Issue and Options 2023

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Yes

It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF . It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Rosconn Strategic Land consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases , an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

No answer given

Yes

Yes, Rosconn Strategic Land support the allocation of other sites as necessary for short-term development. These sites should include those already allocated for development within the Draft Site Allocations Plan, such as the land north of Collingham Lane, Long Itchington (Proposal SCB.5 of the SAP). This site has been allocated as a site to deliver 10 self-build and/or custom-build. Its suitability, availability and deliverability has therefore been assessed, and found to be acceptable. The requirement to allocate sites for self-build and custom-build across the District should be confirmed within the South Warwickshire Local Plan Part 1 Document.

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 interest west of Marton Road, with the north and eastern boundary abutting the built up area boundary. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village and covers the site. 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, this site lies within the least sensitive part of the settlement, within parcel ‘LI02’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). LI02 adjoins parcel LI03 to the east where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). In landscape terms, the site aligns with the Council’s own decision-making in this part of Long Itchington, with the Bloor Homes scheme at Bishop Drive, where the landscape’s capacity to accommodate change was considered acceptable. Furthermore, as shown on the Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries which will further reinforce the site’s visual containment. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Long Itchington, with the 2012 Landscape Sensitivity Assessment and subsequent Council decision-making showing the areas of lower sensitivity with capacity to change. 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.

Yes

Yes, growth of existing settlements in South Warwickshire is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the settlements. The following comments are made in respect of Rosconn Strategic Land Site west of Marton Road, Long Itchington (site 478) which falls in part within Area 9, and in part within an area defined as significant public green space. The inclusion of this land in an area of green space is incorrect as the land controlled by Rosconn Strategic Land isn’t publically available and not used as green space. The boundary of Area 9 and the significant public green space should be amended in the next iteration of the Analysis. The connectivity analysis states that Area 9 is graded as ‘C’, defined as with barriers that may be overcome. The commentary states that this location has a ‘fairly busy road access’. Development on Marton Road has been found acceptable in highway terms, such as Bishop Drive, and an access can be provided onto Marton Road from Area 9. The Development Framework Plan that has been prepared to illustrate development proposals for land west of Marton Road includes a proposed access close to the Bishop Drive scheme. Land west of Marton Road should therefore be graded ‘B’. In respect of landform, as noted above, site 478 is not green infrastructure and not public green space. The boundary of this designation should be amended in the next iteration of the Analysis. It is noted that growth to the north of the village is supported in flood risk policy terms, with the area being sequentially preferable to land to the west. In respect of local facilities within 800m, Area 9 scores well with the site scoring 3 out of 5, only marked down for healthcare (due to no facilities within the village at present) and being just outside of the 800m distance to the primary school. Areas 14 and 15 have been scored as 5 out of 5, however these areas 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 9 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 (or just over 800m) of a good range of local facilities. It is noted that Stratford-on-Avon District Council scored the site (LONG.17) negatively within the SHLAA 2021 update. The assessment concluded that the site formed part of an important undeveloped gap to west of the main road, with a mature hedgerow which would have to be removed to achieve an access which could not be mitigated effectively. However, planning permission was granted on 3rd March 2004 for a new 5m gateway access into the field adjacent to playing fields, Marton Road (Ref:03/04009/FUL). The permission was implemented and remains in situ. The accompanying Development Framework Plan also demonstrates how the natural features on site can be retained and that the mature hedgerow along the eastern boundary will not need to be removed to allow for access. In addition, the recreational ground known as ‘Lilac Field’ to the south of the site would remain and therefore provide an undeveloped gap between dwellings on Green End and proposed dwellings on land west of Marton Road. The accompanying Development Framework Plan for land west of Marton Road demonstrates how the built form will be split between the two parcels of land, respecting the settlement pattern to the north of the site. The built form will not extend beyond the existing build line with public open space and landscaping features within the remaining sections of the site. The existing trees along the western boundary and woodland areas within the northern parcel will be retained and incorporated into the development. Furthermore, the development has the potential to deliver additional planting along the northern and western boundaries to form a positive edge to the site. It is therefore considered that the site is capable of accommodating an appropriately designed residential development set within a robust GI framework as presented in the accompanying Development Framework Plan. 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 west of Marton Road, 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.

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Yes

Yes, Rosconn Strategic Land support the allocation of other sites as necessary for short-term development.

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 interest east of Manor Farm, Stockton Road, with the site abutting the built up area boundary on its western and southern boundaries. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village and partly overlaps the site. 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, this site lies within the least sensitive part of the settlement, within parcel ‘LI01’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). For Parcel LI01 the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). This is further explained in the enclosed Landscape Statement (FPCR, October 2020). In landscape terms, the aligns with the Council’s own decision-making in this part of Long Itchington, with the adjoining David Wilson Homes scheme to the south at Keepers Meadow considered to have capacity to accommodate change. Furthermore, as demonstrated in the enclosed Landscape Statement and shown on the Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries to the north and the east. This will further reinforce the site’s visual containment and its clear alignment with the existing built up area as part of a sensitively designed scheme where landscape impacts are minimised. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Long Itchington, with the 2012 Landscape Sensitivity Assessment and subsequent Council decision-making showing the areas of lower sensitivity and with capacity to change. 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.

Yes

Yes, growth of existing settlements in South Warwickshire is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the settlements. The following comments are made in respect of Rosconn Strategic Land Site at Manor Farm, Long Itchington (467) which falls within Area 12. Area 12 is given a ‘C’ grade in terms of connectivity, defined as with barriers that may be 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 12. Reference is also made to the school playing fields to the south, but these are not a barrier to connectivity to the village. The accompanying Development Framework Plan illustrates how a suitable access can be provided to this site from Collingham Lane. 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 12 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 12 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 is noted that Stratford-on-Avon District Council scored the site (LONG.06) negatively within the SHLAA 2021 update. The assessment concluded that access through the existing housing development to the south would not be suitable according to the Highway Authority. However, Rosconn Strategic Land have undertook their own assessment which concludes that access can be provided from Collingham Lane. The supporting Transport Note from Savoy Consulting states that a satisfactory means of access can be provided for the development, and all potential capacity issues on the local highway network can be addressed through the installation of traffic signals at the A423 Southam Road/Stockton Road junction. The SHLAA update 2021 also noted that the site forms part of an extensive open landscape to the north of the village which cannot be mitigated effectively. However FPCR have prepared a Landscape Statement which demonstrates that the site is well contained, relates well to the existing settlement, and is not particularly sensitive in landscape and visual terms. It is well contained by the existing settlement to the south and west including the recent residential development off Stockton Road, Long Itchington Primary School and properties off Collingham Lane. The boundary between the site and existing development is generally defined by a combination of hedgerows and trees. Established vegetation along the site’s boundary to the north and east helps visually contain the site. The Landscape Statement concludes the site is capable of accepting residential development reflective of the scale and size that exists within the settlement. The supporting Development Framework Plan shows how development of the site could be brought forward in a way which respects the local context. This demonstrates the retention and reinforcement of existing landscape features alongside additional planting to the site’s boundaries which will help to further visually contain the site. Retention of the existing field boundary within the site will maintain the existing field pattern. The Development Framework Plan also shows the potential developable area set back from the north east of the site relating to the existing settlement pattern. The positioning of the proposed Public Open Space (POS) would ensure a strong buffer between any future development on this site and the wider countryside to the north and east. In addition, the Development Framework Plan also demonstrates the location of a potential Habitat Creation Area (3.06ha). This land is within the landowner’s ownership which can be provided to deliver biodiversity enhancement as part of this scheme. The scheme can also provide further benefits with 0.8 ha of land available for a potential expansion to the existing Primary School. 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 east of Manor Farm, 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.

Yes

Yes, growth of existing settlements in South Warwickshire is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the settlements. The following comments are made in respect of the site promoted by Rosconn Strategic Land east of Coventry Road, Cubbington (Site 176). The site has not been assessed within the Settlement Analysis, and this should be rectified in the next iteration of the Analysis. An assessment has been undertaken of the site to assist in this process. In relation to connectivity, Site 176 can access onto Coventry Road (red route) which connects directly into the settlement and can accommodate all modes of transport. There are no barriers to connectivity, and therefore the site should be assessed as (A). In relation to landform, there are no flood or green infrastructure constraints on the site. In relation to local facilities within 800m, the adjacent Area 13 scores 4 out of 5 with only healthcare being outside of the 800m distance. The same score would apply to Site 176 as the local surgery is beyond 800m. However, it would still be one of the best performing areas. Overall, Site 176 is therefore considered a suitable location to accommodate development as there are no barriers to connectivity to the village, no constraints, and the site is within 800m of a good range of local facilities.