Issue and Options 2023
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New searchBloor Homes consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and Bloor Homes consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
Harbury is excluded from consideration in the Sustainability Appraisal. Bloor Homes Midlands consider that Harbury should be identified in the next iteration of the SA as a Small Settlement Location (SSL). It is noted that there are a number of SSLs identified which are Category 1, 2, 3 and 4 Local Service Villages in Stratford-on-Avon, but not Harbury which is a Category 1 Local Service Village in the adopted Core Strategy. This is an inconsistent approach, and Bloor Homes Midlands considers that, at a minimum, all Category 1 Local Service Villages in Stratford-on-Avon should be included in the Sustainability Appraisal as a SSL, including Harbury. Settlements at this level of the hierarchy should make a notable contribution towards meeting housing needs, and therefore should be included in the SA. The Councils will need to be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations.
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The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF . The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, Bloor Homes consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF. In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF.
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The village of Harbury has not been included within the Settlement Analysis evidence supporting the South Warwickshire Local Plan, and this should be rectified in the next iteration of the analysis. The Settlement Analysis states that it focuses on the first and second tier settlements, with a number of additional settlements also identified and assessed. This includes a range of Category 1, 2, 3, and 4 Local Service Villages in Stratford-on-Avon, but not Harbury which is identified as a Category 1 Local Service Village in the adopted Core Strategy. Harbury should be included in the next iteration of this analysis given its size, range of facilities, and status as a Category 1 Village. It is a suitable location to accommodate growth commensurate with its size and facilities, and therefore it should be assessed. In the absence of any analysis, the following comments are therefore made in support of growth at land at east of Harbury (site 377). In terms of connectivity, the site is adjacent to the eastern edge of the settlement and bordered by the B4452 and Butt Lane. Both routes can accommodate all modes of transport. There are therefore no barriers to connectivity with the settlement. In fact, the ability to connect with Vicarage Lane provides a direct route into the centre. In terms of landform, there are no constraints on the site. Furthermore, it will be noted from the Council’s 2012 Landscape Sensitivity Assessment that site 377 is considered high/medium landscape sensitivity equivalent to the best performing parcels around the village. In terms of local facilities within 800m, the village church, shops, playing fields, and village hall are all within 800m. The primary school and doctors surgery is just beyond 800m but within reasonable walking distance. In more detail, this area has the greatest potential to accommodate development without harming the existing residential areas given the separation afforded by Butt Lane. Its location also means it is unique in being able to route traffic to both the M40 and Leamington (via Chesterton Road to the south and Harbury Lane) avoiding the village centre. It also has the potential to offer land to enhance village facilities and services. When taking account of the evidence above, site 377 is a suitable location to accommodate an allocation, as there are no barriers to connectivity to the village, no constraints, and facilities are available within 800m. In light of the potential of this site to contribute to meeting development needs over the Plan period in a sustainable location outside of the Green Belt, we respectfully request the site be allocated within the South Warwickshire Local Plan.
The potential for a new settlement at Harbury is noted, and F1 (North of Harbury) performs relatively well compared to the other options in the SA. F1 is indicatively shown in the SA as a broad area, but clearly the size and location of growth at Harbury would need to be explored in more detail if this area were to be identified to accommodate significant growth in order to support a new rail station. Bloor Homes have therefore submitted with these representations a Wider Masterplan showing how circa 1,000 homes and associated land uses and green infrastructure could be accommodated within the entire area of land put forward through the call for sites (site 377). Whilst this site in isolation would not support a rail station, it clearly could form a component of a larger site including land north of Harbury which delivers 6,000 dwellings, or one of a number of different sites in the nearby villages and towns (including Gaydon and Southam) that cumulatively deliver up to 6,000 dwellings. This larger proposal using all of site 377 could therefore form an important component should the Councils decide F1 should be part of their growth strategy taken forward in the Plan.
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? Without knowing the chosen strategy, it is difficult to answer this question. However, yes, Bloor Homes agree that a threshold approach would be appropriate for any settlement listed within Option 5 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? 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 size and availability of suitable land identified. The threshold should not be set at a fixed figure but should be flexible to respond to the circumstances of the settlement.
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