Issue and Options 2023
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New search6. 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.
7. Chapter 11: A biodiverse and environmentally resilient South Warwickshire Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
8.1. There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.
9. Land North of Mill Street, Harbury 9.1. Rainier Developments is promoting land north of Mill Street, Harbury for residential development, including on-site public open space. 9.2. The land comprises of two adjoining agricultural fields, each field is defined by hedgerow and tree planting. The existing built development to the north of Mill Street is excluded from the site boundary (please see Concept Masterplan enclosed at Appendix 3). 9.3. The area is characterised by existing residential development and associated local services and facilities. It is notable that existing built development on Mill Street extends further north on land to the east and west of the Site. The Concept Masterplan has carefully considered the existing built form and settlement pattern. This is reflected in the concentration of built development towards Mill Street, with proposed open space, play facilities and sustainable drainage systems proposed towards the northern boundary. 9.4. Harbury benefits from access to a range of local services and facilities, notably Harbury Surgery, Harbury Primary School, Village Hall and playing fields. There are existing bus stops throughout the village which provide services to Leamington Spa, Southam and Long Itchington. 9.5. It should be noted that the currently adopted Core Strategy identifies Harbury as a Category 1 Settlement alongside Bishop’s Itchington, Long Itchington, Quinton and Tiddington. This clearly reflects that settlement is a sustainable location for growth and the South Warwickshire Plan should reflect this. 9.6. It is also of relevance to note that this Site was identified as a reserve housing allocation in the December 2020 Site Allocation Plan Preferred Options (prepared by Stratford-on-Avon Councill: Site Reference HAR.C*). This clearly demonstrates that the Council has previously assessed the site and concluded it is suitable to accommodate residential development. The only reason the allocation was omitted in the July 2022 Preferred Options SAP was the Council considered Harbury had met its housing development apportionment and did not require further development at this time, under the Core Strategy. Representations were submitted at the time to query this approach however, of relevance to the South Warwickshire Local Plan, is that the proposed allocation was not omitted due to any overriding constraints that would preclude the development of this Site for residential use. 9.7. A Landscape Position Note (enclosed at Appendix 4) sets out that the site makes a limited contribution to the Feldon landscape and that the Site could be developed without undermining the local landscape character. Sustainability Appraisal (SA) 9.8. The settlement has not been identified as a ‘Small Settlement’ within the SA. At Figure 3.4 the SA sets out the procedure for identifying reasonable alternative small settlement locations, these are replicated below, with additional commentary regarding Harbury added in italics: • Over 50% of the potential location should be within 400m if the small settlement edge. This is achievable for Harbury. • Over 50% of the potential location should be within 800m of a least one of the following services: public transport access point (train station or bus station), GP surgery, a primary school, a local shop and/or publicly accessible green space. This is achievable for Harbury which has bus stops, a GP surgery, a primary school, a local shop (Cooperative Food Shop) and publicly accessible green space (for example the play area and playing fields co-located with the Village Hall. • Over 50% of each field/land parcel does not coincide with a constraint including Flood Zones 2 or 3, AONB, ALC Grade 1, Scheduled Monuments, SSSI, Registered Parks and Gardens and ancient woodland. This is achievable for Harbury as there are no areas of flood zones 2 or 3 adjoining the village, the closest AONB is the Cotswolds which is well separated from the settlement (south of the M40), the Natural England ALC maps show no Grade 1 land around the settlement, the closest SSSI is Harbury Railway Cutting SSSI to the north however this could be avoided by much of the land around the settlement (including this Site), the are no registered parks and gardens in proximity of Harbury and the closest ancient woodland is located to the south circa 1.4km from the southern edge of the settlement. • Sports facilities and publicly accessible greenspaces are included in the potential location, although it is assumed that these would be retained. There are existing playing field facilities on the southern edge of the settlement. The rest of the settlement surroundings are not constrained by existing sports uses. • Farms and private residential properties are excluded from the potential locations where practical. This Site demonstrates this approach and this could be taken across Harbury. • Only greenfield locations, such as agricultural fields, have not been included. The identification of small settlements locations does not include Previously Developed Land. The land surrounding Harbury is majority greenfield, agricultural land. 9.9. It is clear that Harbury meets the criteria outlined in the SA to be considered as a small settlement however it has not been. It is not clearly set out in the SA why certain settlements, such as Harbury, have not been included and therefore all reasonable alternatives have not been considered. Harbury should be assessed as a small settlement, suitable to accommodate growth, and the next iteration of the SA should include this. Summary 9.10. In accordance with national policy, this section sets out the suitability, achievability and deliverability of this Site. Suitability 9.11. The Concept Masterplan indicates how a residential scheme can be achieved having regard to the site constraints and opportunities. 9.12. The site benefits from a sustainable location within Harbury and is well placed to meet the housing needs of the area. The site is well-placed to ensure easy access to a range of services and facilities including public transport. 9.13. The Concept Masterplan shows how the site would follow the existing building line along and settlement pattern of Harbury through the location of open space towards the northern part of the site with built development in the southern part of the site around Mill Road. 9.14. The site is not subject to any statutory nature or heritage designations. The site is entirely within Flood Zone 1 which represents the lowest risk of flooding. The Site could deliver sustainable drainage systems (SuDS) as part of any development. 9.15. In view of the above, there are no known constraints which would prevent development of this site. 9.16. Rainier have a land interest in the Site and are promoting the site for residential development. The Site has already been submitted as part of the Call for Sites exercise associated with the Scoping Consultation in 2021, and accompanying representations were also submitted. 9.17. Rainier is a strategic land and development company operating across the UK and with a strong track record for delivering high-quality development. 9.18. Rainier’s willingness for residential development to be delivered on this site is demonstrated through the submission of this representation and previous representations throughout the preparation of the South Warwickshire Local Plan. 9.19. As set out above, there are no known constraints which would prevent the delivery of residential development on this site. Availability 9.20. Rainier have a land interest in this Site and are actively promoting the Site for residential development. The site is immediately available and could deliver housing in the early part of the Plan period.
Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why 2.1. As set out in response to the Scoping and Call for Sites consultation, Rainier supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Rainier supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered, do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning, however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.
3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements, and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options consultation the SA has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA 3.6. The principle and broad approach of the SA is supported and it is recognised that the SA is at an early stage, however the SA only considers a limited number of settlements. As the Plan progresses it will be necessary to undertake a wider analysis of other settlements as these are reasonable alternatives.
Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.
