Issue and Options 2023
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site. Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District? Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and interrelationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g. Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. In light of the above considerations, we agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District. Q-H5: Please select all options which are appropriate for South Warwickshire Whilst it is considered that Option H5a would enable the South Warwickshire Authorities to group this type of housing together in small sites in various locations, such an approach would be dependent on landowners putting sites forward for this type of housing. Therefore, this approach may not provide sufficient suitable development permissions to meet the identified demand in accordance with the duties under sections 2 and 2A of the Self Build and Custom Housebuilding Act 2015. We consider Option H5b is appropriate for South Warwickshire, provided it can be demonstrated that there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located. The proportion of self and custom-build plots to be made available within large sites should be sufficient to match the current number on the register. Such an approach would align with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. It is considered that any policy under Option H5b should also include a fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (of, say, 12 months, for example).
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Issue C7: Adapting to higher temperatures It is considered that a requirement to future-proof new development to adapt to the effects of higher and more extreme temperature change could be incorporated as part of design guides/codes for strategic development sites or locations. As shown on the Vision Document for Land South of Allimore Lane, Alcester, the orientation of buildings and streets to reduce excessive solar gain and to catch breezescould be considered as part of the scheme design. The use of green infrastructure, greenspace and bluespace can be integrated within the masterplan and landscape framework, in order to minimise the urban heat island effect, provide shading and places of refuge and promote evaporative cooling. L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Land South of Allimore Lane, Alcester development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Q-C9.1: Please select the option which is most appropriate for South Warwickshire NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. L&Q Estates are supportive of Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. The Site will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention of woodland habitats, enhancement of the setting of Spittle Brook, strengthening of hedgerow along the site frontages, and the creation of wildflower meadows around SuDS features which are tolerant to wetter conditions. Low-lying areas of the site would allow for the creation of wetland habitats to enhance the setting of the development and to provide net gains in biodiversity. In addition, the large arable field to the south of the Site provides a wide range of opportunities for good quality habitat creation.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire We are generally supportive of Option C4.1c – a phased approach to net zero carbon -setting a future date by which all new development will need to achieve net zero standards. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Option C4.1c insofar as this option allows time for the cost of achieving these standards to come down, and may mean that more affordable housing and community benefits can be secured from development.
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Q-D2: Please select all options which are appropriate for South Warwickshire L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Land South of Allimore Lane, Alcester development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Therefore, L&Q Estates are supportive of Option D2c: Develop design guides/codes for strategic development sites/locations, particularly as the planned public engagement will ensure the design of spaces and buildings will be appropriate and will respond to local context and identified needs in terms of size, type and tenure. The Vision Document demonstrates that much work has already been undertaken into achieving a welldesigned neighbourhood. Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? L&Q Estates agree that a high-level strategic policy that seeks to protect and enhance existing heritage assets should be included within the Part 1 plan, in accordance with Paragraph 190 of the Framework. Detailed heritage policies should be deferred to Part 2. The Site is not adjacent to any designated heritage assets. A Heritage Appraisal has been undertaken to inform the Concept Masterplan and Vision Document for Land South of Allimore Lane, Alcester. The deliverability of development on the site with reference to the historic environment constraints has been assessed. There are distant views towards the Grade II* Listed Church of St Nicholas, located within the Alcester Conservation Area, from the eastern area of the Site. Currently, it is anticipated that this area of the site would remain as open space. The Heritage Appraisal considers that residential development in the northern area of the Site would not adversely impact the Church of St Nicholas or any other designated heritage assets. An initial review of the archaeological resource has also been undertaken. Allimore Lane, which bounds the Site to the north, follows the route of The Saltway Roman road. Grunthill Roman cemetery is recorded to the east of the Site. The full extent of the cemetery is not known. The Heritage Appraisal considers there is potential for burials to have extended into the Site, particularly at the south east, and it is anticipated that this area will be proposed as Public Open Space. There is also potential for prehistoric and Roman period archaeological remains to be present elsewhere within the Site. However, it is anticipated these would be addressed by an appropriate programme of archaeological works.
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Q-W2: Please select the option which is most appropriate for South Warwickshire • Option W2a: Include a policy on Health Impact Assessments. • Option W2b: Do not include a policy on Health Impact Assessments. We are supportive of Option W2a and consider a policy should be included on Health Impact Assessments. This option seeks to deliver appropriate local facilities to support residents and to enhance the sustainability of existing areas. The Vision Document prepared for the Site has been structured to follow Building for a Healthy Life (BHL) principles. BHL is one of the most widely used design tools in England for creating places that are better for people and nature. It was written in partnership with Homes England, NHS England and NHS Improvement and is structured to set clear expectations for new developments. By following BHL, a critical aspect of the Vision for the Site is to design for active travel and access to green space. The ability to be able to walk and cycle within the new neighbourhood and the site’s good accessibility to the built-up area of Alcester, a town with many local services, is key in order to minimise traffic and mitigating climate change. Equally, and as BHL sets out, the COVID-19 pandemic has reinforced the importance of designing for active travel. This is in recognition that design choices that help people feel disposed to walk or ride a bicycle in their neighbourhood are critical to supporting a sense of well-being from outdoor exercise. It is considered that the healthcare requirements for strategic sites should be set out in the Infrastructure Delivery Plan, once prepared. We note that work is ongoing in relation to the Infrastructure Delivery Plan. We therefore reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined.
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