Issue and Options 2023

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Form ID: 75795
Respondent: Rosconn Strategic Land
Agent: Marrons

No

Rosconn Strategic Land consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and Rosconn Strategic Land consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded. South Warwickshire falls within both the Coventry and Warwickshire Housing Market Area and the Birmingham and Black Country Housing Market Area it is therefore imperative that the SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire.

Form ID: 75802
Respondent: Rosconn Strategic Land
Agent: Marrons

No

Rosconn Strategic Land consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and Rosconn Strategic Land consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded. South Warwickshire falls within both the Coventry and Warwickshire Housing Market Area and the Birmingham and Black Country Housing Market Area it is therefore imperative that the SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire.

Form ID: 75812
Respondent: Rosconn Strategic Land
Agent: Marrons

The following comments are made in respect of the Sustainability Appraisal (SA) for Long Itchington. The Small Settlement Location (SSLs) for Long Itchington includes Rosconn Strategic Land's interest off Collingham Lane. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village. It is clear that certain parts of Long Itchington are more sensitive than others. For example, land to the west is more constrained by flood plain. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. It is clear from Table 5.1 that the only major adverse impacts identified for Long Itchington relate to landscape sensitivity and agricultural land classification. With respect to landscape sensitivity, the SA notes that impacts can be avoided by matching development types with areas with capacity for change. The Rosconn Strategic Land site lies within one such area, as it is the least sensitive part of the settlement within parcel ‘LI01’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). LI01 adjoins parcel LI03 to the north where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). Furthermore, mitigation can be incorporated within the site to enhance the existing strong landscaped and hedgerow boundaries to the south and north east. This will further reinforce the site’s visual containment, and its clear alignment with the existing built up area. On the basis of the above, it is clear that landscape sensitivity to accommodate change should not be an overriding factor to future growth at Long Itchington. With the 2012 Landscape Sensitivity Assessment helpfully showing the areas of lower sensitivity, including an area of land which includes this site. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon the development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Long Itchington and that it is considered as a suitable location for growth, with a good range of facilities available. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.

Form ID: 75822
Respondent: Rosconn Strategic Land
Agent: Marrons

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Form ID: 75832
Respondent: Rosconn Strategic Land
Agent: Marrons

The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF . The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, Rosconn Strategic Land consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF . In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF .

Form ID: 75833
Respondent: Rosconn Strategic Land
Agent: Marrons

Yes

The following comments are made in respect of land off Collingham Lane, Long Itchington. The site lies within Area 11 within the Settlement Design Analysis. In respect of Connectivity, the Area has been assessed as ‘B’. This is defined as having negligible barriers that are easily overcome. The commentary in the Analysis states that Collingham Lane narrows to a single track after first sharp bend. This bend is beyond the edge of the village and would not be a barrier to development within Area 11. Reference is also made to it being a fairly busy road, however suitable and safe access can be provided onto this residential street. As Collingham Lane, is capable of accommodating all modes of transport, there are no barriers to connectivity to the settlement and this should be rectified in the next iteration of the Analysis to a score of (A). In the analysis of landform, there are no constraints, unlike the majority of the western side of Long Itchington which is covered by a flood plain. Therefore growth to the north of the village is supported in flood risk policy terms, with the area being sequentially preferable. In respect of local facilities within 800m, Area 11 scores very well with the site scoring 4 out of 5, only marked down for healthcare due to no facilities within the village at present. Areas 14 and 15 have been scored as 5 out of 5, however these sites appear to have been incorrectly scored as they are not within 800m of healthcare facilities either. The analysis should therefore be updated to reflect this. Area 11 is therefore considered a suitable location to accommodate development as there are no barriers to connectivity to the village, and the site is within 800m of a good range of local facilities. It should also be noted that Stratford-on-Avon District Council scored the Collingham Lane site (LONG.04) positively within the SHLAA 2021 update. The SHLAA concluded that site was ‘likely to be deliverable’. This is supported by the draft allocation of the site within the Site Allocations Plan Revised Preferred Options Consultation (June 2022) for 10 self-build and/or custom-build housing under Proposal SCB.5: North of Collingham Lane, Long Itchington. An Outline Planning Application was submitted to Stratford-on-Avon District Council in September 2021 for up to 9 self-build/ custom build dwellings and a new vehicular access from Collingham lane. The application was refused at Planning Committee on 22nd June 2022, with the decision contrary to the officer’s recommendation to grant permission. In response to the refusal of permission, Rosconn Strategic Land are preparing a revised application for a reduced number of units to address the reasons for refusal outlined above, and compliant with draft policy SCB.5 – land north of Collingham Lane. Paragraph 141 of the NPPF states that before changes are made to Green Belt boundaries, the LPA will need to demonstrate that they have considered all other reasonable options for meeting its identified need for development. LPA’s must therefore demonstrate that they have made use of suitable and underutilised land before Green Belt land is released. Land off Collingham Lane, Long Itchington, should therefore be given priority as this land is outside of the Green Belt and is considered to be a deliverable site to help deliver homes within the plan period.

Form ID: 75834
Respondent: Rosconn Strategic Land
Agent: Marrons

Yes

A higher limit is appropriate

Form ID: 75835
Respondent: Rosconn Strategic Land
Agent: Marrons

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Form ID: 75836
Respondent: Rosconn Strategic Land
Agent: Marrons

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Form ID: 75837
Respondent: Rosconn Strategic Land
Agent: Marrons

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Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Rosconn Strategic Land reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals” . National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF , it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance ; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness , which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, Rosconn Strategic Land consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings.

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