Issue and Options 2023

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2.93. No. The Respondent has significant concerns regarding the preparation of a two-part plan. The Respondent’s main concern with regards to a two-tier system is the inevitable delay in plan-making that will occur as result and the impact that this will have on the ability to deliver the Councils’ growth strategy in a timely manner, including the delivery of market and affordable housing. 2.94. The current two-tier approach in Stratford-on-Avon District Council is a prime example of where significant delays in the preparation of second tier policy documents have occurred. In proposing a two-tier SWLP, the authorities are in danger of repeating the same mistakes of the Stratford on Avon Local Plan and putting in place a Plan that will genuinely not be reviewed every five years as required by national guidance. 2.95. Owing to the interrelationship between a Part 1 strategic plan and subsequent lower tier plans there will also be no flexibility in the second-tier documents to make changes to the development strategy to reflect any updated evidence needs. This is a particular concern given the projected end date of the plan. 2.96. While it is noted that the intention is to “allow for a flexible, robust and long-lasting framework” this can be difficult to achieve in practice and will need to be given very careful consideration when policies are drafted. 2.97. The South Worcestershire Development Plan has demonstrated that it is entirely possible for authorities to work together to produce a complex development plan covering all aspects of managing growth across three or four LPAs without recourse to a divisive and time-consuming two-tier approach. 2.98. On this basis, it is considered that a comprehensive local plan should be prepared that includes a full complement of allocations and development management policies; with Area Action Plans, Neighbourhood Plans, Design Codes and Design Briefs/Masterplans prepared in a timely, albeit subsequent, timeframe.

3.0 Land off Old Budbrooke Road, Hampton Magna 3.1. This Section of the Statement promotes land to the west of Old Budbrooke Road, Hampton Magna which the Respondent can confirm is under the sole control of William Davis Homes and is available for residential development. William Davis Homes 3.2. William Davis Homes has more than eight decades of experience as a quality housebuilder and are proud to have secured the industry’s gold standard ‘5 star’ status − awarded by the Home Builders Federation - seven years running. 3.3. As a housebuilder, with a directly employed workforce, they have the knowledge and capability to bring forward and deliver residential sites almost immediately upon allocation, which is often not the case where a site has been promoted by a strategic land promotion company or landowner due to the need to sell the site on. The Site 3.4. The Respondent’s site is located to the west of the village of Hampton Magna at land off Old Budbrooke Road. Hampton Magna is located approximately 3 miles to the west of Warwick and lies within the Parish of Budbrooke within Warwick District. 3.5. Hampton Magna was originally founded on the site of the former Budbrooke Barracks during the late 1960’s and 1970’s. The village is relatively small and its appearance is of its time but it has a good range of services and facilities including: • Primary School: • Medical Centre: • Post Office and Convenience Store: • Play areas • Community Centre 3.6. The Site itself comprises approximately 21.1 hectares of predominantly arable land, with some pasture and horticulture activity. Of note is its proximity to Warwick Parkway Rail Station, which is situated on the north-western side of Warwick and within a 10-minute walk of the site, along a footway that runs the entire length of Old Budbrooke Road. 3.7. A comprehensive summary of the site’s constraints and opportunities is set out in the accompanying Promotion Document which confirms that there are no technical impediments to the development of the site for residential use. Planning Considerations 3.8. The village is, on the whole, relatively unconstrained in so far as it is not subject to any local or national landscape designation (i.e., SLA, AONB). Nor does it hold any particular value in heritage terms. The village was substantially developed in the 1960s-70s and, as such, contains very few listed buildings and no Conservation Area. 3.9. Whilst Natural England's Provisional Agricultural Land Classification Map indicates that the site comprises Grade 3 Agricultural Land the same provisional classification applies to all the land surrounding Hampton Magna and is not therefore considered to be an insurmountable constraint to development. The site is, however, located within the West Midlands Green Belt which has severely prohibited the village’s growth. Why release land at Hampton Magna from the Green Belt? 3.10. Green Belt is designed to prevent urban sprawl through the unplanned expansion of urban areas. While it is a successful spatial planning tool in this regard, it can have significant implications on the ability to deliver otherwise sustainable patterns of development. In recognition of this, there are mechanisms within National Planning Policy to enable Green Belt Review. 3.11. The Issues and Options Consultation Document (January 2023) sets out five options for growth (1-5) as follows: • Option 1: Rail Corridors • Option 2: Sustainable Travel • Option 3: Economy • Option 4: Sustainable Travel and Economy • Option 5: Dispersed 3.12. It noted that all five growth options include Hampton Magna as a potential location for growth. However, it is understood that the option currently considered to best align with mitigating climate change, following completion of a Sustainability Appraisal, is Option 2. This option is a hybrid of the Rail Corridor and Bus Corridor Options presented at the Scoping Consultation stage. It is therefore expected that improving connectivity and locating development in highly sustainable locations, with access to public transport, and particularly rail, is likely to remain the focus of the joint authorities’ overarching strategy. 3.13. Given that there are so few settlements within South Warwickshire with rail stations outside of the Green Belt it is considered somewhat inevitable that in order to release sufficient land for development within the most sustainable locations with regards to sustainable travel options that there must be Green Belt release. 3.14. Paragraph 142 of the NPPF provides that where it has been concluded that it is necessary to release Green Belt land for development that plans should give first consideration to land which has been previously developed and/or well-served by public transport. 3.15. Hampton Magna is one of only a small number of settlements that benefit from an existing rail station with frequent services to a major urban centre (in this case Warwick, Birmingham and London) and, aside from the Green Belt, is relatively unconstrainted. It is for these reasons that the village has been identified as a potential location for growth under all five growth options set out in the Issues and Options Consultation Document. Why Release Land at Old Budbrooke Road for Development? 3.16. The site constitutes a logical and sustainable location that is consistent with the historic evolution of the settlement and benefits from close proximity to the village’s facilities. The site is within a 10-minute walking distance of Warwick Parkway Station and provides an excellent opportunity to realise the Council’s ambition to apply the principles of the 20-minute neighbourhood. Such benefits also mean making better use of existing infrastructure without significant investment being required. 3.17. The site is ideally situated on the western side of the village and will not lead to the coalescence of Hampton Magna with Warwick. This notably sets it apart from other options considered in the Councils’ Settlement Analysis, particularly the alternatives to the north-east and east of the village which would significantly reduce the visual gap between the village and Warwick in addition to those to the south, which suffer greater heritage implications. Assessment against the Purposes of the Green Belt 3.18. The representations set out in this Statement makes clear that irrespective of the options taken forward in the SWLP that Hampton Magna should be considered as a location for growth despite is location within the Green Belt. Whilst development could be provided outside of the Green Belt, there is a concern that a blanket exclusion on development would be counterproductive to the economic and social wellbeing of those areas within the Green Belt and give rise to an unsustainable pattern of development by pushing development to areas that are inherently less sustainable. 3.19. Paragraphs 137 to 143 of the NPPF provides the necessary guidance for the review of Green Belt. The joint authorities will need to be satisfied that there are exceptional circumstances to justify Green Belt release and should look to release land that does not compromise the five purposes of including land within the Green Belt. A Green Belt Review will therefore be an essential component of the evidence base. Set out below is a brief overview of the performance of the Respondent’s site against these five purposes: 1. To check the unrestricted sprawl of large built-up areas. 3.20. Hampton Magna is not a large built-up urban area, although it is located to the west of Warwick, which is. Given the location of the site to the west of Hampton Magna its development would not have any bearing on the risk of urban sprawl with Warwick and would therefore preserve the function of the Green Belt in accordance with this purpose. 2. Prevent neighbouring towns merging into one another. 3.21. The western expansion of Hampton Magna will not lead to the coalescence of one town with another and, in the particular circumstances of this case, the wider urban area of Warwick. The site is well-contained by mature vegetation and presents clearly defined boundaries which would provide a distinctive and defensible edge to new built form, further preventing the risk of unrestricted sprawl. 3. To assist in safeguarding the countryside from encroachment. 3.22. The extension of Hampton Magna to the west would lead to the expansion of development into the countryside. However, this ignores the location of the site within the urban fridge and how it is already seen in the context of existing development at Hampton Magna. Enhancements to existing green infrastructure and the maintenance of existing Public Rights of Way provide an ideal framework against which defendable boundaries can be designed, limiting the extent of any perceived encroachment into the wider landscape. Development of the site would also provide opportunity for a new and significantly improved defined edge to the village. The broad thrust and function of the purpose of the Green Belt in safeguarding the countryside from encroachment in this location would therefore remain essentially unaffected. 4. To preserve the setting and special character of historic towns. 3.23. Hampton Magna has no recognised historic qualities or character to speak of. The site does not lie within or alongside a historic town, with the closest Conservation Area located 1.2km to the east in Warwick. The western side of the village performs no role in providing a setting for Warwick and is considered neutral in this respect. 5. To assist urban regeneration by encouraging recycling of derelict and other urban land. 3.24. While the site itself is greenfield its release does not in any way disincentivise the urban regeneration of sites elsewhere in the plan area. That said, in terms of the wider issue of encouraging the redevelopment of brownfield land within the plan area, it is simply unrealistic to expect the level of housing proposed to be accommodated on brownfield sites alone. The Urban Capacity Study (October 2022) confirms that it will be impossible to meet the development needs of South Warwickshire without significant greenfield development. It is therefore considered inevitable that both greenfield and Green Belt land will need to be released as has been the case in previous Local Plans. Conclusion 3.25. Given the scale of housing need and the significant consequences for sustainable development within the plan area if Green Belt is not released, the exceptional circumstances threshold set out under Paragraph 140 of the NPPF is considered to be met. Unlike other options, the release of land to the west of Hampton Magna would not compromise the five purposes set out under Paragraph 138 of the NPPF. The release of the Respondent’s land off Old Budbrooke Road from the Green Belt is therefore supportable in principle, unlike other options. Vision 3.26. The Vision for the site has been informed by the site’s location, the unique local character and context and identified aspirations and priorities for the local area, as well as the site-specific considerations and core design principles that will help to inform the formulation of a detailed and high-quality scheme in due course. 3.27. The Promotion Document that accompanies these representations, while it illustrates only one way in which the site could be developed, emphasises the reasons why the site is deliverable and, if allocated, explains how the development will help to meet identified local housing needs and provide meaningful benefits for the local community. Conclusion 3.28. It is clear from the accompanying Promotion Document that, aside from Green Belt, the Respondent’s site at Hampton Magna is not subject to any major constraints and, as such, would be capable of being delivered in a relatively short period of time post adoption of the plan given that the site is already in the control of a housebuilder. 3.29. While the Promotion Document illustrates only one way in which the site could be developed, it demonstrates that land to the west of Hampton Magna would constitute a logical and suitable location for sustainable development and outperforms other available options at the village. Through comprehensive analysis of the contextual, planning and technical parameters it also provides evidence that the site is an appropriate location for development proximate to Warwick Parkway Station, is available now and is deliverable without any technical impediments. 3.30. In light of the above, it is therefore the Respondent’s belief that their site at Hampton Magna is the superior option for the accommodation of new homes at the village and accordingly should be allocated for housing development for around 250 dwellings to assist in meeting the housing requirement of the SWLP in a positive and effective way in accordance with both Paragraph 79 of the NPPF and the tests of soundness set out under Paragraph 35 of the NPPF.

Q-S2: Intensification is a way to optimise brownfield land and realise its effectiveness. However, William Davis consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided.

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Q-H3: Whilst the provision homes of an appropriate range and size is supported, William Davis are concerned that the blanket application of Nationally Described Space Standards across South Warwickshire could significantly and negatively impact viability in areas with high levels of unaffordability. There are already substantial existing and emerging policy and building regulations requirements (e.g. biodiversity net gain and future homes standard), combined with fluctuations in the housing market and construction costs that are impacting development viability. The cumulative effects of all proposed plan policies will need to be viability tested, in accordance with national policy. The result may be a choice between policies such as minimum space standards and a lowering of the affordable housing requirement relative to existing expectations.

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Q-T1: The concept of the 20 minute neighbourhood is supported and William Davis would be content with Option T1c, meaning a bespoke policy requiring the principles of a 20 minute neighbourhood is included within appropriate development proposals. As explained elsewhere within these representations and supporting Vision Document, Shipston is a sustainable settlement, and the Site at Furze Hill is well connected to the town centre and existing amenities, which the SWLP evidence recognises. This also aligns with recent changes to the development management system whereby Active Travel England are now a statutory consultee for development of a certain scale.