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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Cubbington and North Leamington It is considered that the whole process of connectivity including both the accessibility mapping and local facilities within the Settlement Analysis report is over simplified and does not look holistically at a site or its location. The assessments need to be applied carefully and not be too prescriptive as some sites may have multiple facilities just beyond the 800 metres (20-minute walking time) and could still be sustainable locations for new housing. We specifically object to the Connectivity Analysis for Areas 9, 10 and 12 in Cubbington and North Leamington which incorrectly categorise Call for Sites References 174, 210 and 211 as Grade C. Within the Settlement Analysis Report Grade C is described as having: “barriers may be overcome, but not easily. Connects to: - one brown or red route - potential for connecting existing cul-de-sacs or loops into new red route - active links (e.g. via green / blue infrastructure or other active links) are possible but not easy It is noted that Areas 9 and 10 are bounded by primary roads on all sides. The assessment comments for Areas 9 and 10 state that there is an existing footpath to the east and west. It is noted that a public right of way (132/W206/1) runs through Call for Sites Ref 174 which forms an active link from Westhill Road to Leicester Lane. Based on the above, the analysis should be amended from Grade C to Grade B as any barriers are negligible or easily overcome; the site connects to a brown route (primary street); and there is a strong existing active link within both Areas 9 and D and in close proximity to Area 12.
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It is very confusing, and actually difficult, to use all the multiple links for this section, so difficult to comment. We note some transcription error in the Barford Sensitivity assessment and consider the RASG grading far too simplistic for this purpose.
Question S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.2 Yes, growth of settlements within and adjoining the South Warwickshire area boundary should be part of the overall strategy. 3.3 The Issues & Option states the following: “… 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” 3.4 The growth of some existing settlements offers the realistic prospect of meeting local housing needs and achieving the delivery of sustainable development. 3.5 Although the settlement boundary of Hockley Heath lies within a different administrative area (i.e. Solihull metropolitan borough), “the edges of the existing settlement” to its east represent the boundary between SMBC and WDC. 3.6 In line with the Issues & Options it is prudent for the SWLP and its evidence base to explore the potential for growth around the eastern edge of Hockley Heath as it is this land that lies within South Warwickshire. 3.7 Hockley Heath is such an existing settlement that is or can be made capable of accommodating housing growth to support the local housing needs of South Warwickshire and those unmet local housing needs from the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) over the respective plan periods of 2050 and 2040. This is evident by Hockley Heath being identified as an existing settlement in the emerging Solihull Local Plan (which is currently subject to examination) for proposed housing growth over a plan period to 2036/37. 3.8 The administrative boundary should not be considered as a constraint to development nor should it act as a barrier to consider sustainable growth options on land within South Warwickshire but abuts existing settlements in neighbouring authorities. At paragraph 660 of the Solihull Local Plan Draft Submission Plan (October 2020), SMBC recognises the administrative limits of growth at Hockley Heath: “Due to the proximity to the Borough boundary, future expansion of the settlement within Solihull Borough is limited and largely restricted to the north and west of the village.” 5 3.9 The exploration of spatial growth options on land around existing settlements in neighbouring authorities is not unique. There are many Local Plans across the country which has allocated housing development on administrative boundaries, most notably including WDC on land adjoining Coventry City; Bromsgrove District Council on land adjoining Redditch; and Lichfield District Council on land adjoining Tamworth. 3.10 Whilst Hockley Heath is not assessed in the majority of technical assessments undertaken to date, it is assessed in the Bus Accessibility Mapping as being within 15- 30 minutes bus travel time of major and minor towns, employment centres, GPs, dentists and pharmacies, and secondary schools and colleges. 3.11 In turn, it is recommended Hockley Heath is assessed via the sustainability appraisal process and addendums are produced to include the settlement in the Settlement Design Analysis (January 2023) and Heritage and Settlement Sensitivity Assessment (September 2023). It should be assessed in all new commissioned technical assessment from hereon in during the plan-making process. Question S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on 3.12 As described and explained in our response to Question S4.1, Hockley Heath is currently omitted from the settlement analysis. However, it should be included to understand the spatial growth option of new housing on land to the east of Hockley Heath, which lies within South Warwickshire. 3.13 In high level terms, using the methodology in the settlement analysis, land east of Hockley Heath, if included, would perform as follows: • Connectivity: Grade B • Landform: Slight and outside Flood Zone 2 and 3 • Accessibility: Total number of categories – 4 3.14 This high-level assessment supports the consideration of a spatial growth option to direct new housing to Hockley Heath to address the local housing needs and unmet housing needs of South Warwickshire and the GBBCHMA respectively.
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Q-S4.2: Settlement Analysis 29. The following comments are made in respect of HLM’s site reference 103, which is referenced as Area 7 and 8 within the South of Coventry Area. 30. In respect of Connectivity, it is noted the only barriers listed are the railway between Areas 7 and 8, and HS2 to the south. The Transport Authorities for the area have consulted on a new A46 Strategic Link Road within the HLM site that would provide a new crossing over the railway. Connectivity across the railway can be overcome and is envisaged by the Transport Authorities. HS2 to the south is not a barrier to connectivity to the South of Coventry, and therefore not considered relevant. Importantly, there are no barriers between the site 103 and the urban area of South Coventry. 31. In respect of Landforms, no account is taken in the assessment of the planned services at Kings Hill SUE. Unless there is evidence this development which has planning permission is not to be delivered, then it should be taken into consideration when assessing sites otherwise opportunities will be missed to locate development near to planned infrastructure and facilities. 32. Paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The assessment should therefore be amended to take into account the planned facilities at Kings Hill SUE. 33. A comment is made in the Connectivity Section that the area would erode the separation between Coventry and Kenilworth at its narrowest point. This comment does not appear to be relevant to the Connectivity Assessment, and in any event is inaccurate as the narrowest point would not be eroded. 34. It is noted the Councils are to undertake a review of the Green Belt to assess whether there are areas which no longer meet all five of the Green Belt purposes and could be removed. HLM have submitted with these representations an assessment of its site against the five purposes of the Green Belt, and it is requested this is taken into account when the Councils undertake their assessment. 35. In summary, the extent to which site 103 contributes to the purposes of the Green Belt and preventing neighbouring towns merging is diminished by the construction of HS2, the planned construction of the A46 Strategic Link Road, and the planned woodland belt that will be planted along these two infrastructure corridors. These works will create a sizeable and strong defensible boundary between the settlements of Coventry and Kenilworth, and the narrowest part of the gap between the two will not be eroded as illustrated within the assessment provided by HLM. 36. It is important also that any assessment has regard to paragraph 142 of the NPPF, and the need to give first consideration to previously developed land and/or land well served by public transport, and also to take into consideration the ability to offset any removal through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. HLM’s proposals as illustrated within the Vision Document for site 104 show how compensatory improvements are proposed to the environmental quality of land north of Kenilworth in the form of flood mitigation and ecological enhancement works. 37. The Councils will be aware of the Transport Authorities plans to provide a new rail station/public transport interchange within the HLM site, that is to be connected by Very Light Rail to Coventry running through the site. When completed, this site will be one of the best served sites in South Warwickshire for public transport.
Q-S4.1: Growth of Existing Settlements 26. Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the larger sustainable settlements. Q-S4.2: Settlement Analysis 27. The following comments are made in respect of HLM’s site, which is referenced as Area 4 within the Southam Area. 28. In respect of Connectivity, it is noted reference is made to the A423 as a barrier to the western edge. This is acknowledged however there are several points at which crossings can be safely made for pedestrians and cyclists. 29. Firstly, the existing underpass which serves the Flying Fields development to the north of Area 4. This underpass provides a safe, secure, and direct route for pedestrians and cyclists into the town centre from Welsh Road East. The HLM site can access the underpass via Welsh Road East. 30. Secondly, there is an existing public right of way for pedestrians that runs through the middle of Area 4 before crossing the A423 at grade and then connecting onto Stowe Drive and then along residential streets towards the town centre. This route can be improved through the provision of a controlled toucan crossing. 31. Thirdly, there is an existing bridleway that runs through Area 4 and connects to an existing traffic light controlled pedestrian crossing adjacent to the junction with the A425. This route provides a safe and direct route to the Banbury Road and Sustrans National Cycle Route 48 which connects to the town centre and employment areas. 32. Finally, there is the ability to connect with and across Banbury Road to the south of the A423/A425 junction to provide an alternative means of accessing the town from the southern end of Area 4. 33. It is therefore considered that active and sustainable modes of travel from Area 4 to the town can be made across the A423 at four separate crossing points, and that connectivity is not a barrier that would prevent the area from being a strategic allocation. Further, enhanced connectivity between Southam Southeast and the main town will benefit existing residents east of the A423. 34. In respect of Landforms, it is noted there are no physical constraints on Area 4. It is also noted that Area 4 has all local facilities within 800m. 35. When taking account of this evidence, the comments above in relation to connectivity, and the evidence of the SA, it is clear that Area 4 performs best. This area is the most suitable location to accommodate a broad location of up to 2,000 dwellings, as it is the least environmentally constrained and yet the most accessible to the town and its facilities.
5. The Settlement Analysis has understandably focussed on assisting with identifying locations for new housing. However, a similar exercise should be carried out for employment. It is noted that Gaydon/Lighthorne Heath falls within the spatial growth option, Economy Option (3). However, no analysis has been undertaken as to its ability to accommodate employment growth. This work should be undertaken to inform the next iteration of the Plan, and in particular take into consideration the opportunities to expand Jaguar Land Rover (sites 375 and 376).
17. The SWLP Issues and Options consultation evidence base includes a Settlement Analysis which reviews existing settlement structures across South Warwickshire with a view to guiding future development, assessing connectivity, landforms, accessibility to local facilities and density. 18. Kingswood is broken up into 12 Areas, with MacMic Group’s interest at Land at Station Lane, Kingswood forming a large proportion of Area 7. The assessment of Area 7 in the Settlement Analysis with associated commentary is provided below. 19. Connectivity – Area 7 is graded B in recognition of its accessibility to key routes in the settlement, including Station Lane and the canal towpath. Area 7 is one of only four Areas in Kingswood graded B on connectivity, with the remainder achieving C, D or E. 20. Landforms – Area 7 is clear of any constraints aside from Flood Zones 2 and 3 on the eastern boundary of the site, which can be appropriately avoided and indeed enhanced in bringing forward residential development on Land at Station Lane, Kingswood. 21. Local Facilities – Area 7 scores 2 out of 5 with regard to accessibility to local facilities, being within 800m of categories: Places to Meet and Education. In terms of Retail, Jobs and Economy, it is recognised that Area 7 falls outside the 800m limit, however this is marginal with the convenience store, post office and other retail and employment generating uses falling around 850-900m of Area 7 and thus still considered generally accessible. With regard to Open Space, Leisure, Recreation – Wellbeing, the Concept Masterplan demonstrates how significant green infrastructure provision and associated access to the canal towpath is to be incorporated into the development. On Healthcare, it is recognised that Area 7 falls outside the 800m limit, however again this is marginal with the surgery falling within 1km and thus still considered generally accessible. Connections with local facilities are supported in the emerging Concept Masterplan through maximising existing links and providing additional accessibility where appropriate. 22. Density – Kingswood is covered entirely by residential development classified as ‘Outer Suburb (approx. 20-40 dph)’. This has been taken account of in the emerging Concept Masterplan for Land at Station Lane, Kingswood, with residential development proposed at an average of 36 dph. 23. In conclusion, Area 7 performs well in the Settlement Analysis for Kingswood, particularly with regard to Connectivity and Landforms. With regard to access to Local Facilities, whilst some of these fall outside of the 800m threshold, this is marginal and generally the range of facilities on offer in Kingswood are considered to be accessible. This will be supported through significant green infrastructure provision on Land at Station Lane, Kingswood, along with improved connectivity from the Site. The density mapping has been considered and is reflected in the Concept Masterplan for Land at Station Lane, Kingswood with residential development proposed at an average of 36 dph. MacMic Group consider that more weight should be afforded to accessibility to rail in the Settlement Analysis and indeed wider consideration of the development strategy and site selection.
82. Detailed commentary on the Settlement Analysis in relation to Kingswood is provided in response to Q-S4.2 above. 83. To summarise, Area 7 performs well in the Settlement Analysis for Kingswood, particularly with regard to Connectivity and Landforms. With regard to access to Local Facilities, whilst some of these fall outside of the 800m threshold, this is marginal and generally the range of facilities on offer in Kingswood are considered to be accessible. This will be supported through significant green infrastructure provision on Land at Station Lane, Kingswood, along with improved connectivity from the Site. The density mapping has been considered and is reflected in the Concept Masterplan for Land at Station Lane, Kingswood with residential development proposed at an average of 36 dph.
Q S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Brownfield site should be given the upmost priority and areas should only be proven to be an unsustainable location if regeneration projects of the area to make it a sustainable option is not viable. Q S4.2 Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on 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
QS4.1 Growth of existing settlements – 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.
Paragraph 72 of the NPPF notes that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. As part of a range of considerations, the NPPF also states that such policies should ensure that the size and location of such development will support a sustainable community, with sufficient access to services and employment opportunities within the development itself, or in larger towns to which there is good access. In the context of residential led urban extensions to existing sustainable settlements, these can offer clear sustainability benefits associated with being close to the existing built-up area and sufficient critical mass such that they can deliver on-site infrastructure and community facilities. Such sites can also deliver a substantial quantum of market and affordable homes in a range of sizes and types to respond to the needs of specific groups, plus extensive access to high quality green spaces and recreational areas, promoting health and well-being. Accordingly, such growth options present an excellent opportunity to limit the need to travel long distances and maximise the use of sustainable modes of travel. Stratford-upon-Avon, as the principal and most sustainable settlement in Stratford-upon-Avon District and one of five main towns across the Plan area, should be one of the settlements where growth is focussed, with the SA demonstrating certain growth options in this location are some of the best performing within the Plan as a whole.
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3.3 It is considered that growth of some of the existing settlement should feature as part of the overall strategy as this will help to ensure a sustainable pattern of development through aligning growth with jobs, services and facilities and infrastructure provision. Land to the South of Coventry should be included within this process. 3.4 Whilst outside of South Warwickshire, the City of Coventry, as the sub-regional centre, should be acknowledged as part of the overall strategy as indeed was the case in the formulation of the Warwick District Local Plan. Land to the South of Coventry at Westwood Heath should therefore be considered for growth for a residential led mixeduse development as part of the overall strategy within the SWLP.
St Philips considers that the growth of existing settlements should form an important part of the overall strategy. The NPPF emphasises importance “on the need to support economic growth and productivity” (Para 81) and St Philips is concerned that overlooking existing settlements would constrain economic growth in these locations. The growth of existing settlements would support local services and facilities and would also direct development to sustainable locations in line with the NPPF (Para 11a). Existing settlements often have access to education, healthcare, retail, jobs, and public transport, and should therefore be considered as ideal locations for growth. 2.12 In this context, St Philips is promoting the land at Hockley Heath for residential development. Development on the edge of Hockley Heath lends itself well to achieving a proportion of the required development, particularly given the fact that the site is welllocated in order for residents to access a range of key local amenities and facilities. Additionally, Hockley Heath is well connected to the strategic transport network and is accessible via public and private methods of transport offering the opportunity to achieve sustainable development. 2.13 Whilst part of the site falls within SMBC’s administrative area, the majority of the site lies within the administrative boundary of WDC. In consideration, St Philips considers that directing growth towards Hockley Heath would be a suitable and sustainable strategy and would like to confirm the site’s status as being ‘suitable, available and achievable’. 2.14 Allocations that support the growth of Hockley Heath would be highly sustainable and would support existing local services and facilities. In this regard, the NPPF is clear that: “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” (Para 79). 2.15 St Philips therefore welcomes that the IO recognises the importance of considering the potential for growth around the edges of existing settlements, alongside or in combination with options such as new settlements. Whilst the NPPF recognises that “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements” (Para 72), it is equally clear that small-medium sized sites can make a valuable contribution to meeting the housing requirement of an area (Para 69). Therefore, regardless of whether a new settlement is pursued, the SWLP will need to allocate a variety of small-medium sized sites. St Philips considers that the proportionate growth of existing settlements will play a key role in fulfilling this requirement.