Issue and Options 2023

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Form ID: 82109
Respondent: The Kler Group
Agent: Cerda Planning Ltd

Yes

Issue D1: Strategic design principles Q-D1.1 Yes, the components listed (comprehensive development; attractiveness; sensitive to context; distinctiveness; connectedness; safety; environmental sustainability and adapting to climate change and; mix and amount of development) are considered to be an appropriate range of topics for a strategic design policy. The proposed content aligns with chapter 12 – achieving well-designed places of the NPPF as is currently worded. Proposed amendments to the NPPF currently under consultation strengthen the importance of good design. Issue D2: Design Codes and design guides Q-D2. We consider that the high level principles of good design could be contained within a suitably worded policy within Part 1 of the Plan which could relate to the whole of the South Warwickshire geographical area – there may be limited merit in doing so however, as expectations are already set out within the National Design Guide and National Model Design Code – for part 1, generally then, it may be sufficient to refer to the Framework and the National Design Guide requiring applicants to demonstrate compliance with. To ensure that design guides/design codes respond to local characteristics, it is essential in our view that these are prepared on an area (if a group of settlements share common features) or individual settlement basis. The design codes/guides should ideally be formulated over time, with input from all key stakeholders including local residents and business owners as well as technical and environmental personnel from both the private and public sector to ensure that these guides will be robust in their assessment of the character and what would be acceptable in terms of visual and environmental (to capture effects of climate change and so on) and deliverable from a developer point of view. Due to the nature of the above; being a collaborative exercise, which will take time, it is considered that the finer detail required to produce such codes, should be required at a later stage of the local plan – either within Part 2, and specific to new allocations proposed, or following adoption, when new sites are confirmed, where a site specific design code/guide could be required. The use of site wide design codes for new allocations is supported, provided there is proper consultation with relevant council departments at both District and County to avoid problems post adoption. Cerda has experience with a site in Warwick which has an adopted site wide design code (which was prepared following a series of workshops with key stakeholders and relevant officers from both the District and County, submitted and approved via a discharge of condition attached to the outline consent). It was very prescriptive in terms of layout, design, materials, car parking spaces, public open space, connectivity and so on, even down to the widths of roads and pavements which would be expected for the main spine road, primary, secondary and tertiary roads. Whilst this code enabled the applicants to prepare reserved matters applications to a set of agreed principles, which the District (planning officer) confirmed they were supportive of; we were significantly delayed by the repeated objections from the County Highways officer who maintained concerns over highway safety and general layout of tertiary roads. This was despite apparently having provided comments on the proposed design code before it was approved. This situation left the District in a difficult position - the Code has been approved and therefore has considerable status in planning terms – to satisfy highways, tertiary roads were re-designed – to appear more engineered and to have footways on both sides – which is contrary to the design code – the engineered appearance significantly detracts from the intended character of these streets. Despite many discussions to try to persuade Highways and to remind them that they were involved with the production of the Code – it was easier to amend the proposals than to continue to argue. In addition to this, tertiary roads have been approved (as per the Design Code) with block paving. We have now received objection to use of block paving and a particular kerb height (again specified within the code) from the Technical Team. We are categorically being told that these materials will NOT receive technical approval. Initial discussions with the District (to try and resolve) have not progressed as the technical team have suggested the use of black tarmac and high kerbs is the only solution – this would fundamentally change the nature of the tertiary roads and character areas in which they are located. This would be across the whole development consisting of 900 dwellings. The planning officer is not keen to support as cumulatively, this change would adversely impact on the appearance of the whole of the development – contrary to the adopted Site Wide Design Code. For any design code to be acceptable therefore, it is critical that the correct officers, statutory and non-statutory consultees and other key stakeholders are consulted on and their views properly taken into account before adoption to avoid similar problems again. Whilst laudable, if any document is adopted without concerns or objections being addressed, it can cause a significant delay to the granting of permission for schemes, which will ultimately affect their deliverability. Issue D3: Designing adaptable, diverse and flexible places Q-D3a. We consider that option a – to 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 is the most appropriate option. This would allow a greater flexibility to be considered for individual sites as they come forward for development. There will be a need to take into account the character of the surroundings and density is just one element of this. Issue D4: Safe and attractive streets and public spaces Q-D4.1 Yes. We agree that the range of topics listed is appropriate for a policy on the design of safe and attractive streets. Issue D5: Protecting and enhancing heritage assets Q-D5: Should we continue with the approach to include a high-level strategic policy within Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detail policies to Part 2? Yes. The NPPF advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment

Form ID: 82111
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82112
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82113
Respondent: The Kler Group
Agent: Cerda Planning Ltd

Issue W2: Health Impact Assessments for major development Option W2b. We do not consider that a specific policy on Health Impact is required. From our experience the health impact screening requests often required by LPA’s (to understand whether a full HIA for the specific proposals are required) is just a tick box exercise with no real purpose. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q- W3a. We consider option a which would include an overall policy on heath is the most appropriate for South Warwickshire. A policy worded to address all aspects of health and assist in creating communities which are safe, healthy and inclusive would be consistent with chapter 8 of the NPPF and build upon existing health policies within the Warwick District Local Plan and the Stratford Core Strategy.

Form ID: 82114
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82116
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82117
Respondent: The Kler Group
Agent: Cerda Planning Ltd

No answer given

Issue T1:20-minute neighbourhoods Option T1b: We consider that there should not be a specific blanket approach to a policy on the principles of the 20-minute neighbourhood for new development. We fully acknowledge the benefits of achieving a 20-minute neighbourhood but if applied stringently, this requirement could effectively rule out many sites, which otherwise could come forward to assist the council in meeting its housing requirement. Option b therefore is considered the most appropriate option to allow flexibility of the approach and to allow site specifics to be taken into account. Issue T2: Sustainable transport accessibility across South Warwickshire Q-T2a. We consider that a policy which takes a hierarchical approach in terms of prioritizing transport infrastructure should be taken. This would include lowering of car parking standards for areas where there are good/active public transport links and include opportunities to use existing green and blue infrastructure as potential active travel options. This approach would be consistent with chapter 9 of the Framework which encourages the planning system to actively manage patterns of growth to support the objectives of promoting walking, cycling and public transport and assisting with environmental gain.

Form ID: 82118
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82119
Respondent: The Kler Group
Agent: Cerda Planning Ltd

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Form ID: 82120
Respondent: The Kler Group
Agent: Cerda Planning Ltd

Yes

No answer given

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