Canalside Development Plan Document

Comment

Representation ID: 72032

Received: 21/12/2020

Respondent: Canal & River Trust

The objectives set out are generally positive, but the DPD lacks detail and clarity in identifying a strategy for helping to deliver them. Too much is descriptive, and too little is focussed on identifying clearly the ways in which new development should contribute towards achieving this aim or assisting in promoting and facilitating the use of the canal network as a multi-functional resource which can itself contribute towards the realisation of many objectives and aspirations set out in the Local Plan and national planning policy . We question whether the DPD can be considered to be positively prepared or effective.

Comment

Representation ID: 72033

Received: 21/12/2020

Respondent: Canal & River Trust

The extent of the DPD has not been made clear. It refers to considering the land either side of canals without providing any indication as to how far this might extend beyond the canals themselves. Although the document considers environmental and social issues affecting the canal network, it often does so in general terms and without specific consideration of how all of these issues appear in the local context across the District. It is not clear that the plan has been positively prepared to provide a clear approach that is properly relevant to the canal network in Warwick District.

Comment

Representation ID: 72034

Received: 21/12/2020

Respondent: Canal & River Trust

It is not clear how the Council sees the other opportunities sites identified at Appendix 1 as contributing towards its aims and aspirations for the canals within the District. Most of these sites have been assessed as being unlikely to be suitable for development, so do not seem to represent any significant “opportunity” to be pursued. There is no strategy relating to these sites and how the Council considers that their redevelopment could contribute positively towards meeting its objectives. There is no policy framework for guiding redevelopment of any sites other than those identified in Policies CS10, 11 and 12.

Comment

Representation ID: 72035

Received: 21/12/2020

Respondent: Canal & River Trust

Policy CS1 repeats the requirements of Policy BE1 of the adopted Local Plan and adds little to identify particular considerations around design and layout that apply specifically to canalside locations.

We consider that Policy CS1 does not satisfy the requirements of NPPF Paragraph 16 c), d) and f). It has not been shaped by meaningful engagement with the Trust as operator of the canal, is ambiguous and lacking in clarity and does not serve a sufficiently clear purpose, containing unnecessary duplication of existing adopted policies. We question whether it can be regarded as being positively prepared, justified or effective.

Comment

Representation ID: 72036

Received: 21/12/2020

Respondent: Canal & River Trust

This policy repeats existing best practice in terms of employing good design principles in considering how to incorporate parking within layouts that can be found in existing adopted local and national planning policies.

We consider that the policy should be amended to provide more specific advice on potential impacts on canals and how they can be addressed.

Comment

Representation ID: 72037

Received: 21/12/2020

Respondent: Canal & River Trust

Policy CS3 repeats existing requirements relevant to any development proposal that potentially affects heritage assets, whether near a canal or not.

As the entire canal network through Warwick District is designated as a conservation area and is therefore a designated heritage asset, it already benefits from quite significant protection through existing national and local planning policies. It is therefore not clear what additional protection is intended to be achieved through Policy CS3.

Comment

Representation ID: 72038

Received: 21/12/2020

Respondent: Canal & River Trust

Policy CS4 could more specifically consider the role of the canal network as a wildlife habitat and corridor and its intrinsic ecological interest and value. The Policy should be strengthened as suggested to achieve a more effective policy.

Comment

Representation ID: 72039

Received: 21/12/2020

Respondent: Canal & River Trust

Whilst the Canal & River Trust agrees with the statement made in Policy CS5, the policy does not appear to require anything to be done by prospective applicants/developers. It simply states that the canal should be recognised as a potential renewable energy resource.

As written, the policy appears unlikely to achieve any increase in the exploration of or take up of opportunities for using the canal as a renewable energy resource as an integral element of new development proposals adjacent or sufficiently close to the canal. The policy should be strengthened to address this.

Comment

Representation ID: 72040

Received: 21/12/2020

Respondent: Canal & River Trust

Policy CS6 appears to have no specific application to canalside development or require any particular consideration of Purpose-Built Student Accommodation in relation to how it affects canals.

We consider that Policy CS6 does not satisfy the requirements of NPPF Paragraph 16 f) as it contains significant unnecessary duplication of existing adopted Local Plan policies. We therefore question whether Policy CS6 can be regarded as being justified or effective.

Comment

Representation ID: 72041

Received: 21/12/2020

Respondent: Canal & River Trust

Policy CS7 provides no specific guidance in relation to signage provided as part of canalside development. The policy does not require such signage to be provided and simply allows for the provision of appropriate signage. It does not appear to differ from the position that would apply to any new development, whether near a canal or not. The policy sets out no particular aims or aspirations that the Council has in relation to the provision of signage in canalside locations.

Policy CS7 should be strengthened to be proactive in guiding the approach to providing signage.