Issue and Options 2023
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New searchQ-D1.1 – Do you agree that this is an appropriate range of topics for the strategic design policy? Yes, the range of topics identified is appropriate for a strategic design policy. South Warwickshire has a large plan area, comprising large towns, a variety of villages of different size, hamlets and significant areas of countryside. It is, therefore, imperative that a design policy is flexible to recognise the different environments across the plan area, delivering high quality schemes. Q-D2 – Please select a design code option which is appropriate for South Warwickshire It is our view that a single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. It is our view that the most appropriate approach would be to include policy guidance within the site specific allocation policies where appropriate making it clear how the allocations are expected to respond to their surroundings. If necessary, design codes could also be produced for specific settlements and locations that have a particular design issue that need addressing. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire We support a policy that confirms the relevance and importance of density, but it is not appropriate to identify a minimum density or range of densities within the policy. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitate schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area. In addition, the SWLP will need to recognise the impact of the inclusion NDSS, open space and green infrastructure policies will have a density. NDSS compliance schemes result in larger property types, reducing the density of developments. Incorporating a significant amount of green space on schemes and biodiversity net gain measures is also likely to reduce net developable areas beyond those previously achieved. The proposed allocations need to be of a sufficient size to accommodate green and blue infrastructure whilst having realistic density assumptions.
QW2 – Please select a Health Impact Assessment option which is most appropriate for South Warwickshire In our view it is not necessary for the SWLP to include a Health Impact Assessment policy requiring new developments to be submitted with a Health Impact Assessment. HLPC operate in a variety of authorities where Health Impact Assessments are required. In our experience, they add little to the overall application submission and create additional cost. Matters such as pollution, air quality, access to services and facilities can be addressed in the wider planning submission.
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Q-T1 – Please select the 20 minute neighbourhood option which is most appropriate for South Warwickshire As part of the preparation of the SWLP the local authorities will need to identify the most appropriate locations for housing allocations. In doing so it is appropriate to consider the 20 minute neighbourhood principle and the ability of residents to gain access to employment land, schools, services and facilities and high quality public transport connections. We fully support this approach and it should be noted that the land in Vistry’s control at Southam can fulfil the 20 minute neighbourhood objectives through its own onsite infrastructure and by connecting to the exiting services and facilities in Southam town. We have no particular objection to the SWLP including a policy that sets out the principle of the 20 minute neighbourhood. However, this concept is, in our view, more closely linked to the identification of allocations rather than the development control process. Whilst the strategic sites will provide a range of services and facilities and can be planned using 20 minute neighbourhood style approach this is not the case with smaller schemes that rely on existing or upgrade local infrastructure. Q-T2 – Please select a transport hierarchical approach that is most appropriate for South Warwickshire It is our view that it would be helpful for the plan to include guidance on the hierarchical approach in terms of prioritising transport infrastructure. The proximity to public transport opportunities should be a consideration. This is, however, of more significance to the preparation of the plan and the site selection process. In addition, it should be noted that there are a large number of settlements within the plan area that do not have train stations. They do, however, require additional development to support their sustainable growth. There must, therefore, be flexibility in terms of the application of the transport hierarchical approach in these instances. As a final point, we note that reference is made to a potential to reducing car parking standards in certain where there are good active/public transport links. This must be treated with caution. Delivering development in locations with good public transport links should help to encourage people to commute without the use of a car. However, this cannot be guaranteed. Restricting car parking spaces will not reduce car ownership. If a resident needs a car for work, to visit relatives or for another reason, a lack of car parking space will not prevent them owning a car. Instead, it is likely to result in on-road car parking that would detract from the character of the area.
Q-B5 – Please select the environmental net gain option that is most appropriate for South Warwickshire Whilst we have no particular difficulty with the inclusion of environmental net gain policy within the SWLP, it is noted that the Draft Plan’s supporting text advises that there is “much work to be done to explore environmental net gain further”. In order for the SWLP to include the policy on environmental net gain its implications need to be fully understood, in terms of both the site selection and development control process. Its requirements would need to be factored into the viability work being undertaken in the plan in order to establish what impact it would have on the deliverability of allocations and the masterplanning process generally. Q-B6 – Should the South Warwickshire Local Plan introduce wild belt designations? The wild belting approach means that land would be specifically designated for environmental enhancement. The wild belts would be designated areas of land that are currently of low biodiversity value where works could be undertaken to support nature’s recovery, including creating new habitats or bringing nature back. It is questioned how this is deliverable, given that the land is likely to be in private ownership. Whilst a policy could be put in place there can be no mechanisms to require a landowner to maintain or manage their land in a particular way. Whilst we have no specific concerns of the concept, it is undeliverable as we understand it and as such it is not a realistic objective of the plan.
