Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy?
In more general terms, the Settlement Analysis (like the other technical documents) has been conducted ‘blind’ to whether an area is in the Green Belt or not. Chapter 2, para 2.2, page 6 states that “The premise of the study is to identify the opportunities and constraints for growth in and around the settlements.” The analysis then undermines its own premise by ignoring the massive constraint that Green Belt land rightly places upon development: “the analysis has been undertaken irrespective of whether the settlement is within the green belt – it is simply the physical attributes of the settlements.” Although it does acknowledge the “strong national policy designation” for Green Belt where “any incursion would require thorough examination and robust justification” the analysis is flawed because this fact is not even mentioned in the analysis of those settlements which are in the Green Belt. In addition, it only analyses the existing settlement, rather than the proposed extension areas, many of which spill into Green Belt land.
In more general terms, the Settlement Analysis (like the other technical documents) has been conducted ‘blind’ to whether an area is in the Green Belt or not. Chapter 2, para 2.2, page 6 states that “The premise of the study is to identify the opportunities and constraints for growth in and around the settlements.” The analysis then undermines its own premise by ignoring the massive constraint that Green Belt land rightly places upon development: “the analysis has been undertaken irrespective of whether the settlement is within the green belt – it is simply the physical attributes of the settlements.” Although it does acknowledge the “strong national policy designation” for Green Belt where “any incursion would require thorough examination and robust justification” the analysis is flawed because this fact is not even mentioned in the analysis of those settlements which are in the Green Belt. In addition, it only analyses the existing settlement, rather than the proposed extension areas, many of which spill into Green Belt land. Finally it is inaccurate to say that “this matter will be explored further in the Issues and Options consultation.” It is dealt with only summarily in Section S6 and no consultation question is posed so there is no opportunity for stakeholders to comment directly.
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The 20 minute neighbourhood is a flawed concept. Shipston on Stour can never meet this criterion in large areas of the Parish, following the last five years of new development. It obviously is not s concept that can be 'retro-fitted'.
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It is noted that the Landform Analysis example (Figure 9) includes Flood Zones 2 and 3. These zones represent only part of the picture when it comes to understanding the constraints of flood risk on new development. Flood zones show the risk of flooding from rivers only. Flood risk from surface water is the biggest risk of all and our view is that it should be included in constraints mapping alongside flood risk from rivers. The NPPF Para 160 states “strategic policies should…manage flood risk from all sources”. Furthermore, including surface water in constraint mapping would align with the emerging Level 2 SFRA. Nationally consistent surface water flood mapping is available on the gov.uk website, similarly to the flood zones, here: https://check-long-term-flood-risk.service.gov.uk/map
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We support that Radford Semele is a sustainable and well-located settlement to accommodate additional growth. This aligns with the SWLP which seeks to maximise the capacity of its existing urban areas in order to meet development needs of the plan period. Radford Semele provides for a strong level of services and facilities and is well connected in terms of sustainable transport connections. Radford Semele is identified under Table 2 as a settlement which was subject to connectivity, accessibility and density analysis. The South Warwickshire Settlement Analysis 2023 identifies Radford Semele as a ‘smaller settlement’. Of the available land around the existing built-up edge of the settlement, land at Radford Semele is identified to have a connectivity grade of B, which is only matched by one other site to the south east of the settlement. Grade B is shown to connect to at least one brown route or at least on ready route, there is also an existing or potential active link, e.g., via green/blue infrastructure or other active links. The land at Radford Semele runs along a Primary Street through the settlement. Given the above context, we support that Radford Semele should be considered as a contributing settlement as part of the overall growth strategy.
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Kingswood/Lapworth Settlement analysis is not wrong but is incomplete and potentially misleading. There are multiple reasons why development around Lapworth Station on any large scale would be wrong, not least because there are very few trains, the area has poor road connectivity with major arteries and employment, there are no (1) shops, has old and creaking infrastructure already, and is absolutely nothing like a 20 minute community
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The Accessibility analysis uses the term Mitigate as a solution to lessen the impact of particular effects. In a number of cases, this term seems to have been used without a solution in mind, and in several cases mitigation would not be possible, or would be economically unviable. The appraisal does not appear to consider where people will travel to, the volume of travelers, and the potential / viability of amendments to transport infrastructure required. Furthermore, it scores potential development sites based on issues such as distance from existing bus stops, without consideration of how easy it would be to change a bus route between now and 2050, and uses the word mitigation liberally, without consideration of the cost or practicality of transport infrastructure required in and around Stratford-upon-Avon. A specific example of where major infrastructure needs to be planned and financed, before locations can be unlocked for development, is land south of the River Avon. This applies both to the new settlement shown in all options and to any development on the edge of Stratford south of the river. The Clopton Bridge is now at capacity and studies have shown that it would not be able to accommodate the associated increase in traffic. Land in these areas should not be earmarked for development, even at a strategic level, without first addressing the viability and impact on residents of associated infrastructure which is likely to include extensive civil engineering.
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The following comments are made in respect of land off Collingham Lane, Long Itchington. The site lies within Area 11 within the Settlement Design Analysis. In respect of Connectivity, the Area has been assessed as ‘B’. This is defined as having negligible barriers that are easily overcome. The commentary in the Analysis states that Collingham Lane narrows to a single track after first sharp bend. This bend is beyond the edge of the village and would not be a barrier to development within Area 11. Reference is also made to it being a fairly busy road, however suitable and safe access can be provided onto this residential street. As Collingham Lane, is capable of accommodating all modes of transport, there are no barriers to connectivity to the settlement and this should be rectified in the next iteration of the Analysis to a score of (A). In the analysis of landform, there are no constraints, unlike the majority of the western side of Long Itchington which is covered by a flood plain. Therefore growth to the north of the village is supported in flood risk policy terms, with the area being sequentially preferable. In respect of local facilities within 800m, Area 11 scores very well with the site scoring 4 out of 5, only marked down for healthcare due to no facilities within the village at present. Areas 14 and 15 have been scored as 5 out of 5, however these sites appear to have been incorrectly scored as they are not within 800m of healthcare facilities either. The analysis should therefore be updated to reflect this. Area 11 is therefore considered a suitable location to accommodate development as there are no barriers to connectivity to the village, and the site is within 800m of a good range of local facilities. It should also be noted that Stratford-on-Avon District Council scored the Collingham Lane site (LONG.04) positively within the SHLAA 2021 update. The SHLAA concluded that site was ‘likely to be deliverable’. This is supported by the draft allocation of the site within the Site Allocations Plan Revised Preferred Options Consultation (June 2022) for 10 self-build and/or custom-build housing under Proposal SCB.5: North of Collingham Lane, Long Itchington. An Outline Planning Application was submitted to Stratford-on-Avon District Council in September 2021 for up to 9 self-build/ custom build dwellings and a new vehicular access from Collingham lane. The application was refused at Planning Committee on 22nd June 2022, with the decision contrary to the officer’s recommendation to grant permission. In response to the refusal of permission, Rosconn Strategic Land are preparing a revised application for a reduced number of units to address the reasons for refusal outlined above, and compliant with draft policy SCB.5 – land north of Collingham Lane. Paragraph 141 of the NPPF states that before changes are made to Green Belt boundaries, the LPA will need to demonstrate that they have considered all other reasonable options for meeting its identified need for development. LPA’s must therefore demonstrate that they have made use of suitable and underutilised land before Green Belt land is released. Land off Collingham Lane, Long Itchington, should therefore be given priority as this land is outside of the Green Belt and is considered to be a deliverable site to help deliver homes within the plan period.