban extensions to existing sustainable settlements, these can offer clear sustainability benefits associated with being close to the existing built-up area and sufficient critical mass such that they can deliver on-site infrastructure and community facilities. Such sites can also deliver a substantial quantum of market and affordable homes in a range of sizes and types to respond to the needs of specific groups, plus extensive access to high quality green spaces and recreational areas, promoting health and well-being. Accordingly, such growth options present an excellent opportunity to limit the need to travel long distances and maximise the use of sustainable modes of travel. Stratford-upon-Avon, as the principal and most sustainable settlement in Stratford-upon-Avon District and one of five main towns across the Plan area, should be one of the settlements where growth is focussed, with the SA demonstrating certain growth options in this location are some of the best performing within the Plan as a whole.
The NPPF 2012 introduced a radical shift in relation to the approach to meeting housing needs. This remains in the 2021 version where at paragraph 8 it outlines the three overarching objectives to securing sustainable development and paragraph 8b states that to achieve the ‘social objective’ it is necessary to “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations…” Paragraph 60 of the NPPF then states that “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” However, despite the additional requirements and objectives imposed by the NPPF, it is widely accepted that there is a national housing crisis due to the consistent failure to achieve the Government’s target of 300,000 homes per annum, with affordability unsurprisingly worsening across many parts of the country, year on year. On 6 December 2022, Secretary of State Michael Gove announced the Government’s intentions via a Written Ministerial Statement (“WMS’”) to make fundamental changes to the planning system, which were then set out in a NPPF prospectus (“the prospectus”), published for consultation on 23 December 2022. On 8 December 2022, the Planning Inspectorate set out clear guidance (PINS NOTE 14/2022) which confirms that the WMS set out proposals for consultation only, rather than immediate changes to Government policy. It is therefore the case that in the interests of plan-making, the requirements of the existing NPPF (published July 2021) still apply. Given the above, these representations do not therefore focus on the content of the draft changes, but it is of note that the Government remains committed to its target of achieving 300,000 homes per year. Accordingly, it is vital the SWLP sets a positive framework to fully accommodate its housing needs and importantly address existing underlying issues as well. The NPPF is clear at paragraph 61 that housing need should be calculated using the Government’s Standard Method unless there are exceptional circumstances to justify an alternative approach. The HEDNA outlines a rationale for applying a trend-based approach for which there is merit but noting the test of national policy for such an approach, it is considered that further justification is still required in this regard. However, regardless of whether the standard method is used, based on the 2014-based projections, or whether the alternative trend-based projection is used, this should still only be the starting point for determining the housing requirement for the Plan. The Plan acknowledges that there will likely be a need to accommodate some unmet housing needs from adjoining authorities which of course represents one potential uplift (addressed in response to a separate question), but it is suggested that an affordability adjustment should also be applied. The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Stratford-upon-Avon District, the affordable housing need identified in the Table 10 of the Plan is some 547 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 96% of the 13 total housing need using the 2014-based projections, or 63% using the trend-based projections. The situation in Warwick District is worse still. Affordability is an on-going and increasing pressure which will require a proactive approach that should be rooted in increasing the housing requirement given that market led housing schemes have, and will continue, to deliverthe biggest supply of affordable homes.
The standard methodology includes an affordability adjustment. However, the National Planning Practice Guidance is clear that the affordability adjustment applied to the standard methodology formula is not a solution to problems of affordability as outlined below.“The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (Paragraph: 006 Reference ID: 2a-006-20190220) The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Stratford-upon-Avon District, the affordable housing need identified in the Table 10 of the Plan is some 547 dwellings per annum. When this is compared to the overall housing need for the district, stated at Table 9 of the Plan, affordable housing need would equate to 96% of the total housing need using the 2014-based projections, or 63% using the trend-based projections. The situation in Warwick District is worse still. Given the above, applying the standard method or trend based approach will barely scratch the surface of addressing affordability in the Plan area and accordingly, it is suggested that an affordability adjustment should be applied to the identified housing need in order to address the considerable housing affordability issue across the Plan area.
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Table 11 of the Plan only provides data until 2032 but the Plan itself covers a long period. Therefore, before an approach is determined, the level of need should be fully evidenced over the entire Plan period as this will have a direct effect on the required strategy. Nevertheless, in meeting any identified need for specialist housing for older people, large scale sites are able to cater for a wide variety of needs and therefore where evidenced, such schemes could accommodate these needs in a proportionate manner.
Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. There remains to be an agreed and co-ordinated approach to addressing unmet needs around Birmingham so the SWLP should consider accommodating some needs having regard to, inter alia, the functional relationship between the South Warwickshire and the source of these shortfalls. It is noted that for the purposes of the SA the Councils have tested the effects of an additional 5,000 and 10,000 homes, which we support in principle. However, further engagement and agreement with neighbouring authorities is required and any level of unmet need planned to be accommodated must also be subject to a future review, pending the outcome of any wider work to comprehensively address unmet needs in the region.
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Q-H6: Pitches and Plots for Gypsies, Travellers and Travelling Showpeople It is considered that the SWLP should adopt a flexible approach to Gypsy and Traveller provision and this approach should utilise a combination of options H6A (identify a range of specific sites in sustainable locations) and H6C (rely on a case-by-case approach where applications are assessed against a range of criteria). This will ensure that locations are chosen that a suitable and attractive for Gypsy and Traveller and Travelling Showpeople which will ensure their needs are met. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire The site – South East Stratford: CEG and Mixed Farms Ltd control 102 hectares of land on the south-eastern edge of Stratford-upon-Avon, which is considered to be an appropriate location for a major residential-led mixed use development, with potential for an initial short-term phase (included as a Reserve Site in the Revised Preferred Options Consultation of the Stratfordupon-Avon Site Allocations Plan – ref: STR.D (SAP)) that could be delivered early within the Plan period, without prejudicing wider growth of this strategic opportunity. The site is located on the edge of the principal and most sustainable settlement in Stratford-upon-Avon District, one of five main towns across the Plan area, and benefits from easy access to a range of services and facilities. It is not subject to any landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets. The site is located adjacent to and north of the A422 Banbury Road and would form a natural extension to the existing residential area to the east of Stratford-upon-Avon. It benefits from having direct frontage along the A422 thus enabling a new junction to be accommodated to access the development which links into existing footways. A number of local facilities including Bridgetown Primary School, recreational pitches, convenience food stores, pharmacies are in the immediate vicinity of the site. The town centre of Stratford-upon-Avon offering a range of high street retailers, restaurants and leisure facilities is within 2km of the site. Local buses travel along A422 Banbury Road as well as A4390 Trinity Way. Local bus stops are within a comfortable walking distance from the site along Banbury Road making public transport a genuine option for travel. The site benefits from excellent pedestrian infrastructure with continuous footways on both sides of A422 Banbury Road into Stratford-upon-Avon. Similarly, both A422 Banbury Road and the A4390 Trinity Way provide cycle infrastructure in the form of on-carriageway cycle lanes (A422) and a shared traffic-free cycleway/footway on the norther side of the A4390. The shared route extends from the roundabout junction with A422 Banbury Road to the immediate west of the site to the roundabout of the A4300/Severn Meadows Rd roundabout further west. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages. Development in this location would provide a significant level of market and affordable housing and supporting community infrastructure. It would also help facilitate the delivery and provide financial contributions towards an eastern relief road around Stratford-upon-Avon, as required. This would, in its own right, deliver significant social and economic benefits locally and at the sub-regional level. Given that the SWLP now has a remit of exploring strategic growth opportunities, it should comprehensively consider the substantial benefits that can be delivered through large scale growth south east of Stratford-uponAvon, in particular supporting the delivery of an eastern relief road, strategic piece of infrastructure, noting that paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs of their area. CEG and Mixed Farms are pleased to see that growth in south east Stratford-upon-Avon features in each of the five growth options outlined in the Plan and is rightly scored as the most sustainable option in Stratford-upon-Avon. Having regard to the above, CEG and Mixed Farms proposes to prepare a detailed Vision Document for the site, which will be supported by a range of technical work to demonstrate how the site could successfully deliver a residential-led mixed use development on the edge of the largest and most sustainable settlement in Stratford-onAvon District. At this stage, a ‘Site Constraints and Opportunities Plan and Conceptual Framework’ prepared by Define is provided (see Appendix 2 to these representations) to outline how development of the site could sustainably be provided. This demonstrates that the site can address site specific considerations, comprising the following; a. Circa 1,200 market and affordable dwellings; b. Significant community infrastructure provision including a neighbourhood centre, primary school, sports pitches, public parkland and biodiversity parkland; c. A genuinely landscape-led approach that mitigates the impact on the Alveston Hill vantage point and important views; d. A substantial network of green infrastructure with green corridors that will provide opportunities for sustainable travel and recreation. This will build upon a local neighbourhood concept; e. New movement corridors to help address existing traffic and associated environmental issues within Stratfordupon-Avon itself and create strong, direct links with the economic growth aspirations at Wellesbourne as identified within the SWLP and the recently adopted Wellesbourne Innovation Campus Masterplan SPD; f. Avoiding residential development within the safeguarded zone of the high-pressure gas pipeline; and g. Strong connectivity to Stratford-Upon-Avon through improved linkages along Banbury Road. We would welcome the opportunity to discuss our proposals for the site in more detail, once the Vision Document and associated technical work has been completed. Assessment through the SAP: In the preparation of SDC’s SAP, it was clear that despite Stratford-upon-Avon being the most sustainable settlement in the District, growth was being significantly limited due to a single purported highway capacity issue. In this regard, CEG and Mixed Farms did not consider Stratford-upon-Avon District Council (SDC) struck an appropriate balance between all relevant considerations (noting the significant benefits outlined above) and would seek to ensure that the SWLP does not follow a similar path. Firstly, the matter related to highway capacity, rather than highway safety and paragraph 109 of the NPPF is clear that development should only be prevented on highway grounds if the residual cumulative impacts on the road network would be severe, which we do not consider arises in this instance even based upon the Council’s evidence. Secondly, SDC’s highway evidence supporting the SAP was not considered to be robust, in particular having regard to the substantial growth in future traffic levels that completely ignore trends over the last decade. The SWLP should therefore adopt a more realistic approach, which it appears to be taken having regard to the favourable SA outcomes for the site. It should be noted that Vectos has previously provided transport representations as part of the SAP preparation process which are summarised in a Technical Highways Note, provided at Appendix 1 to these representations, which addresses the mobility vision for the site. The Notes outlines that in relation to the development of the site, the aim is to minimise the need to travel in the first instance, internalise a proportion of trips within the site through local living principles, and where people travel outside of the site, it is practical to make the very best of the site’s locational advantages through sustainable travel modes. This will not only reduce journeys, but journey mode and will hence directly respond to the declared climate change emergency in the region whilst providing for essential growth. Furthermore, it demonstrates that the proposals can suitably mitigate impacts upon the highway network and addresses purported underlying issues with the highway network. 4.29 Thirdly, it outlines that the substantial sustainability benefits of allocating further growth a Stratford-upon-Avon had been ignored through the SAP process and as already outlined, we urge the Councils not to follow this approach again through the SWLP. Summary: Overall, the proposals represent a highly sustainable option growth option that can deliver a range of substantial benefits, a position the Council accept, noting its own evidence identifies it as one of the most sustainable options around Stratford-Upon-Avon and indeed the plan area as a whole. We would welcome the opportunity to discuss the our proposals for the site in due course, once more detailed information has been prepared.
2.2 The Vision for South Warwickshire includes five overarching principles which will determine how development will be delivered. The CEG proposals for Westwood Heath are considered against each of these principles to demonstrate how the site can contribute to achieving the Vision: • A climate resilient and Net Zero Carbon South Warwickshire - The proposed development at the site would contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking advantage of two key attributes, size (strategic growth) and location (adjacent to Coventry and the University of Warwick and the associated employment) development of the site can include numerous measures and strategies to encourage local living, reduce the need to travel and support the initiatives of 20-minute neighbourhoods. This will help the South Warwickshire economy achieve its aspirations for delivering a net-zero carbon economy through the reduction in emissions. This transition will be further supported through the delivery of modern, energy efficient homes and commercial premises of which CEG have a clear track record of delivery. • A well-designed and beautiful South Warwickshire - Westwood Heath is strategically well located to deliver a well-designed neighbourhood that respects the existing beauty and heritage of the area. It is not located within any local landscape designations and whilst situated in the Green Belt, circa 30ha of this is identified as safeguarded land through policy DS21 of the Warwick Local Plan therefore the principle of it being released to meet longer-term strategic development needs has been established. Furthermore, the identified alignment of HS2, provides a new logical Green Belt boundary for the Coventry urban area, and alongside other measures such as proposed green infrastructure corridors, will help to maintain separation with Kenilworth and thus ensure that the development does not contribute to settlement coalescence. Moreover, there are no historic assets located within the site and a limited number in the immediate area. • A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable garden community, providing both a range of housing to meet identified needs, and community facilities, focussed around a mixed-use centre with primary school, convenience and community facilities, sports provision and potential for live/work community hubs supporting both the development and diverse economic uses in the surrounding area. This would be set within a substantial green infrastructure network that will encourage active travel and contribute to enhanced health and wellbeing. • A well-connected South Warwickshire - The site will be integrated and connected with Coventry and the University of Warwick including through a potential green travel corridor providing a sustainable link across the area, supporting walking, cycling and enhanced public transport. The site will also be able to link to existing public transport connections (including access to Tile Hill station). These infrastructure improvements, including an improved southern access to The University of Warwick will align with the significant transport improvements already being implemented in the area, including the improvements at the A46 Stoneleigh Junction and the new crossing of the A45. This corridor also has the potential to integrate with wider connections to the HS2 interchange at Arden Cross. This will further ensure the area is well-connected and realises the benefits of infrastructure investment, ensuring strategic growth is suitably aligned. • A biodiverse and environmentally resilient South-Warwickshire - Biodiversity net gain will be incorporated into the proposals for the site. The conceptual framework for the site will feature and cohesive ecological network that retains existing landscape features integrated with the existing local wildlife sites.
