Revised Development Strategy

Object

Representation ID: 55399

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Question why the Council has consulted on the RDS at this stage (on basis of interim housing figures) , rather than waiting for the updated SHMA to be completed? Reserve our right to comment on the revised housing figure when the new SHMA is published later in 2013 and encourage the Council to formerly consult once again at that time.

Object

Representation ID: 57010

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

The 'interim housing figure' set out in the RDS policy RDS1 fails to meet the full need in the housing market area.

There is also no rationale or evidence as to how the housing figure has been arrived at and why the higher figures set out above and in the evidence base have been rejected.
Moreover the 2012 SHMA is not NPPF compliant in that it only assesses housing and employment growth within Warwick District and not the wider housing market area. The final housing figure should await the findings of the 2013 update to the SHMA.

The housing numbers fail to refer to the need for a 5% or 20% buffer on the overall housing figure and as such is contrary to NPPF (para 47).

Choosing a housing figure that fails to meet the identified housing need in the area, along with the current five year land supply shortfall will result in an unsound plan. The NPPF requires a flexible approach in such instances to boost significantly the supply of housing.

Object

Representation ID: 57012

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

The plan period is confusing in that the 2012 SHMA refers to a 20 year period (2011 - 2031), the RDS document refers to an 18 year period (2011-2029) whilst the introduction to the RDS refers to a 15 year time period.

The NPPF (paragraph 157) refers to a need for plans to be drawn up over an appropriate timescale "preferably a 15 year time horizon" and also to "take account of longer term requirements." This approach is supported by the evidence in the SHMA that refers to evidence of growth over the longer time period up to and post 2031.

Given the on-going delays in the production of the Local Plan consideration should be given to extending the plan period accordingly. As such the housing figure would need to be increased to reflect the longer time period.

Object

Representation ID: 57013

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Generally support the Council's broad location of development in so far as it seeks to accommodate growth within and on the edge of the existing urban areas.

However, in order to accommodate housing where it is needed there will be a requirement to review Green Belt boundaries, especially around key sustainable settlements for example, Kenilworth.

In addition the need to identify "areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet the longer-term development needs stretching well beyond the plan period." (NPPF para 85) has not been addressed in any of the evidence base documents or the RDS.

In the case of Kenilworth, which is recognised as one of the most sustainable centres in the District, there will be a need to accommodate further growth beyond the current plan period.

For the reasons set out in the current SHLAA and at paragraph 4.3.12 of the RDS it is accepted that there are limited opportunities for growth within the existing built up area of the Town.

As such growth will have to take place on edge of the Town within the Green Belt. In such circumstances the NPPF requires that land be 'safeguarded' to avoid further reviews at the end of the development plan period (paragraph 85 NPPF).


Paragraph 4.3.12 of the RDS recognises the need to expand in to the Green Belt in Kenilworth due to the lack of non-Green Belt options. However, no justification has been set out as to why the "Land at Thickthorn" is the "least harmful alternative in terms of the purposes of Green Belt land."

Indeed, in the Joint Green Belt Review, January 2009, all of the land to the east and north-east of Kenilworth is identified as being 'least constrained'. Table 6 of the Joint Green Belt Review assesses the various sites and the land at Thickthorn is given the same score (8.5) as sites K17 and K19, referred to in the report as site K4.

The Landscape Assessment in the Green Belt Review gives the same score (1 - low value) to both Thickthorn and K17/K19) in landscape impact terms recognising that the A46 forms a definitive boundary to built development in this part of Kenilworth.

The more recent landscape assessment commissioned by the Council does not refer to land around Kenilworth at all.

The question of whether the proposed site at Thickhorn is the most sustainable option is questioned on the basis of the findings of both the initial SA (May 2012), and the Final Interim SA Report (June 2013)

Both sites are equally as sustainable with regard to the criteria set out in the NPPF. Transport and highway issues have been fully researched by highway consultants acting for client and has been found not to be a constraint to bring sites K17 and K19 forward.

Object

Representation ID: 57015

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

The broad location of housing set out at table RDS4 does not accord with the objectively assessed need evidence set out in the SHMA, May 2012 document

The spatial distribution should be amended to reflect the findings of the SHMA, 2012 and as more appropriately set out under the distribution Option 3 as considered in the housing evidence and Sustainability Appraisal, ie 1,260 dwellings to Kenilworth.

Support

Representation ID: 57016

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Support the principle of the distribution of housing to the east of Kenilworth. This in part reflects the need/demand findings of the SHMA. It also accords with the "golden thread" of sustainable development set out in the NPPF and the findings of the Joint Green Belt Review.

Object

Representation ID: 57017

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Object to the proposed allocation of land at Thickthorn, Kenilworth and also to the 700 dwellings proposed for following reasons:

Housing Number:
Object to the number of 700 dwellings to Kenilworth (see also objection to RDS4) . The final distribution should await the publication of the NPPF compliant update to the SHMA and joint working with neighbouring authorities. For this reason alone, the site area should be increased to include land at sites K17 and K19.
Capacity at Thickthorn:

* The land at Thickthorn (confirmed at 46.5 ha) is constrained by a number of factors that have been identified in detailed technical surveys that we have undertaken, including:

* the need for noise bunding due to proximity of the A46;

* ancient woodland;

* heritage assets - the Manor & Stables and Scheduled Ancient Monument;

* the need to replace two large areas of playing fields/sports grounds;

* the need for areas for water attenuation;

* proximity to existing housing; and,

* the presence of two local wildlife sites and the need to have 50m buffers around the sites and woodland.

Considers that the land at Thickthorn is not capable on its own of accommodating the proposed 700 homes. (Based on an assessment set out in the representation of the housing capacity of the site at different densities-allowing, for open space, community facilities, green infrastructure, education and employment requirements)

Stresses that the capacity figures are significant over estimates as many of the constraints on the site are greater than currently stated and the density figures are more likely to be around 25 - 30 dph for this site.

Furthermore, the clear view coming out of the public consultation carried out by Kenilworth Town Council on its Area Action Plan was that development should stop at Rocky Lane and that the current playing fields should either remain or the land given over for open space. This would further reduce the capacity of the site.

Playing Field/Sports Pitches:

The RDS acknowledges at paragraph 5.4.24 that the three playing fields/ sports pitches are a potential constraint to the development coming forward in its entirety.

Standing advice from Sport England is to object to the loss of such facilities unless suitable and convenient replacement facilities can be provided.

Sport England Require Local Plans to be justified with appropriate evidence. Aware that work on a Playing Field Strategy is on going but no timetable is in place for its conclusion. No informed decision can be therefore be taken on whether to include the playing fields until such a Strategy has been prepared and/or replacement facilities are provided in close proximity to meet the Sport England tests.

Encouragement for Sports Facilities

The Garden Suburbs prospectus encourage sports pitches/playing fields as part of a well planned, integrated, mixed use urban extension. It seems illogical to therefore move established facilities that are both convenient for local residents and ideally located to help plan a sustainable urban extension for Kenilworth.

Deliverability

Paragraph 173 of the NPPF confirms that "pursuing sustainable development requires careful attention to viability and costs in plan-making and decision taking. Plans should be deliverable."

The Thickthorn land is owned by several different landowners. There is no certainty that the land will come forward for development as a collective whole, as required to deliver the well planned and phased approach to development that is supported in the RDS and is essential for delivery of the key infrastructure required for the .

No assessment of the viability of the scheme has been made.

Alos, there are in consistencies between the requirement for 40% affordable housing on the site and the findings of the Warwick District Council Affordable Housing Viability Assessment Final Report, Nov 2011 that concludes that no development was viable at 40% affordable housing provision.

For the above reasons the allocation of the site at Thickthorn is uncertain and as currently drafted is unsound. Given the need to provide land for policy consider PO4 as it relates to Thickthorn is unsound.

Changes proposed to address the objection:

It is proposed that rather than looking at land at Southcrest and Woodside Training centre as different to Thickthorn, a comprehensive approach to the future growth at Kenilworth should be taken including all of the land to the east of the town.

This will enable:
* the principle of a Garden Suburb to be advanced.
* provide for retention and enhancement of the playing fields and provide expansion for employment uses close to the A46 junction.
* It will also enable greater mitigation in terms of noise and buffers around the ancient woodland and Scheduled Ancient Monument.

The above stance accords with the aims and objectives of sustainable development set out in the NPPF, that encourage longer term planning and the Garden City approach to development. The increased area of land would also enable the proposed housing numbers to be delivered and increase flexibility in the Plan. These changes would result in a sound strategy for development at Kenilworth.

Object

Representation ID: 57019

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Landscape Impact

Paragraph 5.4.22 of the RDS states that the Joint Green Belt review landscape assessment "recognised the Thickthorn area as being of relatively less quality than other areas on the fringe of Kenilworth".

Whilst this is true in relation to sites to the north, west and east of the Town, the land at K17 and K19 was found to be of equally low landscape value in the assessment (1 - low value). The paragraph should be corrected accordingly.

Object

Representation ID: 57020

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Whilst supporting the need to meet the housing requirement of the existing and future population of the District does not support the specific principle of only identifying land for around 683 new homes per year.

In addition, it is noted that there is no reference in any of the specific principles to the need to maintain and improve the quality and provision of sporting and leisure facilities in the District.

This was a key theme set out in the previous Preferred Options document and one that should be taken forward in the updated Local Plan as it is in line with advice produced by the Government and Sport England.

Object

Representation ID: 57021

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Paragraph 1.2 confirms the importance of taking account of the evidence and representations submitted on the Local Plan. To date the Council has failed to consider the fundamental issues that our Client's have raised regarding the deliverability of the land at Thickthorn. This includes issues regarding land ownership, collaboration, alternative playing field provision, the capacity of the land to deliver the required development at appropriate densities to reflect the Garden Suburbs approach and the site's identified technical constraints.

Concerned by the statement at paragraph 1.3 of the Strategy that the "housing growth requirements are unlikely to change substantially as a result of the new assessment." Whilst changes to housing requirements in Warwick District may not change, the need to accommodate housing growth from neighbouring authorities may.

Under the Duty to Cooperate, on going dialogue and active engagement is required. The implication of this may be a need to consult further, either on the updated housing figure or a completely revised development strategy. The Council should maintain a flexible and open mind to deal with any issues that may arise.