Issue and Options 2023
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New searchQ-S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on. We note that the Settlement Design Analysis, which is published in support of the Issues and Options consultation, seeks to identify the best connected locations for potential growth, and to identify locations with good accessibility to existing services and facilities. Kenilworth is identified as a Main Town in that report. Our client’s land (which forms part of Parcel 6), adjacent to Kenilworth, is assessed as having a connectivity level B, the second best connectivity achievable. The Landform Analysis in the same document identifies the site as Green Infrastructure. We contend that the site should not be identified as Green Infrastructure. The European Commission definition of Green Infrastructure is: ‘A strategically planned network of natural and semi-natural areas with other environmental features, designed and managed to deliver a wide range of ecosystem services, while also enhancing biodiversity.” The site currently provides mown and managed playing fields, which support minimal biodiversity, do not provide natural habitats, and are used for recreational purposes by multiple people. As such, we request that the Green Infrastructure designation is removed from the site. The document also notes that the site has access to three types of facilities within 800m; retail, jobs and economy, places to meet and open space, leisure and recreation. In addition, Kenilworth High Street only lies 1,000m from the site, and there is a wide pavement along Coventry Road to the High Street which could be upgraded to a cycle and pedestrian route, providing a quick and convenient link to the shops and services in the town centre, and the train station with its services to Leamington Spa, Nuneaton and Milton Keynes. The Service 24 bus passes the site , linking the site to Kenilworth, the University of Warwick and Coventry. The site covers an area of 3.16ha. Some of the land is surplus to requirements, and therefore it is proposed that reconfigured sports facilities required by Crackley Hall School are retained at the site to make more efficient use of the site, and that the remainder of the site is released for residential development and development of a new childrens’ nursery, for use by both existing and new residents. The site has excellent potential access to Coventry Road. Sworders has engaged with the adjacent landowner, Border Holdings; we are aware of the Border Holdings’ submission of a masterplan and promotion document to the Councils, and this submission is made in that context, and would seek to complement that development.
Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Growth of existing settlements should be part of the overall strategy. Additional growth adjacent to these settlements offers the opportunity to make efficient use of existing infrastructure, and to make contributions to enhance and improve it for the benefit of new and existing residents. Examples include the expansion of health facilities, increase in bus services, or provision of additional school places or new cycle routes. Allocating land adjacent to existing towns enables new residents to connect to existing rail and bus services, and to access existing employment areas. It does require careful consideration to ensure that new development can be integrated into the existing urban fabric in a way which is not detrimental to existing residents, shops and services. Our client’s site lies to the north of the Coventry Road, Kenilworth. It is immediately adjacent to the adopted settlement boundary and to the Princes Drive employment area, which offers a range of light industrial units and a focus for local employment. As such, an allocation for residential development on our client’s site would provide a sustainable location for new homes. Issue S6 – A review of Green Belt boundaries As noted in the Plan, the Green Belt includes some of the larger settlements such as Kenilworth, the majority of the railway stations in the South Warwickshire Plan area, and all of the land surrounding Kenilworth. It also covers the northern part of the Plan area, where it would be sensible to allocate sites to meet un-met housing needs from Greater Birmingham and Coventry, due to the proximity of the area to these conurbations. While we acknowledge that the Government’s proposed changes to the National Planning Policy Framework may result in LPA’s no longer being required to release Green Belt land to meet housing need, this should not preclude them from doing so if that is the most sensible option for that authority, and we believe that this is the case in South Warwickshire. A full and detailed assessment of the contribution which land around Kenilworth makes to the five purposes of the Green Belt should be carried out at an appropriately granular level to enable sites to be released. For any growth of Kenilworth to take place, some Green Belt land is likely to need to be released, and therefore this should be accepted proactively by the LPA, and the assessment undertaken positively, with a view to releasing land from the Green Belt around Kenilworth. A balance should be struck between Green Belt protection, and the need to allocate sites which lie in the most sustainable locations. We contend that climate change is now a more pressing and important issue than the retention of Green Belt, and that therefore land should be released from Green Belt adjacent to existing towns if it provides housing in locations which minimise the need to travel, and thereby reduce the attendant carbon emissions. We therefore support the proposal in the Issues and Options document that a comprehensive Green Belt assessment will be undertaken, and will be used to inform the Plan’s spatial strategy, and we look forward to reviewing this document as part of future consultations. Our client’s site currently comprises playing fields which are located in the Green Belt. In terms of the contribution the site currently makes to the five purposes of the Green Belt, we demonstrate below that its contribution to Green Belt functions is limited: The site does not check the unrestricted sprawl of urban areas. Crackley Lane forms a strong western boundary beyond the site. The site does not prevent two urban areas merging into one another. There is development to the north east, east and south of the site. The site’s current use is playing fields, not open countryside. Its location, immediately adjacent to built form, and its current use do not assist in safeguarding the countryside from encroachment. The site does not currently preserve the setting or special character of Kenilworth. This is an urbanised environment with the industrial site to the east and post war residential development in close proximity to the south. The allocation of the site would not prevent urban or derelict sites coming forward; it is of a size where its allocation would complement urban regeneration and use of brownfield sites. It is therefore requested that the site is released from the Green Belt to provide an area for residential and a nursery development adjacent to Coventry Road, to be masterplanned alongside retention of reconfigured sports facilities for Crackley Hall school.
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Q-H1-1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? We confirm that the HEDNA evidence base provides a reasonable basis for identifying future levels of housing need. The draft Plan notes that, based on the Standard Housing Method, 5,554 new dwellings per annum will be needed across Coventry and Warwickshire to 2050, a proportion of which will be provided by the South Warwickshire authorities. We note that it is expected that Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth over the Plan period than other authorities within the Housing Market Area.
