Issue and Options 2023
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New searchIt is important to have in mind that South Warwickshire is to grow and evolve in the plan period to 2050. Change is inevitable, and the planning process functions to support sustainable growth and should not be applied to stymie or otherwise place unnecessary obstacles in the way of new development. Thus, tackling the climate emergency cannot be at the expense of delivering new housing, employment and retail and other space. We consider that the Vision has been modified to better reflect this important principle, and one of the six Strategic Objectives now relates to meeting sustainable development needs. This is welcomed and reflects our earlier submissions. However, we consider that this should be further amended to make clear that development needs must be met in any event, and that it is for the plan to set out how this is achieved sustainably.
The SA prepared to support the Issues and Options explores reasonable options in relation to: • 5 Growth Options which provide details about where development should be distributed at a strategic scale across the South Warwickshire area • 7 New Settlement Locations for large-scale development of not less than 6,000 new homes and associated infrastructure • 32 Broad Locations which represents options for up to 2,000 homes located around the main settlements for medium scale development and associated infrastructure in any one Broad Location • 22 Small Settlement locations for intermediate scale development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. • 116 Policy alternative options for shaping the relevant policies. Subjects include for example climate change, tourism and health. Each option has been assessed/scored against each of the 13 SA objectives in relation to 1. climate change; 2. flood risk; 3. biodiversity and geodiversity; 4. landscape; 5. cultural heritage; 6. pollution; 7. natural resources; 8. waste; 9. housing; 10. health; 11. transport; 12. education and 13. economy. The comments below relate first of all to the housing numbers and then to the growth options and broad locations around main settlements. Housing numbers Two reasonable alternatives to establishing housing number calculations have been undertaken. Option 1 – the HEDNA trend- based projections which point to a need for 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum in Warwick – total of 1,679 dwellings per annum. Option 2 – uses the Standard Method and identifies the need of 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum in Warwick – total of 1,239 dwellings per annum. It is reported within the SA that using the HEDNA figure would more accurately represent local housing need and would better meet the needs of the various members of the community (including affordable homes, student accommodation, older people’s accommodation, specialist housing and custom and self-build plus gypsy and traveller and travelling show people communities). Both options have a similar negative impact on climate change, biodiversity, pollution, natural resources and potentially waste. Option 1 would likely have a greater adverse impact on landscape and townscape character due to higher housing numbers. Both options have a similar minor positive impact on 11 – transport, by the location of new housing in closer proximity to workplaces. The consideration of housing numbers does not provide any locational information and so the impacts in relation to climate change, cultural heritage, health, education is uncertain. Whilst overall, at this stage option 2 appears to perform better overall, we would support the use of the higher HEDNA figure which will allow flexibility within the overall development strategy. This will enable the plan to accommodate a meaningful percentage of displaced unmet housing needs of the adjoining authorities – notably Birmingham, Black Country and Coventry. Growth options As set out in the SA, scores each option against the SA objective, which indicates that each option is likely to perform better than others. All perform positively in relation to employment and housing and so, at this stage, no stage should be ruled out in our view. The broad locations for proposed new development have also considered reasonable alternatives within Alcester, Kenilworth, Royal Leamington Spa and Whitnash, Shipston-on-Stour, Southam, Stratford-upon-Avon and Warwick. These locations were further analysed to test distances from GP surgeries, schools, public transport etc, to remove land within flood zones 2 or 3, AONB, Grade 1 agricultural land, scheduled monuments, SSSI, Registered Parks and Gardens and Ancient Woodland. These broad locations all perform similarly against the SA objectives and at this stage, we would consider it too early to discount any broad locations without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. The same principle is considered appropriate in terms of reasonable alternatives put forward in relation to small settlement locations. Early indications within the SA consideration in relation to New Settlements suggest that this growth option would perform poorly against climate change overall and waste, use of natural resources and landscape; some performing poorly against flood risk, pollution, health, education and biodiversity and local wildlife sites. Whilst this option would achieve up to 6,000 dwellings, thereby resulting in a significant contribution towards meeting the housing need, and seen as being a major positive impact on housing provision, these large-scale developments invariably take years to come to fruition, requiring major investment in all types of infrastructure before housing can come forward. Numerous local plans relying on this type of option have failed. This option, in our opinion therefore is the least favoured and potentially should be ruled out at this stage.
Q-I4.1 Should we include a policy to safeguard specific infrastructure schemes within the SWLP? Yes, in part. We consider that it is appropriate for a policy to safeguard specific infrastructure schemes within the SWLP, where those infrastructure schemes have been evidenced through the plan making process. Where infrastructure schemes have not been evidenced, it would be inappropriate for the plan to specify and safeguard such schemes, since these would not be justified having regard to the tests of soundness embedded in the NPPF. Where specific infrastructure schemes are safeguarded, the policy must be sufficiently flexible to be adaptable to changing circumstances. For example, one such infrastructure scheme which may be safeguarded is the improvement of the A46 at Bishopton and Wildmoor junctions. We are aware that scheme proposals for junction improvements are evolving, and the land take required may change over time. Where a plan showing the extent of safeguarding is embedded in the SWLP it should be made clear that the precise extent of safeguarding may change (either extending or shrinking) due to changing circumstances.
Issue I2 Infrastructure Requirements and Delivery Q12a: This option, to set out infrastructure for all scales, types and location of development within Part 1 of the Local Plan is considered is preferred. This would allow the requirements to be applied equally across the District and provide developers with more certainty when coming to consider implications for proposed development/proposed sites across both Stratford and Warwick. Issue I3 CIL Q-13a: This option for CIL is preferred, which would set a single levy for the whole of South Warwickshire. This would give developers greater certainty regarding likely development costs.
Yes, we agree that some of the existing settlements should be part of the overall strategy. The SA has explored a number of alternative options for growth at existing settlements. The importance of considering the potential for growth around the edges of existing settlements is acknowledged. The growth of all existing settlements (proportionate to their size) could also assist the council to secure benefits associated with the 20-minute neighbourhood principle – the settlement analysis undertaken as part of the evidence base identifies settlements which are considered to be suitable for growth – based on connectivity, accessibility and density analysis. Taylor Wimpey (Midlands) Ltd and Bloor Homes have an interest in a parcel of land at The Asps, which is located on the southern edge of Warwick and to the west of Royal Leamington Spa. It has been submitted to the Call for Sites and known as Agricultural Land. The Asps site is located to the south-east of Warwick and as such the following comments relate to the analysis of that area contained within the Settlement Analysis undertaken by the Council to inform the Local Plan. The connectivity analysis considers The Asp Farm within Area 8. There is no real commentary other than to highlight that the site is served by one brown route (the A46). It has been graded as Grade D – which is the equivalent of an amber score. We do not necessarily agree with the above score but do accept that the site does not physically link with the southern edge of Warwick. We would like to point out however, that the development of this whole site for residential development for up to 900 dwellings, a primary school, a local centre and a Park and Ride facility for up to 500 spaces, with access from Europa Way and Banbury Road, areas of public open space, landscaping enhancements and archaeological mitigation was allowed at appeal in 2014, following a refusal by the council. The appeal was called in by the Secretary of State for determination. He placed moderate weight on the accessibility drawbacks of the site but considered that the Park and Ride facility would be a substantial benefit that has the potential to reduce vehicular traffic in the town centre and surrounding highway network as well as alleviating town centre parking congestion. Essentially then, the site at the Asps once developed in accordance with the outline consent will become a separate neighbourhood, with access to a primary school, local centre and served by a park and ride facility with regular bus services running into Leamington Spa and Warwick. The connectivity for residents throughout the development to services/facilities required on a daily basis will be good, accessible by bus, cycle or walking. The phase 1 Reserved Matters consent resulted in the diversion of a public right of way which leads through the site onto the Banbury Road. Discussions are ongoing with phase 2 proposals to ensure pedestrian connectivity through the site is achieved through the site to services/facilities on Banbury Road (particularly Warwick school). The Park and Ride reserved matters application is currently being considered by the LPA and discussions have been on-going with the Council to ensure that it meets their expectations and complies with the specification set out within the S106 legal agreement. The site falls within the red line boundary of the outline approval and is not indicated on the approved phasing plan for any purpose. The advanced planting stage was approved by a separate Reserved Matters application and has been implemented. The infrastructure phase has also received consent and also implemented. The Reserved Matters schemes for phase 1 have been approved (450 dwellings in total); and the layout fixed for phase 2 and currently under consideration (also for 450 units), which cumulatively achieves the 900 dwellings approved by the outline – the development of the agricultural land cannot be carried out without a fresh consent. The site could provide up to 70 units and development of them would make efficient use of the land and form a logical extension to the Asps. Further site-specific details can be considered at relevant points in the future as the development of the plan progresses. From a sequential point of view, the site is not contained within the Green Belt or within a Landscape Sensitivity area and so as such, should be given priority for development over other sites located within sensitive locations such as those within the Green Belt.
