Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2?
Q-D2: Please select all options which are appropriate for South Warwickshire Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. We would support this approach although, at present, there is a tendency for planners applying design guidance too rigidly to developments and there is a lack of consideration as to whether (regardless of any deviation from the guidance) the development looks appropriate and/or adds value to its surrounding and functional for its needs. Any Design Guide/Code should not be overtly prescriptive or rigidly applied but, provide guidance and/or performance criteria – there is a real danger that this could prevent innovative and creative designs that are different but still appropriate and create interest. Designs should be considered on their merits in meeting performance. Option D2c: Develop design guides/codes for strategic development sites/locations. We would support this approach. Q-D3: Please select all options which are appropriate for South Warwickshire We consider a flexible approach that considers the site context, local character and the efficient use of land, and ultimately the creation of high quality development, would be more appropriate. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Yes. Although we remain unconvinced by the 20-minute neighbourhood concept. Q-D6: Please add any comments you wish to make about a well-designed and beautiful South Warwickshire Please refer to earlier comments regarding unnecessary and too rigid application of design guidance.
Tourism is a major part of Henley life and many businesses rely on it. Tourists come to see a quaint market town not a busy housing estate with old buildings in the middle. Roads would be so busy with difficulties parking which would definitely affect trade. We feel that new settlements should be built in out of town locations with supporting new infrastructure built around it, a new school, doctors and shops, like the Dickens Heath village in Solihull
QD5: Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…" 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Warwickshire has many fine gardens, and the Warwickshire Gardens Trust (WGT) works, inter alia, to record and protect gardens and parks of outstanding quality from neglect and inappropriate development, including those held only on local lists. The Gardens Trust, to whom the Warwickshire Trust is affiliated, has been appointed a statutory consultant on planning matters relating to registered gardens. The WGT is therefore pleased to be able to comment on the South Warwickshire Local Plan proposals. In order to protect our garden heritage, it is vital that gardens and their settings and other green spaces on the local register be given the same degree of protection/consideration as other heritage assets such as conservation areas, Listed Buildings, Scheduled Monuments, and archaeological sites. The Historic Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon looks at a number of settlements but does not cover all of the two districts. It is, therefore, important to note that all areas of the combined district should be assessed against development proposals by the same RAG methodology in order to bar or mitigate any damage to our garden heritage. The question posed in the consultation was whether the correct approach was to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? The WGT believe that this is the correct approach – but would ask that all areas be included.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Self-build and custom housing sites are likely to require a different approach to design codes compared to other types of development and this should be reflected in a specific self-build and custom housing policy. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2: The inclusion of broader design guides for planning and general needs housing may be a good opportunity too also incorporate design guides for extra care and supported housing to ensure the housing stock delivered for these specific areas is fit for purpose and aligned to commissioning needs. WCC would welcome further opportunities to engage in relation to this. Q-D3: The appropriate density of development is likley to differ across the Local Plan area with greater densities being more acceptable in urban areas than would be appropriate in more rural areas. Q-D6: Thought to be given to the inclusion of reference to supporting local distinctiveness which lead to a sense of place. Consideration of key non-designated heritage assets to also be considered.
Beautiful Warwickshire depends on protecting landscapes and views from eyesores - i.e where can this development be seen from? E.G. views from a castle, not just of it. 'Beautiful' depends on protecting important green areas, woodlands, hedgerows, footpaths, green corridors and spaces within villages, towns, settlements; environmental diversity and richness should be a priority; waterways should be clean, litter removed from along main roads; historic buildings should be preserved inside and out - not just their frontages; quiet places and dark skies should be part of the county. Where developers build hundreds of new houses new parks should be added so existing ones do not get worn out by footfall.
Q-D2: While Design Guides can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable in a local authority area, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design perspective since they can give rise to homogeny. The Respondent would also caution against the preparation of design guides for numerous different areas, which would seem an overly complex approach. If the Councils decide to proceed with the preparation of design guides or codes for specific places, then it is considered imperative that these are publicly consulted on. If intended to be used as policy rather than flexible guides, then Design Guides must be brought forward as Development Plan Documents (DPD) and independently examined given the implications that they could have on the viability and delivery of development. Q-D3: The Respondent is not convinced that a policy that prescribes densities is entirely necessary and considers Options D3c and D3d to be unduly complex. However, it is acknowledged that density does need to be optimised in accordance with Paragraph 141 of the NPPF if Green Belt release is to be justified. Considering the options therefore, the Respondent would suggest the inclusion of a policy that is in line with Option D3a but which is perhaps supplemented with explanatory supporting text with regards to the sort of density ranges that developments should be aiming for depending on their location, accessibility and context.
Q-D2: Lockley Homes would select Option D2d referred to above. There are some concerns given the challenges being faced by Local Planning Authorities who, in many cases, simply do not have the staff resources, and staff with the specialist technical skills needed to prepare Design Guides or codes for their areas. At a time when Local Planning Authorities across the United Kingdom are struggling and significantly under-resourced, where some Council’s Development Management and Planning Policy Teams are failing and over-stretched, due to 15 years of continual ongoing financial austerity measures being imposed by Central Government (London), since the year 2008. And at a time when Local Planning Authorities (LPA’s) are facing significantly high workload pressures, with very limited staff resource levels, and notable significant and severe town planning skills shortages within Local Planning Authority both Development Management and Planning Policy Teams, we would advise that a pre-cautionary approach is taken in relation to this specific planning policy topic matter. It is clear that LPA’s across the South Warwickshire Region, the wider West Midlands Region, and wider UK are currently under significant pressures for the various reasons highlighted above. Council’s are also grappling with the problems of managing significant budget shortfalls, which is affecting resourcing levels within LPA Planning Departments. Combined with the shortages of competent skilled town planners, urban designers, and the shortages of in-house qualified architects. These resourcing constraints realistically will affect the ability of LPA’s to successfully deliver Design Guides or codes for their areas. Good quality housing developers bringing forward high quality residential schemes, such as Lockley Homes (as evidenced in the photographs at the back of this Representation Statement which show our recent development schemes) will always adopt high quality design standards from the early concept stage of development proposals. So the principles of good design are already established, so Design Guides and codes may not always be necessary, as these matters can be satisfactorily addressed through dialogue with LPA’s at the pre-application advice stage. We also make use of other evidence where available to influence our development schemes, such as adopted Conservation Area Character Appraisals (CACA) reports. Finally, another key point is how LPA Planning Policy Teams within South Warwickshire will deliver effective methods of engagement with local residents in the preparation of Design Guides and codes. In practice, this may prove difficult for LPA’s to achieve. Q-D5: Lockley Homes would select ‘No’ to Question-D5 referred to above. On page 47 of the SWLP consultation report (January 2023), within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment”, we have concerns that the Village of Broom settlement has been recognised as having high historic environment sensitivity. We have concerns about the findings and historic environment planning policy assumptions being made within this emerging background evidence base document, and would question whether it is sufficiently robust and fit for purpose to inform future ongoing Local Plan preparation work going forward within both the emerging SWLP (2023) and SAP (2023) Local Plan Reviews. 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). Paragraph 192 (indent a) of the Revised NPPF (2021) is perfectly clear that: “…Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to: (indent a) assess the significance of heritage assets and the contribution they make to their environment…” Paragraph 31 of the Revised NPPF (2021) confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” In addition, heritage designations should not be viewed as a site constraint to prevent new development, given that high-quality new residential development schemes incorporating good quality architectural design features, and use of appropriate 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 nearby 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…” As a key local stakeholder with a strong commitment and proven track record of bringing forward and delivering very high-quality new build residential schemes within the South Warwickshire countryside, and across the wider Midlands Region (see photographic evidence of the high-quality character of our new build residential schemes at the end of this Representations Statement). We maintain our view that the presence of heritage designations should therefore not be viewed as a site constraint within any future Local Plan policy approach to prevent future new housing development sites from coming forward within the emerging Local Plan area. Our views on this issue are supported by the above NPPF guidance. It is critically important that any future planning policy approach taken on this issue within the emerging Local Plan Review, has a positive and pro-active development approach towards supporting the needs of the private sector house building development industry. To ensure that a sufficiently robust Local Plan-making approach it taken by the LPA, reflecting the requirements of paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021). Q-D6: On page 47 of the SWLP consultation report (January 2023), within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment”, we have concerns that the Village of Broom settlement has been recognised as having high historic environment sensitivity. We have concerns about the findings and historic environment planning policy assumptions being made within this emerging background evidence base document, and would question whether it is sufficiently robust and fit for purpose to inform future ongoing Local Plan preparation work going forward within both the emerging SWLP (2023) and SAP (2023) Local Plan Reviews. 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). Paragraph 192 (indent a) of the Revised NPPF (2021) is perfectly clear that: “…Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to: (indent a) assess the significance of heritage assets and the contribution they make to their environment…” Paragraph 31 of the Revised NPPF (2021) confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” In addition, heritage designations should not be viewed as a site constraint to prevent new development, given that high-quality new residential development schemes incorporating good quality architectural design features, and use of appropriate 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 nearby 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…” As a key local stakeholder with a strong commitment and proven track record of bringing forward and delivering very high-quality new build residential schemes within the South Warwickshire countryside, and across the wider Midlands Region (see photographic evidence of the high-quality character of our new build residential schemes at the end of this Representations Statement). We maintain our view that the presence of heritage designations should therefore not be viewed as a site constraint within any future Local Plan policy approach to prevent future new housing development sites from coming forward within the emerging Local Plan area. Our views on this issue are supported by the above NPPF guidance. It is critically important that any future planning policy approach taken on this issue within the emerging Local Plan Review, has a positive and pro-active development approach towards supporting the needs of the private sector house building development industry. To ensure that a sufficiently robust Local Plan-making approach it taken by the LPA, reflecting the requirements of paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021).
QD5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
6. Chapter 8: A well-designed and beautiful South Warwickshire Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements, and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage. Whilst the IO document has not requested any responses specifically on the HSSA, RPS has nonetheless reviewed the assessment with respect to Southam, which is set out below. Identifying potential impacts of development – Southam 7.3 Southam has been sub-divided into four sub-areas (North, South, East and West). The HSSA provides a table (not numbered in the report) which summarises the scores, based on a ‘RAG’ rating system, broken down by these sub-areas. The full assessment is provided at section 10.21 of the HSAA, alongside a number of supporting plans. 7.4 In summary, the HSSA scores the West sub-area as ‘Red’, and the other three sub-areas as ‘Green’. According to the HSSA commentary, this is largely the result of the Conservation Area and open landscape associated with the valley of the River Stowe which also contains the Scheduled Monument of the Holy Well. However, whilst the HSSA provides detailed commentary on each subarea, these sub-areas are not defined on a map or plan. This creates uncertainty for the reader in understanding how development on specific sites might impact on the sensitivity or susceptibility of heritage assets within those sub-areas. RPS recommends that the HSSA is updated to provide an indication of the boundaries of each sub-area so the reader can properly interpret the information provided. 7.5 That said, of particular interest is the sub-area North, which is assumed to cover the area that includes the Land off Coventry Road, which scores ‘Green’ in the RAG assessment. In respect of designated heritage assets, there are no known assets identified along the northern boundary of the settlement (see pdf page 190 of the HSSA for the mapping). In terms of the sensitivity and susceptibility of development in this sub-area, the HSSA acknowledges there are no designated assets present in this area and that the area comprises largely an agricultural and industrial landscape. In terms of potential impacts on heritage assets, the HSSA acknowledges that modern development to the north, south and east of the settlement has partially enclosed and eroded the Conservation Area and its setting (pdf page 188). The HSSA also acknowledges that this sub-area may be able to accommodate development, and thus does not preclude it from coming forward. 7.6 The HSSA mapping (on pdf page 191) does indicate the presence of features on the Historic Environment Record (HER) and other non-designated assets to the North of the settlement, which covers the Land off Coventry Road. This is consistent with information provided in the updated Vision Document for the site (Appendix A) which identifies Ravenswood House (also known as Southam Fields Farm) as recorded on the HER, but in any event these buildings would be retained. 7.7 On this basis, it is not anticipated that the development in this part of the sub-area, including the Land west of Coventry Road, would have an adverse impact on any designated heritage assets. Recommendations 7.8 In light of the findings highlighted above, the HSSA recommends that development should be restricted to the North sub-area of Southam (and other sub-areas), whilst avoided in the West subarea (see pdf page 189). RPS broadly concurs with these recommendations. 7.9 On this basis, RPS broadly welcomes the conclusion that development has potential in the North sub-area (subject to confirmation that Land off Coventry Road being promoted on behalf of Taylor Wimpey is located within this sub-area) and that any potential impact on any designated or non-designated heritage asset can be suitably mitigated as part of the planning application process.
Q-D2: Please select all options which are appropriate for South Warwickshire L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the land north of Leamington Road, Long Itchington development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Therefore, L&Q Estates are supportive of Option D2c: Develop design guides/codes for strategic development sites/locations, particularly as the planned public engagement will ensure the design of spaces and buildings will be appropriate and will respond to local context and identified needs in terms of size, type and tenure. The Vision Document demonstrates that much work has already been undertaken into achieving a welldesigned neighbourhood. Q-D5: Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? L&Q Estates agree that a high-level strategic policy that seeks to protect and enhance existing heritage assets should be included within the Part 1 plan, in accordance with Paragraph 190 of the Framework. Detailed heritage policies should be deferred to Part 2. The Site does not contain any Locally Listed or Statutorily Listed Buildings, nor is it located within the Long Itchington Conservation Area. A Heritage Appraisal has been undertaken to inform the Concept Masterplan and Vision Document for land north of Leamington Road, Long Itchington. The deliverability of development on the site with reference to the historic environment constraints has been assessed. The Long Itchington Conservation Area, which contains 16 listed buildings, is located 95 metres to the south east of the Site at its nearest point. The Heritage Appraisal considers that the undulating topography of the area coupled with the screening provided by the intervening planted and built environment, has the effect of masking the historic core of the village and its listed buildings from the site. The one exception is the tower of the Grade II* Listed Church of the Holy Trinity, which is visible from parts of the Site. However, the Site cannot be experienced from this immediate setting and therefore none of these contributions would be affected by its development. Furthermore, the limited view of the church from the Site comprises obscured views to the upper elements of the tower. The Heritage Appraisal concludes that residential development at the Site would not adversely impact the Church of the Holy Trinity or any other designated heritage assets.
The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage. 7.3 The HSSA does not include an appraisal of Haye Lane, East of Redditch site or its environs. Nevertheless, the Vision document appended to this submission (Appendix A) includes an initial review in relation to archaeology, built heritage and historic landscape. The review did not identify any designated heritage assets within the site. Two designated assets were identified approximately 130m north of the site. Whilst there was some potential for non-designated heritage assets to be present on the site, it is not anticipated that this would necessarily preclude development. Furthermore, any potential impact on the setting of any nearby assets (designated or nondesignated) could be suitably addressed through appropriate mitigation as part of the overall masterplan. 7.4 In this context, RPS considers the Haye Lane, East of Redditch site would score either ‘Green’ or ‘Amber’ against the HSSA methodology as any potential heritage impacts can be suitably mitigated, as evidenced in the updated Vision Document submitted for the site (Appendix A).
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2: In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Corbally therefore agrees that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the nature of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up much needed development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies.
Q-D2: Please select all options which are appropriate for South Warwickshire In principle, the introduction of design codes and design guides would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. Lone Star Land Ltd. therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites such as settlements such as Deppers Bridge. In these circumstances design codes can be a valuable tool to provide high quality development. Paragraph 129 of the NPPF states that design codes should allow developers to contribute towards within the design guide/code process. Lone Star Land would support a policy which would enable collaborative working with local councils to positively produce a shared vision for a new settlement that is deliverable and viable in South Warwickshire at Deppers Bridge. This work may be undertaken in parallel with the preparation and submission to support an application for the development of the new settlement site. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could beencouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. For large scale allocations, a target average density may be appropriate to allow for flexibility across the wider site. This strategy could also be linked to the use of site-specific design codes. The development of a new settlement at Deppers Bridge would provide an opportunity to develop more homes within mixed-use real places at ‘gentle density’, thereby creating streets, squares and blocks with clear backs and fronts. By ‘gentle density’ this means where homes are more closely placed in the townscape than at present, but without negating the environmental benefits of lower emissions, frequent small-scale greenery and pleasant views across streets patrolled by sunlight. In alignment with the aspirations of Central Government, as outlined in the published reports produced by the Building Better, Building Beautiful Commission, local policies should encourage ‘gentle density’ which could at a strategic level be pursued through design codes.
Q-D2: Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. We would support this approach although, at present, there is a tendency for planners applying design guidance too rigidly to developments and there is a lack of consideration as to whether (regardless of any deviation from the guidance) the development looks appropriate and/or adds value to its surrounding and functional for its needs. Any Design Guide/Code should not be overtly prescriptive or rigidly applied but, provide guidance and/or performance criteria – there is a real danger that this could prevent innovative and creative designs that are different but still appropriate and create interest. Designs should be considered on their merits in meeting performance. Option D2c: Develop design guides/codes for strategic development sites/locations. We would support this approach. Q-D3: We consider a flexible approach that considers the site context, local character and the efficient use of land, and ultimately the creation of high quality development, would be more appropriate. Q-D6: Please refer to earlier comments regarding unnecessary and too rigid application of design guidance.
QD5: Yes, the heritage assessment is very important. I am not certain the Heritage assessment to date for Henley is sufficient to show that large scale development in the area would be highly detrimental to historic heritage and environmental heritage and feel of the Henley area. It is important that Local communities are able to work with the SWLP to meet their local needs and for the SWLP to accept that local residents will often understand their local area more comprehensively than the SWLP or developers, to that end NDPs should be respected.
Q-D2: Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. We would support this approach although, at present, there is a tendency for planners applying design guidance too rigidly to developments and there is a lack of consideration as to whether (regardless of any deviation from the guidance) the development looks appropriate and/or adds value to its surrounding and functional for its needs. Any Design Guide/Code should not be overtly prescriptive or rigidly applied but, provide guidance and/or performance criteria – there is a real danger that this could prevent innovative and creative designs that are different but still appropriate and create interest. Designs should be considered on their merits in meeting performance. Option D2c: Develop design guides/codes for strategic development sites/locations. We would support this approach. Q-D3: We consider a flexible approach that considers the site context, local character and the efficient use of land, and ultimately the creation of high quality development, would be more appropriate. Q-D6: Please refer to earlier comments regarding unnecessary and too rigid application of design guidance.
I write to ask that the plan concerning the Old Milverton and Blackdown areas are left as they are, agricultural land for recreation. The facility is for all, not just locals but many people visit the are to take advantage of this lovely open area to walk and enjoy the surroundings. It is to the advantage of all for mental health reasons that a little open countryside is available within easy reach. Planning means there are less and less open spaces. We have wonderful parks but this is less organised and open to nature, used by farmers and the public for the benefit of all. A bit less concreted than it would be otherwise. The traffic increase is also of extreme concern.
Q-D2: Please select all options which are appropriate for South Warwickshire 6.1. In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Rainier therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire 6.6. There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encourage to exceed this minimum density where it could be done in a manner consistent with other development plan policies. Q-D4.1: Do you agree that this is an appropriate range of topics for a policy on the design of safe and attractive streets? Q-D4.2: If no, please indicate why 6.7. The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.
Q-D2 – Please select a design code option which is appropriate for South Warwickshire Option D2d: None of these A single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitates schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area.
Q-D2 – Please select a design code option which is appropriate for South Warwickshire Option D2d: None of these A single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitates schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area.
Q-D2 – Please select a design code option which is appropriate for South Warwickshire Option D2d: None of these A single design code for the whole of South Warwickshire would be problematic as it would be difficult to tailor requirements to individual settlements or places. Q-D3 – Please select a density policy option which is appropriate for South Warwickshire Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. The density achieved should be a product of good design. The SWLP should include a policy that seeks to make the best use of the land and facilitates schemes delivering at an efficient density, but does not set a specific target. What constitutes an appropriate density is likely to vary significantly across the geography of the plan area.
Issue D2: Design Codes and design guides Q-D2: please select all options which are appropriate for South Warwickshire The Church Commissioners considers Option D2c most appropriate and notes that these are likely to be the larger and more strategic sites, such as any new settlements. It is not appropriate to have a Design Guide across South Warwickshire as the area is too vast, and has a range of characteristics, therefore would not be representative or achieve suitable design across a variety of landscapes. Therefore, each Site should be assessed on its’ own merits. Issue D3: Designing adaptable, diverse and flexible places Q-D3: Please select all options which are appropriate for South Warwickshire The Church Commissioners supports Option D3b where policy should specify a minimum density requirement across South Warwickshire. However, the Policy needs to be fully tested and evidenced to decipher the minimum housing density whilst also containing flexibility to enable different densities to be achieved in situations such as where housing need requires a greater number of one-bedroom flats, or 4 bedroom houses which would impact upon density. Furthermore, potential site constraints may also impact upon density, consequently, policy needs to be worded identifying the minimum density to be achieved, unless an alternative can otherwise be demonstrated as suitable. 6.5 Clarification is required in relation to the density suggestions, as Option D3b states that an example could be set at a similar level to that of the existing policy at Warwick, being 30dph, whereas the Sustainability Appraisal, produced as part of the evidence base, is based upon the assumption of 35dph, thus an inconsistency between the two approaches.