Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy?
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Q-S4.1 and Q4.2 20. As part of a sound spatial strategy there will inevitably be a need for growth to occur at existing settlements, including Smaller Settlement Locations and other settlements, which possess a range of local facilities and connectivity by sustainable/active modes of travel to other locations. Such settlements represent the most sustainable locations for growth. 21. Concerns about the settlement analysis and the SA have already been raised and are not repeated. However, it is worth noting that there is a balancing act required whereby some environmental concerns may need to be managed to deliver sustainable growth. Not everything needs to be fully protected provide suitable and appropriate mitigation is available. A finer scale settlement analysis is required than currently undertaken.
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3.2 There is concern regarding the methodology when selecting the settlements that form the settlement analysis. The study only considers those Main Town or Main Rural Centres within Stratford-upon-Avon or Urban Areas and Growth Villages within Warwick District. There is no clear justification as to why other category settlements have not formed part of the sustainability appraisal. 3.3 Long Marston is a category 4 village within the Stratford-upon-Avon Local Plan. Such settlements should provide 400 dwellings between them to assist meeting the housing requirement. This confirms that such settlements are capable of providing some growth, and the Council is seeking to ensure a broad distribution including such villages. Such villages could have the potential to bring forward a site of 50 dwellings. The sustainability appraisal should therefore be widened to assess villages such as Long Marston. The village can also support the new developments at the Airfield and Meon Vale, which again are not being considered within the sustainability appraisal.
The local plan is a plan for the whole of the plan area which by definition includes the existing development including settlements of all sizes. This is important because a local plan is for the whole area and new development forms a relatively small proportion of the whole. It is a matter of some concern that that a decision “to maximise the capacity of its existing urban areas in order to meet development needs to 2050” has apparently already been taken. This undermines the consultation by suggesting predetermination of the preferred strategy. The concept of the 20 Minute Neighbourhood (based on a 10 + 10 minute walk there and back) seems rather idealized and not especially effective for a plan area that includes an extensive mix of settlement types across both urban and mainly rural landscapes. There are many smaller settlements and groups of settlements where services could be protected or enhanced through a more dispersed pattern of development and the strategy should allow for a level and distribution of growth that takes account of this. The Connectivity Analysis and Density Analysis have produced a significant amount of information but the extent to which these can help to inform the strategy in the plan is less clear. The landform analysis is clearly helpful in helping demonstrate land where new development should generally be avoided.
Henley in Arden apparently has a projected 500-2000 homes in the SWLP. This growth is very much out of proportion with the existing size of the local population. Henley is certainly unsuitable for growth over 500 houses due to flood risk, poor infrastructure (sewage and drainage at capacity, schools and GP services full, congested road, scanty train and bus services) additionally Henley has already far exceeded the projected settlement growth planned up to 2031 in the Henley Neighbourhood Plan. More information needs to be collated to inform the SWLP how much additional housing Henley could reasonably absorb, with or without improvements in infrastructure
Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land.
3.19. Welford-on-Avon is not included in the settlement analysis. It should be included in this assessment as the evidence base evolves to support the Plan.
Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land.
Growth of existing settlements should only be considered where it does not require development in the greenbelt. Previous growth of existing settlements in non-greenbelt locations should not prevent further development and infrastructure should be invested to support further non-greenbelt development. Where growth of existing settlements cannot be assured without using greenbelt land, alternative solutions should be considered that do not involve development in greenbelt land.
I support the inclusion of land at Royal Leamington Spa East as a Broad Location for residential development. It would promote a sustainable pattern of development and make a significant contribution to meeting local housing need. The Broad Location should be extended to the boundary with Newbold Comyn, as shown by the area coloured red on the attached plan. By extending the boundary the Country Park can be extended and better integrated with the new community. There will be opportunities to create more natural surveillance of the edges of the park and green infrastructure through the residential development and connecting to the communities at Lillington and Cubbington. I consider that The Connectivity Analysis has incorrectly assessed the Areas (6 and 7) of North Leamington and Cubbington. The assessment has failed to reflect that any barriers to connectivity can be overcome through the creation of new accesses, which are feasible and deliverable. The area also connects to at least one red route, which is less than 50 metres from the Site and a brown route being within walking distance. There are also existing and potential active links with the current PRoW available connecting to the wider network. There is also the opportunity to create a new routes through the Broad Location to the Country Park and wider cycle and pedestrian network. The area should correctly be assessed as a Grade B for connectivity.
3.20. The Site [south of Banbury Road, Ettington) falls within Stratford Northwest for the purposes of the Settlement Design Analysis which forms part of the Council’s evidence. The site is within Parcel 1. It scores a B in terms of accessibility (green) which is the joint highest score within this analysis area. It is note identified as having any landform constraints. It has retail, jobs, economy, places to meet and open space, leisure, recreation and wellbeing within 800m of the site. The density map does not reflect the existing residential development to the south of this Site. The plan should be updated to include this.
Issue S4: Growth of existing settlements The Issues and Options document confirms that “The South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet our development needs to 2050”. The SWLP has considered potential growth of certain existing settlements. It is appropriate to consider the potential for growth in the existing settlements. The Issues and Options SWLP has initially considered Connectivity, Accessibility, Density and Local Facilities through the Settlement Design Analysis. Wood End is included on the list of settlements and locations subject to connectivity, accessibility, and density analysis. In relation to Wood End, the Landform Analysis shows that growth is limited in this location due to the Ladbrook Park Golf Club to the west and topographical issues to the east. There is a small amount of flood plain which follows Spring Brook. The Connectivity Analysis grades land to the north of Wood End (identified as 1B) as B (on a scale of A-E. This is joint first of the 8 locations assessed. We agree that this location is very well connected. The site submitted as part of these submissions is located a 500m walk (6 minutes) from the existing Wood End Railway Station. This station offers an hourly service between Stratford and Kidderminster. The service towards Kidderminster stops at Birmingham Moor Street and Birmingham Snow Hill, taking only 32 minutes (to Moor Street) and 35 minutes (to Snow Hill). Furthermore, this is a local service and stops at the majority of stations enroute, therefore offering access to other facilities in nearby villages and towns. The connectivity analysis provides the following comment on area 1B: “Proximity to Train station which would provide sustainable mode of transport”. The analysis does provide comment on ‘Barriers’, which is stated as “Wood End Lane is very narrow and not suitable for two passing cars in its present state”. Wood End Lane is not intended to be the primary access but could be used to provide secondary access (by foot, cycle and vehicular). The principal access (pedestrian, cycle and vehicular) is provided via The Common, which has an existing footpath to the edge of the site boundary leading to both railway platforms and beyond. The Local Facilities Review shows that all areas of Wood End have a very similar level of access to facilities (Healthcare and Places to Meet). Only one location (location 5B) offers access to more than two facilities (Open Space, leisure, recreation – wellbeing). We would like to point out that Ladbrook Park Golf Club is an 850m walk (10 minutes) from the site, so whilst being 50m in excess of the 800m threshold, this distance is not significantly more to travel and would be realistically possible for the majority of people. In our view, utilising land west of The Common, Wood End would tie into the 20 minute neighbourhood principles which the SWLP is seeking to implement.
Kenilworth cannot sustain any more housing growth. The infrastructure will not sustain it. The town centre cannot serve it, the health facilities are not adequate; there will be a risk of flooding from inadequate drainage, green spaces will be swamped or have housing built on them; allotments will be lost; the greenbelts will be damaged and narrowed. The housing will serve jobs in neighbouring towns not Kenilworth, and so will not be good for climate.
3.19. Harbury is not included in the settlement analysis. It should be included in this assessment as the evidence base evolves to support the Plan.
Appendix 2 (Connectivity Analysis for Henley-in-Arden) of the Settlement Analysis indicates particularly poor connectivity to the west, north-east and east of the town which the Respondent would agree with. In respect of land to the north of the town, it is the Respondent’s view that this land should not be graded as high as it has, particularly considering the influence of the dismantled railway embankment that acts as a permanent, physical and visual barrier to rest of the town. If land to the north has been accurately Graded as ‘C’ then, in the Respondent’s view, land to the south should, in turn, be accorded a higher grade (B) in recognition of the absence of any such physical barrier. The respondent also draws attention to the error in the Henley-in-Arden Density Analysis which indicates an area of Green Infrastructure as an ‘Urban Neighbourhood’. There are also notable inconsistencies between the density assumptions made in the settlement analysis versus those made in the Urban Capacity Study; a rationale for which should be provided for the avoidance of doubt.
Issue S4: Growth of existing settlements The Issues and Options document confirms that “The South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet our development needs to 2050”. The SWLP area includes nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-on-Stour, Southam, Stratford-upon-Avon, Warwick and Whitnash). The SWLP has considered potential growth of their existing settlements. It is appropriate to consider the potential for growth in the existing settlements. The Issues and Options SWLP has initially considered Connectivity, Accessibility, Density and Local Facilities through the Settlement Design Analysis. In relation to Henley-in-Arden, the Landform Analysis shows that there are limited directions for growth in Henley-in-Arden, owing to constraints such as green infrastructure, topography and Flood Plain. The Landform Analysis suggests that west of Henley-in-Arden and north of Henley-in-Arden are the only locations which are landform constraint free. The Connectivity Analysis grades land to the west of Henley-in-Arden (identified as 1D) as D (on a scale of A-E. However, the connectivity analysis has failed to properly assess the existence of an important footpath underneath the railway (via an underpass) which provides additional walking and cycling connectivity to land to the west of Henley-in-Arden which has been missed in the analysis. As a consequence, the results of the Connectivity Analysis are flawed. We understand that this footpath has been discounted because the existing pathway heads into open countryside and would not currently be used for connectivity within the settlement. However, this conclusion is unreasonable and fails to consider the potential for enhanced accessibility that the existing footpath provides. This is a key oversight which influences the conclusions of the connectivity analysis. The footpath unlocks access to the west of Henley, and in our view, to an extent provides some resolution to the physical barrier of the railway line, you have identified. We consider that it is therefore extremely important when considering connectivity and the potential for future growth in Henley-in-Arden, to include consideration of the underpass within the analysis. The footpath underneath the railway (via an underpass) provides additional walking and cycling connectivity to land to the west of Henley-in-Arden, the importance of which has been misrepresented in the analysis. The footpath connection to the site from Brook End Drive has a minimum width of 1.5m, connecting to the site through the railway bridge underpass. This pathway could also be resurfaced and lit as part of any proposals at the site. Brook End Drive provides direct access to Henley-in-Arden Railway Station, a 450m (5 minute) walking distance from the eastern site boundary. This route provides step-free access to the railway station and the eastern platform. Not including the pathway is a key oversight to the connectivity conclusions, which are therefore flawed. We consider that this pathway should be included within the connectivity analysis. In our view inclusion of the footpath to the underpass would change the conclusions of Area 1D to the west of Henley-in-Arden, within the connectivity analysis. We consider that this pathway should be included within the connectivity analysis, and moreover, when assessed correctly, including the underpass access, land to the west of Henleyin-Arden would score a higher grade. The Local Facilities Review shows that west of Henley-in-Arden is well connected in terms of facilities. The review confirms that within 800m there is access to Retail, economy, employment, places to meet, open space and leisure, health care and education. This ranks equal first in comparison with the other directions for growth. Utilising land to the west of Henley-in-Arden would tie into the 20 minute neighbourhood principles which the SWLP is seeking to implement. In addition to the Settlement Design Analysis, the Urban Capacity Analysis confirms that there is limited scope for town centre residential development.
Within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment” we have concerns that the Village of Broom settlement (located within the western part of the Stratford-on-Avon District) has been recognised as having high historic environment sensitivity. We would strongly object to these planning policy assumptions. We object to the continued poor quality of the evidence base being used to support Local Plan-preparation. Furthermore, in order to deliver “a More Positively Prepared Local Plan” in accordance with the tests of Local Plan Soundness as reinforced within paragraph 35 (indent a) of the Revised NPPF (2021), the Council’s preparing the emerging SWLP (2023) should not view heritage designations as a site constraint to prevent new housing-led development proposals from coming forward. Given that high-quality new residential development schemes incorporating good architectural design features, and use of appropriate and sympathetic types and colours of building materials in external facing building facades (which remain sympathetic to preserving a proposal sites historic surroundings), can all help to improve the historic setting, appearance and character of both Statutory Listed Buildings (such as Grade II Listed buildings), and adjacent Conservation Areas. Historic environment focused guidance in the Revised NPPF (2021), positively encourages new development proposals which seek to enhance the character and setting of the historic environment. This is confirmed in paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021), which both strongly encourage new development proposals which seek to “…make a positive contribution to local character and distinctiveness…” The presence of heritage designations should therefore not be viewed as a site constraint, to prevent future new housing development sites from coming forward within the emerging Local Plan area. We have concerns that the historic environment policies being taken forward within the emerging SWLP Review are unduly onerous, highly restrictive, are not sufficiently robust, and lack sufficient ambition, and therefore fail to reflect the above NPPF guidance. As already stated within our wider Representations within this Local Plan Representation, it is important that any heritage designations and any heritage assessments being used by Local Planning Authorities to inform future Local Plan preparation work are supported by a sufficiently robust and defendable platform of up-to-date evidence - consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 192 of the Revised NPPF (2021).
Henley in Arden apparently has a projected 500-2000 homes in the SWLP. This growth is very much out of proportion with the existing size of the local population. Henley is certainly unsuitable for growth over 500 houses due to flood risk, poor infrastructure (sewage and drainage at capacity, schools and GP services full, congested road, scanty train and bus services) additionally Henley has already far exceeded the projected settlement growth planned up to 2031 in the Henley Neighbourhood Plan. More information needs to be collated to inform the SWLP how much additional housing Henley could reasonably absorb, with or without improvements in infrastructure
There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire. 3.17 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 3.18 At the local level, RPS notes Table 2 of the IO document which lists a number of existing settlements identified in adopted plans across South Warwickshire. These include Southam. The settlement has been subjected to separate connectivity, accessibility and density analysis, which RPS responds to question Q-S4.2 under section 6 of this submission. Sustainability Appraisal (SA) has also been carried out on the broad locations within which the settlement is situated, and a response to the SA is provided in section 5 of this submission to question Q-I1. 3.19 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). 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, potentially alongside and in combination with other options such as new settlements (see Issue S5).” (RPS emphasis) 3.20 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire District in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites are concerned these can deliver a steady quantum of development over a period of time in order to help maintain delivery against the targets in the SWLP. REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 3.21 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, including Southam, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives.
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.
Sir Thomas White's Charity and The King Henry VIII Endowed Trust, Warwick control land between Lillington and Cubbington. The land has been put forward through the Call for Sites and given reference 97, Glebe Farm, Cubbington. Adjacent site 191 Land Adjacent Bungalow Farm, Cubbington, is also available. Detailed information was submitted as part of the Call for Sites which indicated the site was suitable for development within the next 5 years. Independently prepared highways and landscape reports confirmed the site had good connectivity and could be developed without harm to the wider landscape, the area effectively being screened from wider view by existing developments. The site is assessed in several of the background evidence document. The following considers the key points raised. The site does not contain any heritage assets and, subject to appropriate design, development would not cause harm to those heritage assets lying beyond the site; The site does not suffer from any flooding concerns; This site has good access to a full range of everyday services and facilities including shops, schools and employment opportunities; It scores 4 as a connectivity grade, but this can be improved through development with the provision of enhanced bus services associated with a 2000 dwelling development; Development has the potential to increase in GHG emissions, but this is no different to all other broad locations for development; The site fits well with the 20 minute neighbourhood concept which aims to reduce the need to travel and thus the impact on carbon footprint here would be lower than in many others; Development will not cause harm to any biodiversity, flora, fauna or geodiversity assets; The Council assessments indicate development may cause slight harm to the setting of Newbold Comyn Country Park, but concludes that this can be mitigated through the use of landscape led design practices. The same conclusion is drawn regarding public rights of way which cross the site where again this can be mitigated through careful design. The site is located in the Dunsmore Character Area and Council's report indicates that development could have a minor negative impact on the landscape. The owners own appraisal (submitted as part of the previous Call for Sites) does not agree with this and in any case any potential harm can be mitigated through the use of landscape led design; Development will not lead to coalescence of settlements - indeed this parcel of land is already viewed as part of the settlements; The Council identifies the land as being Grade 2 and 3 land whereas the owners appraisal indicates a mix of grade 3a and 3b. It is probable there will be some loss of higher grade agricultural land but this can be minimised by careful positioning of open spaces. Loss is inevitable to provide sufficient land for development to meet the needs arising during the Plan period. Taking these points together the site scores well in the sustainability appraisal and is an ideal location to accommodate development as an urban extension.
3.18. Sherbourne is not included in the settlement analysis. It should be included in this assessment as the evidence base evolves to support the Plan.
3.20. Long Itchington is assessed as a whole for the purposes of the Settlement Design Analysis which forms part of the Council’s evidence. The site is within Parcel 8. It scores a B in terms of accessibility (green) which is the joint highest score within this analysis area. It is not identified as having any landform constraints. It has retail, jobs, economy, places to meet and open space, leisure, recreation and wellbeing within 800m of the site. The density map identifies the existing residential development on Leamington Road as either Inner Suburb (40-60 dph) or outer suburb (20-40 dph). It is likely that this site would reflect outer suburb densities.