Issue and Options 2023
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Q-S2: As set out at Paragraph 124 of the NPPF, planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area -based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate; however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-S3.2: The NPPF clearly identifies at Paragraph 120 that planning policies should give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 141 highlights that before concluding that e xceptional circumstances exist to justify Green Belt boundaries consideration should be given as to whether the strategy inter alia makes as much use as possible of suitable brownfield sites and underutilised land. The test is therefore one of ‘suitabilit y’. The prioritisation of brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area is a logical approach. Again, we would suggest that there is a need to understand existing housing and employment need in the first instance to then understand what the appropriate policy response is to meet that need. As set out below in respect of Questions Q-S4.1 and Q-S4.2 the Council’s own Settlement Analysis demonstrates the suitability of some greenfield sites, including CEMEX’s land interest at Long Itchington to have good connectivity and access to services and thus a sustainable location for growth. Q-S5.2: Do you think new settlements should be part of the overall strategy? New settlements could be included as part of the overall strategy for development across the plan period to 2050. However new settlements have long lead in periods and often rely on complex land assembly as well as infrastructure funding and delivery which is out of the control of the Planning Authority. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are likely to be towards the end of the plan period. As such the overall strategy should be positive and proactive and we would suggest that smaller development as well as infill sites are included in order to meet the housing demand. Q-S7.2: Growth Options 1 and 2 rely on the creation of new settlements (6,000 new dwel lings or more) linked to the achievement of new or reopened rail corridors. As set out above, new settlements have long lead in periods, often rely on complex land assembly and in this instance are reliant on notable infrastructure funding and delivery outside of the control of the districts. Whilst the plan period to 2050 provides time for any such settlement(s) to come forward, they are likely to be towards the end of the plan period. There is a pressing need for delivery of housing and economic growth now therefore we would caution against an approach that seek to rely on meeting a substantial proportion of housing need through standalone settlements. In our view in order to meet a range of housing and economic needs and provide a sufficient and deliverable supply of housing land, a mixture of the different options would be preferable. There is a need to enable a steady delivery of sites and housing which meets short and medium term housing needs. Whilst it is noted that the priority should be brownfield, housing numbers are unlikely to be met through brownfield sites alone, therefore sustainable greenfield development sites should be reviewed and included in the overall strategy for delivery. Long Itchington is identified as a settlement/location that may feature in Growth Options 3, 4 and 5. The land south of Stockton Road would therefore be compatible with a number of the Growth Options. Long Itchington is a Category 1 Local Service Village, development of the site would not extend the village any further east than the built out site to the north of Stockton Road. As per the Settlement Analysis, the site is located within 800m of Local Facilities, it has access to all items identified: retail, jobs and economy; places to meet; open space, leisure, recreation – wellbeing; healthcare and education. This means it is one of the highest scoring sites. This shows that the site is a positive development prospect at the edge of the settlement and has good prospect for growth in the context of connectivity and accessibility. In our view there is a need for the SWLP to consider housing land supply in this context and the approach of preparing a Part 1 and Part 2 plans and what this means for the housing trajectory, achieving sustainable growth and meeting housing need. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Meeting housing need is likely to rely on achieving housing supply from most settlements. The threshold approach is arbitrary. It is used in the Core Strategy and sets a notional percentage increase for each settlement, however this percentage has been exceeded for many settlements demonstrating that the approach is flawed and does not allow for the future requirement for growth or an appropriate measure or achievement of ‘good growth’. Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? Please see answer to Q-S8.1 which sets out the reasoning as to why the threshold approach is flawed in terms of achieving housing growth across the life of the Development Plan. Q-S9: We would suggest that there is an opportunity for the Council to review settlement boundaries ahead of preparing Part 2 of the Local Plan to see that they are logical and consistent with the growth strategy. The settlement boundary for Long Itchington is incongruous in nature due to the form of development to the north, whilst not including all land which is part of the locality. It is our position, based on the landscape evidence provided in the call for sites, that the inclusion of the site within the settlement boundary would be a logical conclusion to the eastern expansion of Long Itchington that has already been approved and implemented. Such an approach is also consistent with the east west linear nature of the settlement pattern. As noted above in our view there is a need for the SWLP to consider housing land supply and what the approach of preparing a Part 1 and Part 2 plans means for the housing trajectory. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. A review of settlement boundaries as part of Part 1 could form part of that approach.
Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, growth of existing settlements can be a highly sustainable form of development but it should be considered on a case by case basis. The NPPF encourages plan-makers to ensure that all plans promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment, mitigate climate change, and adapt to its effects (Paragraph 11a). Allowing for suitable levels of development to be added to existing settlements would promote a sustainable development pattern. The CEMEX Long Itchington site is located just outside the existing built up area boundary of Long Itchington and offers the opportunity to provide a logical residential infill development. This would be a minor alteration to the settlement boundary and provide a logical conclusion to the eastern expansion of Long Itchington which is linear in its character. Q-S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on The Settlement Analysis focuses on 3 key components: Connectivity, Accessibility and Density. Long Itchington is identified as an additional settlement for assessment. The site is allocated as area number 14, it is found to have a Connectivity Grade of B, where A is the best connectivity. The Connectivity Grade Analysis states that there are cycle routes to the south along the canal and track access from the road to towpath. A potential connection to cycle route and link along the canal and discussed railway to the south. No readings are given in terms of landform analysis, i.e. the site is not within Flood Zones 2 and 3 nor is it green infrastructure. In regards to Local Facilities within 800m of the site, it has access to all items identified: retail, jobs and economy; places to meet; open space, leisure, recreation – wellbeing; healthcare and education. This means it is one of the highest scoring sites, the only other being the CEMEX site to the south (area 15). This shows that the site is a positive development prospect at the edge of the settlement and has good prospect for growth in the context of connectivity and accessibility. The most recent SHLAA (September 2021) finds that the Long Itchington site (LONG.07) secures some ‘Amber’ issues and one ‘Red’ and concludes that the site can contribute 39 units in years 1 – 5. In order to support the promotion of the Site through the emerging Development Plan CEMEX has undertaken an exercise to update the evidence base and respond to the amber and red issues identified. An illustrative layout has also been prepared to demonstrate how development can be brought forward on the site (see Appendix 2). A Pre-Application request was submitted to agree to remove the technical impediments to delivery (see Appendix 2 for updated pack). The Case Officer’s Preapplication Response (see Appendix 3) suggested that further advice was required from County Officers in regard to Ecology, Landscape, Heritage, Transport, and Flooding. It should be noted that Stantec held preapplication discussions with Warwickshire County Council as Lead Local Flood Authority which informed the suggested illustrative masterplan. CEMEX has instructed the engagement with the remaining consultees and pre-application requests have been submitted seeking further advice. The consultant team has prepared a further update to their reports as part of the evidence base and this is submitted in support of the Call for Sites submission, it shows that there are no technical impediments to the site coming forward for development. We would therefore suggest that there is a need for the Council to undertake a further review through the HELAA.
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Q-H3: The matters set out above are of importance and should be reflected in the Local Plan Part 1.
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Q-C9.1: Biodiversity Net Gain has been introduced into national guidance; it aims to leave the natural environment in a measurably better state than it was to start with. It should be reflected in Local Plan Part 1.
Q-D2: As per earlier comments Paragraph 124 of the NPPF sets out that planning policies should support development that makes efficient use of land. Moreover Paragraph 127 states that area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. We would suggest that there is a need to understand existing housing need in the first instance, the ability for that need to be accommodated in the plan area and the policy response needed to meet that need. The use of design codes is appropriate; however we would caution against an approach that relies on numerous Design Codes needing to be prepared at Part 2 as it could delay delivery. Q-D3: As above, the NPPF states that area based character assessments, design guides and codes and masterplans can be used to help achieve well-designed places which make efficient use of land. We would suggest that density ranges can be suitable in signalling what type of development the Council would expect to see in certain areas however we would caution against not providing any flexibility in the ranges to allow for specific circumstances. The aim should be to optimise sites.
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Q-T1: ‘20 minute neighbourhoods’ or the ’15 minute city’ relate to the creation of compact connected places where people can meet their everyday needs within a short walk or a cycle. The TCPA note that the re are multiple benefits to this approach to development, such as improved mental and physical health, reduction in traffic and improvement in air quality, as well as helping local businesses. We would support inclusion of a policy referencing the principles of a 20 minute neighbourhood or other similar approach; however we would caution against being too prescriptive.
Q-B8.1: We support the intention to review development on agricultural land where the harm would be outweighed by the benefit of development.
As noted above in our view there is a need for the SWLP to consider housing land supply and what the approach of preparing a Part 1 and Part 2 plans means for the housing trajectory. In our view Part 2 should be prepared in tandem, or there should be the allocation of smaller ‘non strategic’ sites or a policy approach that facilitates early delivery to maintain supply. A review of settlement boundaries as part of Part 1 could form part of that approach.
