Object

Representation ID: 66184

Received: 04/06/2014

Respondent: The Trustees of the F S Johnson 78NEL Settlement

Agent: Tyler-Parkes Partnership

Legally compliant? No

Sound? No

Duty to co-operate? No

The local plan is not sound because it fails to:

provide sound, accurate evidence to justify discounting land at Station Lane, Kingswood for housing development, despite assurances that previous misrepresentations would be rectified.
does not provide certainty over the long term
identify sufficient land within or adjacent to the largest villages proportionate to their sustainability criteria
include sufficient sites which are deliverable in the next 5 years to meet the 5 year housing land requirement
address the need for a 20% buffer in the 5 year housing land supply arising from the Council's record of persistent under delivery of new housing
fully address the implications on Warwick District of the potential housing land shortfall in the Housing Market Area and surrounding local authority areas as required under the Duty to Cooperate
offer developers sufficient deliverable housing land choices to ensure a rolling 5 year housing land supply is maintained
ensure that Green Belt boundaries are capable of enduring beyond the plan period through the identification of 'areas of development restraint' or 'safeguarded land' including in/adjacent to the most sustainable villages
provide sound evidence to demonstrate that highway access could be satisfactorily achieved to enable safe development of the sites allocated for housing in Kingswood; and
remove part of the land fronting Station Lane from the Green Belt and include it within the Settlement Boundary and allocate it for residential development
it does not comply with the NPPF and its presumption in favour of sustainable development.

Strongly recommends the allocation of land fronting Station Lane. THis would include discounted option 9 together with land to the east up to the existing field boundary. THe site is in an extremely sustainable location, close to Lapworth railway station and bus stops,the local primary school, shops and surgery. The Council's assessment of the site was distorted by the Council's decision to ignore the existing access opposite 145 Station Lane and assume access would be provided towards the northern end of the road boundary opposite 155 Station Lane. The Council also failed to assess in detail the landscape impact if development was confined to the field fronting Station Lane rather than the larger SHLAA site. Alternative landscape and highways assessments demonstrate inaccuracies with the Council's evidence base.
Highways Statement carried out by Savoy Consulting disputes the County Council's conclusions that demonstrating access could be acheived opposite 145 Station Lane. Access into the site would not require the removal of any trees.
THis highways evidence calls into question many of the Highways conclusions on other sites in Kingswood. It raises serious doubts over the deliverability of H29 and H30 where access would need to be obtained over third party land.
Landscape assessment carried out by Barry Chinn concluded overall the landscape and visual impacts for the development are considered to be predominantly localised and contained within a reasonably small area. Despite submitting this information the Council's evidence base remains unchanged. The SHLAA does not relate to the site area being promoted but instead the full extent of the land in the Council's ownership much of which it is agreed would not be suitable for development and would have an acceptable impact on the landscape.