2. Contextual and Policy Overview

Local Plan Consultation - Village Housing Options and Settlement Boundaries

The Federation of Small Businesses would like to thank you for the opportunity to respond to your consultation on Village Housing Options and Settlement Boundaries.

Small businesses are the engine room of the economy, employing more than half of all private sector workers and contributing 50 per cent of UK GDP. Through the Local Plan we would hope you are able to provide opportunities to support the small business community in Warwick District.

Transport: Small businesses depend on their vehicle to operate their business - our research shows that 72 per cent of small firms said their car or van is crucial to their business. We know that more needs to be done to address the problem of congestion and the state of repair of roads in Warwick District, in order to get businesses moving and growing. Any plans for development must include a strategic plan and management of transport needs, working closely with Warwickshire County Council as the highways authority. Any new developments in the surrounding villages must consider how residents and employees will access or move across the district on the road network.

Broadband: High quality broadband services are essential for businesses to increase the UK's productivity and growth. Our research shows that 9 per cent cannot access broadband at all and 22 per cent cannot access current generation broadband. Through the Local Plan, the council should consider how the development of new housing and industrial land would impact on the existing network expansions plans. It is also essential for the districts inward investment offer to ensure all new employment sites are, or can be fully serviced by reliable broadband that is available at acceptable speeds.

Utilities: Small businesses must have access to reliable and readily available energy and water in a similar way to domestic households. Many small businesses lack the expertise to negotiate contracts and are penalised by energy suppliers because of their limited purchasing power, relatively low energy consumption and unpredictability of demand. Through the development of the Local Plan and the allocation of residential and employment land, the Council should consider how it can support businesses to secure reliable utilities at reasonable prices.

Planning: Businesses tell us that the planning system is overly complex and costly and is a barrier for businesses wanting to grow. Our research shows that just over half (53%) of small firms that have applied for planning permission over the past two years said that the rules and process were overly complex and 38 per cent said that the process had higher costs than anticipated. We are therefore concerned that small businesses are put off from investing time and money into expanding because of drawn-out, complicated planning applications. Now that residential and employment land has been allocated and key areas of existing have been identified for investment, the council must ensure it has an 'open for business' planning policy that encourages investment and growth. This can be achieved through a clearer planning system that is easier and more affordable for small firms and by changing the process of planning applications for minor building works to ensure that small firms are encouraged to submit planning applications. The FSB also recommends that the council encourage developers to consider allocating a proportion of development sites for smaller units to support new or growing businesses - similarly to the regulations that exist to support affordable housing.

Community Infrastructure Levy: FSB Members are frequently involved in owning or constructing single dwellings or small developments. Prior to the introduction of CIL, these small developments rarely paid Section 106 developer contributions. We therefore would like you to comply with the National Planning Policy Framework and to avoid imposing requirements that make development unviable. It would also be sensible to set differential CIL rates reflecting real differentials in viability across Warwick District and ensure that where CIL is paid, that there is a link between the development and the infrastructure it funds.

Kind regards,

Linsey Luke - Development Manager
Warwickshire & Coventry Federation of Small Business

The statements made are correct regarding the need for a range of new homes if older residents are to have the opportunity to downsize. However there is a need to consider that residents with either large or difficult to maintain homes (perhaps older properties or homes with large gardens) do not necessarily wish to move to small two bedroom homes or to new village developments.
Parishes such as Rowington are simply dying due to a lack of new middle age residents because of the lack of suitable new housing. Meanwhile management and employees of high growth companies such as Jaguar Land Rover fail to find suitable homes in the very same area. Rowington parish is quite centrally located re the various sites of some of these companies including JLR and its suppliers. The only planned preferred sites within the current local plan are unlikely to meet the needs of many current residents or indeed provide housing opportunity for potential younger middle age / middle class families.
Without such stimulus communities such as Rowington will continue to die re lack of younger, vibrant participants in village activities. The current proposal has failed to take heed of opportunities re sites which were suggested (at Pinley) which would modestly help this current imbalance. There is a need for greater distribution of housing to include smaller sites.

see attached

There is no justification for WDC's proposed growth of 12,300 homes, which is highly subjective and against consultation responses to date. As admitted by WDC as an "interim" figure, why are site allocations being made on the 'highest-case' basis?

WDC's work to co-operate with neighbouring local authorities is still not complete. Why therefore again are site allocations being made based on 12,300? For example Coventry and Nuneaton are rumoured to be encouraging more growth.

A sequential test focussing on brownfield and in-town sites has not been completed.

Specifically for Hatton Park, the subjective analysis JUST puts it into the 'Growth Village' category so 70-90 homes is excessive. WDC's own preamble confirms that Hatton Park is responsible for local population growth of 48% since 2001 (even higher for younger people) and that there is a wide range of housing types. Therefore WDC's justification for improving housing stock and encouraging population growth in the younger demographic DOES NOT APPLY for Hatton Park. So, why is Hatton Park earmarked for 70-90 homes?

Services around Hatton Park are already stretched, for example the Ferncumbe School is at full capacity.

WDC's previous assumptions have been contested by Hatton Parish Council.

All in all the housing outputs and site allocations are being made based on criteria that has not been tested and WDC faces a tough challenge when its Local Plan goes to the Inquiry.

There is no justification for WDC's proposed growth of 12,300 homes, which is highly subjective and against consultation responses to date (work undertaken and supported by Hatton Parish Council shows that the figure is 5,500-6,000 homes). As admitted by WDC as an "interim" figure, why are site allocations being made on the 'highest-case' basis?

WDC's work to co-operate with neighbouring local authorities is still not complete. Why therefore again are site allocations being made based on 12,300? For example Coventry and Nuneaton are rumoured to be encouraging more growth.

A sequential test focussing on brownfield and in-town sites has not been completed.

Specifically for Hatton Park, the subjective analysis JUST puts it into the 'Growth Village' category so 70-90 homes is excessive. WDC's own preamble confirms that Hatton Park is responsible for local population growth of 48% since 2001 (even higher for younger people) and that there is a wide range of housing types. Therefore WDC's justification for improving housing stock and encouraging population growth in the younger demographic DOES NOT APPLY for Hatton Park. So, why is Hatton Park earmarked for 70-90 homes?

Services around Hatton Park are already stretched, for example the Ferncumbe School is at full capacity.

WDC's previous assumptions have been contested by Hatton Parish Council.

All in all the housing outputs and site allocations are being made based on criteria that has not been tested and WDC faces a tough challenge when its Local Plan goes to the Inquiry.

VILLAGE HOUSING OPTIONS (VHO)

Bishops Tachbrook Parish Council (BTPC) wishes to make the following comments: -

1 General Observations

1.1 BTPC accepts that rural settlements should be expanded by accommodating new housing that will help the District fulfil its overall housing numbers.

1.2 We do not agree with the contrived village hierarchy - it's full of inconsistencies. Each rural community should be assessed on an individual basis.

1.3 We recognise that due to demographic and societal changes it is probable that all rural settlements, not just those selected in this consultation, might be capable of and benefit from some new housing.

1.4. Sites for such housing must be selected with care and in conjunction with each rural community, as they prepare their Neighbourhood Plans. Top down imposition is not acceptable, but help from officers to identify and evaluate possible sites for development is very welcome.

1.5 Communities in villages would find growth more acceptable if they were encouraged to identify possible sites and to select small local builders rather than the process being lead by large speculative developers.

1.6 Sites should be small in scale to assist with integration of newcomers into the existing community. This will also smooth entrant numbers into the local primary schools and minimise population stratification, so phasing of the development over the planned period is very important.

1.7 With a consistent approach we think that the number of new houses in rural settlements could be greater than the 937 proposed. But this will require the exercise to be extended to include ALL rural settlements, so increasing from 13 to 22/24 the number of settlements to be included.

2 BT Specifics

2.1 We agree with the Overview of Findings relating to Bishop's Tachbrook on Table 3 on page 27 of the village housing options paper.
2.2 Because of the way the village has evolved, especially the new housing built in the 70's and 80's, the village envelope is very strongly defined. Previous site reviews show that there are hardly any spaces for in-fill development - with perhaps sites for just 6-10 houses. This is not surprising because this was the District's intention when the original village was extended in the 60's and 70's and all the land included in the envelope was planned for.

2.3 As part of its Neighbourhood Plan process the Working Group has commissioned a study from Urban Vision to assess all sites in and around the village. Their draft report is just in and has considered the 3 sites referred to in the VHO as well as 10 other possible sites. There is potential for some of the local plan requirement to be met on some of these sites reducing the numbers required on Site 1.

2.4 Also as part of its Neighbourhood Plan process a community consultation took place on Saturday the 18th January. The unanimous opinion of residents was that if additional housing is required in the village then Site 1 is the best location and it should be phased and limited in total to 70 homes or thereabouts. There was absolutely no support for sites 2 or 3.

2.5 In addition the PC now has the results of a Housing Need Survey conducted by WRHA in December 2013. The 250 completed questionnaires represent a high response rate. Its findings are that our community needs 15 new homes, of which 10 should be "market" and 5 "affordable. This is consistent with the Housing Need Survey carried out in 2009.

2.6 We have participated with Stephen Hay in his review of sites immediately adjacent to the village envelope; and agree in principle with the Preferred Option set out on pp38/39 of the report.

2.7 However we are not able to agree the number of new houses suggested for Site 1. The feedback summarised in paras 2.4 and 2.5 above underpin the reasons for this objection.

2.8 BTPC has major concerns on the number indicated of 150 houses. This would represent more than an 18 % increase in the village housing stock and a 20% increase in our population. We note that this is higher than any other rural community in the District; and we have to ask why this scale of development is being considered when 4500 new houses are being proposed on sites within 2 miles of Bishop's Tachbrook. This is an overwhelming number and would damage community life and the rural setting of the village. We would like the number being required from Bishop's Tachbrook reduced and made up from settlements not yet included in the Primary and Secondary villages mentioned in para 5.9 of the VHO

2.9 Traffic on Oakley Wood Road is already a concern with morning peak volume @1910 and evening @ 1809 according to the Transport Assessment (Phase 3) With the developments set out in the Local Plan per para 2.7 these figures are predicted to rise by 45% and 46% respectively.

2.10 A similar study should be carried out for Mallory Road which is already heavily used by commuters to reach the M40 from Leamington, passing through the centre of the village. The junction of Mallory Road and Banbury Road (B4100) has a bad accident record.

2.11 The Tollgate House site has been granted to have 6 houses built on it. This number could be increased. There are other small sites around the parish - see para 2.3 above - that might be brought forward for small numbers of housing and these are being taken into consideration in our Neighbourhood Plan.

SUMMARY

3.1 A second phase VHO should be set in train immediately to address the opportunities for new housing across all rural settlements in the District, through phased development over the planned period. By spreading the housing requirement more realistically the pressure on infrastructure will be reduced.

3.2 The maximum number of new houses on Site 1 in BT should be set at 70. Part of the site should be reserved for future expansion of the school facilities and the majority of the new housing should be on the lower slopes of the site avoiding the higher part towards the crest of the hill. The southern arc of the site within the gas no development zone to form a green boundary deep enough to have amenity value and mask as much as possible the noise from the M40. This could be designated as either Green Belt by the Local Plan or Local Green Space and include Site 3 that was considered in the VHO.

3.3 WDC Planning should reject all other housing developments in the parish above 5 units.

Settlement Boundaries

4 The VHO should specify the rural area policies that will apply to any land outside the agreed village boundaries, in particular non-green belt villages per para 6.9 on page 32. This could allow "exception sites" for small, appropriate developments to be brought forward as is the case in the current Local Plan.




BTPC 20 Jan 14