Issue and Options 2023
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Q-T1: Please select all options which are appropriate for South Warwickshire Paragraph 110 of the Framework advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users. Therefore, it is considered that Option T1b would be most appropriate. It is considered that the new homes at Land South of Allimore Lane, Alcester will comply with the 20-minute neighbourhood concept. The Vision Document demonstrates that the occupants of the proposed development will be within a 20-minute walk of existing services and facilities available within Alcester. The Site is in a highly sustainable location, benefitting from a full range of day-to-day facilities (education, employment, retail, health and community/recreation/leisure) within walking distance, accessible via the existing pedestrian network and access strategy. The full extent of the Alcester urban area is within cycling distance of the site. Bus services are accessible from bus stops located on Priory Road and Birmingham Road, which include hourly services (weekdays) between Redditch and Evesham, and services to Stratford-upon-Avon every 1-2 hours (weekdays). Q-T2: Please select the option which is most appropriate for South Warwickshire L&Q Estates are supportive of Option T2a as a hierarchical approach in terms of prioritising transport infrastructure for those living in rural areas and urban areas would be most appropriate. In particular, we are supportive of exploring opportunities to use existing green and blue infrastructure as potential active travel options. This approach is consistent with Paragraph 110 of the Framework, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users. L&Q Estates’ site at Land South of Allimore Lane, Alcester will include a series of new pedestrian and cycle routes within the development, in addition to providing active travel connections to the residential development adjacent to Birmingham Road that is currently under construction, Allimore Lane to the north and to Roman Way to the east (via an existing dedicated Public Right of Way). Vehicular access to the site would be provided via connections to the internal road layout delivered as part of the residential development at Land North of Allimore Lane, connecting to Birmingham Road. This would enable the closure of Allimore Lane to through-traffic east of the vehicular access to the site, with through movements permitted for pedestrian and cyclists only.
Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Sites of national importance are protected by national planning policy. Duplication of that policy is not strictly necessary in the SWLP. However, L&Q Estates are supportive of a policy which seeks to require the safeguarding of such sites, unless the benefits of the proposal clearly outweigh the need to protect the site. As noted in the Vision Document accompanying these written representations, Land South of Allimore Lane, Alcester contains a non-statutory ecological designation, the Spittle Brook LWS, which has hydrological connectivity to the Severn Estuary Special Areas of Conservation (SAC)/Special Protection Area (SPA)/Ramsar sites via the River Avon. Accordingly, consideration will be given to the implementation of construction safeguards and a suitable drainage strategy to ensure development of the site does not result in adverse effects on these designations. In addition, Bredon Hill SAC is identified within 20km of the site with the potential for recreational pressure to occur but good design and the creation of areas of formal an informal public open space, recreation pressure to the Bredon Hill SAC can be mitigated for. The Site is dominated by agricultural grassland fields and a single large arable field, with a range of diverse native hedgerows, and mature trees, with a veteran crab apple identified in the north-west. A watercourse flows centrally through the site and is bounded by broadleaved woodland. Subject to a sensitively designed masterplan, including provision of a suitable buffer between the watercourse, woodland, and veteran tree from built development, adverse effects on these higher quality habitats can be avoided. The large arable field in the south provides a wide range of opportunities for good quality habitat creation which will provide a large offset for on-site losses and reduce the amount of off-site compensation if required for Biodiversity Net Gain.
NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ It is noted that in the conclusion for the Sustainability Appraisal it states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ [emphasis added] Furthermore, the following technical assessments are currently being undertaken to help inform later stages of the plan: • Transport Assessment • Climate Change Impact Assessment • Biodiversity and Green Infrastructure Assessment • Landscape Character Assessment • Health Impact Assessment • Green Belt Study • Heritage Assessment The Issues and Options SA is, by its own admission, heavily caveated and no mitigation has been considered. We therefore reserve the right to comment further at a later stage, once the Sustainability Assessment has advanced following the outcome of key evidence base documents.
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Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-onStour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements. Long Itchington is categorised as a ‘Local Service Village’ in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. The settlement hierarchy is defined below: 1. Main Town: Stratford-upon-Avon 2. Main Rural Centres 3. New Settlements 4. Local Service Villages (including Long Itchington) 5. Large Rural Brownfield Sites 6. All other settlements 7. Local Needs Schemes Paragraph 5.1.9 of the Core Strategy explains that the villages across the District display a wide range of sizes, functions and characteristics. As a means of applying the dispersal approach to future housing development, a methodology was devised to identify an appropriate set of Local Service Villages. The approach applied an assessment of the presence and comparative quality of three key services - general store, primary school and public transport - together with the existing size of the settlement. The latter has been applied as the overriding factor, by which a settlement has to have at least 100 dwellings to be identified as a Local Service Centre regardless of the presence of key services. Based on this methodology, Long Itchington is identified as a ‘Category 1’ Local Service Village and is considered to be one of the most sustainable villages in the District. It is suitable and appropriate to accommodate housing growth. The village contains numerous services and facilities, including a supermarket, a small local shop, a nursery and primary school, seven pubs, a diner, hairdressers and allotments. Land north of Leamington Road, Long Itchington is located along the northern edge of the village and immediately adjoins the built-up area boundary of Long Itchington and existing residential development to the south. The promotion site would be well connected to the built-up area of Long Itchington and would constitute sustainable development. Indeed, it is considered that the new homes at land north of Leamington Road will comply with the 20-minute neighbourhoodconcept, owing to the close proximity of the site to Long Itchington’s services and facilities. Given the pressing need for additional housing within the Stratford-on-Avon District, Long Itchington is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the village and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.
Q-S1: Please select the option which is most appropriate for South Warwickshire As shown on the Vision Document (Appendix 2) and Concept Masterplan for land north of Leamington Road, Long Itchington, it is proposed to retain and enhance the majority of the existing landscape fabric, including the central hedgerow which will form a green corridor through the site. SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. The proposals will deliver a number of landscape benefits, including new Public Open Space, play facilities and recreational routes. The promotion site is located adjacent to an existing area of Public Open Space, comprising a community park known as LILAC Field or Green End Park. This area is managed by the Parish Council and contains sports and recreational provision, including play areas, a skate park, outdoor gym and playing fields. In addition, the northern part of LILAC Field contains orchards, a picnic area and memorial garden. It is proposed to create a village green within the promotion site to the east, forming an extension of LILAC Field into the site. New planting will include generous green buffers along the western and northern boundaries of the site. Therefore, the proposals for land north of Leamington Road, Long Itchington demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.
It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. However, it is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and anet increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.
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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.
In accordance with the guidance contained within the Framework, development should be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework. L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. Long Itchington is identified as a Category 1 Local Service Village and is therefore one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon district. It offers a large range of services and facilities, including a supermarket, a small local shop, a nursery and primary school, seven pubs, a diner, hairdressers and allotments. Land north of Leamington Road, Long Itchington is located along the northern edge of the village and immediately adjoins the built-up area boundary of Long Itchington and existing residential development to the south. The promotion site would be well connected to the built-up area of Long Itchington and would constitute sustainable development. Indeed, it is considered that the new homes at land north of Leamington Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Long Itchington’s services and facilities. Given the pressing need for additional housing within the Stratford-on-Avon District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Long Itchington is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the village and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site would be an appropriate location to accommodate a residential development to meet housing shortfalls from outside of South Warwickshire.
