Issue and Options 2023
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New searchIntroduction 1. These representations are made in response to the South Warwickshire Local Plan (SWLP) Part 1 Issues and Options consultation document and associated Call-forSites (January 2023) on behalf of Makestone Strategic Land (MSL). The representations relate to MSL’s land interests east of Snitterfield Street, a ‘reserve site’ identified in Stratford District Council’s Site Allocations Plan (SAP) (Revised Preferred Options, June 2022). Summary 2. MSL’s response to the SWLP is summarised as follows and included on the SWLP online consultation portal. The SWLP needs to plan for at least 47,012 dwellings 2022-2050(consistent with the HEDNA) with an uplift to address demographic and market signals plus unmet needs from the adjoining urban areas of Birmingham and Coventry as required by NPPF61. Whichever spatial option is taken forward to realise the above growth requirement, the SWLP needs to allocate sites at Local Service Villages (LSV) including Hampton Lucy to positively address the needs of rural communities, a key requirement of national planning policy and guidance (NPPF79 and NPPG0091in particular). MSL’s site at east of Snitterfield Street should therefore be allocated in the SWLP and released now. The site has already been identified as a suitable site for allocation, reflecting the site’s draft status as a ‘reserve site’ in Stratford District Council’s emerging SAP (draft Policy HAMP.A). Reserve sites are critical to the delivery and implementation of Policy CS.16 of the Stratford-upon-Avon Core Strategy (SACS) 2011-2031 to meet future needs – i.e. the needs now required in the SWLP to 2050. The allocation will help to meet rural needs in and around Hampton Lucy, and should be allocated for up to 30 homes, including 35% affordable provision, realising wider benefits for Hampton Lucy, including new green space for the local community (further details enclosed as part of these representations). Q-S7.2: Refined Spatial Growth Options 3. The SWLP Issues and Options consultation presents five growth options to address South Warwickshire’s requirements, with one of these to be taken forward as a subsequent Preferred Option. However, it is considered that a mixture of options is likely to be required to meet the needs of South Warwickshire’s communities. 4. Nevertheless, whichever option is taken forward the needs of rural communities needs to be met via dedicated allocations to LSVs in the SWLP. This will enable positive planning in response to the requirements of NPPF79 and NPPG009: “79. To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” (2021 NPPF, emphasis added) 5. In addition, provision of a mix of sites which includes smaller-medium site allocations in rural communities reflects the objectives of NPPF60, 68 and 69. 6. In doing so Stratford District Council has already identified suitable and sustainable sites for allocation as reserve sites as part of its emerging SAP. One of these sites is MSL’s site at Hampton Lucy: Policy HAMP.A. The Sustainability Appraisal (SA) (Addendum, May 2022) underpinning the SAP supports the allocation as follows, all informed by a Heritage Impact Assessment (HIA). 7. Reflecting the draft allocation in the SAP, MSL has undertaken masterplanning and technical work, enclosed with these representations, demonstrating that the site has capacity for up to 30 homes. Appendix A includes a masterplan for the site, underpinned by a landscape and visual strategy which reflects the site’s context to nearby heritage assets and the Council’s own HIA (Appendix B) as well as an appraisal to demonstrate how safe access can be provided in to the site for pedestrians, cyclists and vehicles (Appendix C). 8. In summary, the scheme comprises the following key features and benefits. Up to 30 homes, including 35% affordable provision, with a mix to reflect local needs. Extensive strategic landscaping and green space, reflecting the setting of heritage assets, the Council’s HIA and the site’s landscape and visual context, minimising views from the north and east in particular. Provision of a focal green space to the south of the site - as a potential hub for community activity and events, including LAP, wildlife habitats (to support biodiversity net gain) and a pond - which could potentially be transferred to the local community for management. Promoting walking and cycling to help reduce the need to travel by car, being well-located at the heart of the village, with a main walking/cycle link via the existing bridleway on to Bridge Street providing a direct link to Hampton Lucy C of E Primary School, St Peter’s Church and Boars Head public house. The site also benefits from further existing pedestrian links on to Snitterfield Street. Creation of an attractive new gateway into the village, reducing traffic speeds and extending the 30mph speed limit further north on Snitterfield Street. This scale of development would be able to support the viability of local services as NPPF79 requires – including Hampton Lucy C of E Primary School – as well as securing other funding and investment in local services and facilities where required. 9. The site is included on the interactive map of SHLAA sites from 2021 (site ref. 497) and has already been supported through the SA process informing the SAP, supported by HIA. The information enclosed within these representations provides further evidence on the site’s suitability and deliverability to help inform any further assessments via the SAP and SWLP process. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? 13. Yes, MSL agree that a threshold approach would be appropriate for any settlement not within the chosen strategy. This would ensure those settlements are able to plan for growth to meet their needs, particularly those settlements within designated neighbourhood areas in accordance with NPPF66. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 14. Any limit on the size of site should have regard to the factors set out in NPPF67, namely local housing need, population of the area, and the strategy for the area. Other factors should also be taken into account such as the availability of suitable land, proximity to nearby towns, or scale of local employment opportunities. Therefore, the threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
Q-H1-1: HEDNA and housing requirement 10. The provision of a sufficient level of housing growth in the SWLP is required in national planning policy, specifically NPPF11(a) and (b). The SWLP Issues and Options is informed by the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). This identifies a need for 868dpa for Stratford District and 811dpa for Warwick District, equating to 1,679dpa for the SWLP area. Over the 28-year plan period to 2050 this is a requirement for 47,012 dwellings. 11. Nevertheless, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national policy and guidance (NPPF61 and NPPG0102). 12. Further consideration will also need to be given to unmet needs of neighbouring authorities in line with the Duty to Cooperate and the positively prepared test of soundness (NPPF35a). We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country.
Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan? 15. Yes, MSL support the allocation of other sites as necessary for short-term development. These sites should include those proposed to be allocated as reserve sites within the Site Allocations Plan, such as MSL’s site at Hampton Lucy: Policy HAMP.A. The site’s suitability, availability and deliverability has therefore been assessed, and found to be acceptable. The site is to be released for development when required by the District Council. The requirement to allocate sites through the South Warwickshire Local Plan should be the trigger to release the reserve sites within the Site Allocations Plan, and this should be confirmed within the South Warwickshire Local Plan Part 1 Document.