Issue and Options 2023
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Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Redditch as a major town on its borders that has a significant influence over the western part of the South Warwickshire area. This should be recognised in the description of the area. The following comments are made in respect of the SA for Studley (C.18). The Small Settlement Location for Studley (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. For example, land to the north east falls within the flood zones 2 and 3, and land to the north west would increase the risk of coalescence with Redditch. 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. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design and careful masterplanning. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Studley, and this is a suitable location for growth given its accessibility to facilities and services, including those within Redditch. 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.
The following comments are made in respect of William Davis’s site at Holt Farm (site reference 332), which is referenced as Areas 5 and 6 within the Studley Area. In respect of Connectivity, Area 5 has been assessed as ‘B’ (barriers are negligible and easily overcome) and Area 6 has been assessed as ‘C’ (barriers may be overcome but not easily). For both areas, reference is made to ‘busy route on western edge’. This refers to the A435 which runs through the middle of Studley. Access can be provided onto the A435, and this route is capable of accommodating all modes of transport. Significant residential development and local facilities already exist on the same side of the A435 as these two areas, and therefore the A435 is not a barrier to facilities. There are therefore no significant barriers to connectivity to the settlement from these areas, and this should be rectified in the next iteration of the Analysis to a score of (A). Reference is made to floodplain and sewage works to the east, however this is not a constraint on connectivity. In respect of Landforms, it is noted there are no physical constraints on Areas 5 and 6. It is also noted that Area 5 has all five local facilities within 800m. Area 6 is deficient only in respect of healthcare, however Pool Medical Centre is within 800m of Area 6 and this should be rectified in the next iteration of the Analysis. When taking account of this evidence, the comments above in relation to connectivity, it is clear that Areas 5 and 6 perform best. Comments are also made here in respect of the Heritage Assessment for Studley. This finds that land to south-east of Studley has potential for development in recognition of the lack of historic environment constraints. It is recognised that the north-east of the village is considered to be effectively undevelopable from a historic environment perspective. The relationship between development to the south east of Studley, and the heritage assets further north has been carefully considered by William Davis through its own masterplanning exercise. It is possible to avoid harm to the setting of the assets through the location of development, landscaping, and detailed design. In fact, the ability to provide areas of public open space (possible Country Park) within this area creates an opportunity to enable a greater appreciation of the significance of the setting of the assets to the north. William Davis and its consultants would therefore be very happy to discuss its work with the Councils to demonstrate how heritage assets to the north can be protected. It is also noted the Councils are to undertake a review of the Green Belt to assess whether there are areas which no longer meet all five of the Green Belt purposes and could be removed. It is important that any assessment also has regard to paragraph 142 of the NPPF, and the need to give first consideration to previously developed land and/or land well served by public transport, and also to take into consideration the ability to offset any removal through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. Studley is well served by public transport connections into Redditch and other settlements, and this should be recognised in the review. Moreover, William Davis have demonstrated in its proposal for Holt Farm (site 332) that there is extensive areas of land available for compensatory improvements in terms of public access and environmental quality within a potential new Country Park. In summary, this area is the most suitable location to accommodate a strategic allocation, as it is not environmentally constrained and yet the most accessible to the village and its facilities. Areas 5 and 6 have advantage over areas 8 and 9 (to the south of Studley) in terms of proximity to the village services, but also in terms of connectivity as residents of areas 8 and 9 would have to cross a main road (the A448) to access the village. Further, as there is no development south of the A448 in areas 8 and 9, this would be breaching for the first time a significant edge to the village and increasing the risk of coalescence with Sambourne. William Davis therefore request land within the Areas 5 and 6 form a strategic allocation for Studley.
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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, William Davis consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Greater Birmingham’s unmet needs, this should include Studley given its relationship to Redditch.
Yes, growth of existing settlements in South Warwickshire (and on the edge of 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, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the settlements.
Option S2-C: Intensification 10. 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. 11. 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.
Q-E7.1: Core Opportunity Areas 41. William Davis object to option E7.1a and the exclusion of Studley and the eastern fringe of Redditch from the Core Opportunity Area. This ignores the economic importance of Redditch to this part of South Warwickshire.
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Q-H3: Minimum Space Standards 50. 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.
