Issue and Options 2023

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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Bloor Homes consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Birmingham’s unmet needs, this should include Stratford-upon-Avon given its rail links. As identified above, the Councils will be aware that Stratford–on-Avon District Council’s emerging Site Allocations Plan proposes reserving land east of Shipston Road for housing. This emerging allocation has been identified to help meet Birmingham’s unmet needs.

The following comments are made in respect of the SA for Stratford-upon-Avon. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to 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. The Site promoted by Bloor Homes forms part of Stratford-upon-Avon Southwest (Broad Location 29). In assessing the five Broad Locations (BL) identified against the SA Objectives, the SA concludes that Stratford-upon-Avon East is the least constrained in terms of environmental receptors. However, Stratford-upon-Avon East is not considered developable without significant highway infrastructure improvements, as its only highway connection to the strategic road network is via the Clopton Bridge and the town centre. In the absence of any evidence to demonstrate this BL would be developable in transport terms, it is not therefore a ‘reasonable alternative’ for up to 2,000 homes, and therefore should not be carried forward in the SA process. If such evidence can demonstrate it is developable, the highway infrastructure essential to the delivery of this BL must form part of the SA and therefore this BL will need to be re-assessed in the next iteration. It is also noted that a large part of Stratford-upon-Avon East is a golf course that has not been submitted through the call for sites. If a large proportion of the land is not available, this is not a ‘reasonable alternative’. The following specific comments are made in relation to the SA and Stratford-upon-Avon Southwest. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. This is welcomed as an updated assessment is required, particularly in respect of Stratford-upon-Avon Southwest given the ongoing development of Land west of Shottery and the Western Relief Road. These developments, along with the Employment Area (SUA.2) to the north once built, will significantly change the landscape character of the northern part of this BL (i.e. the land promoted by Bloor Homes for development which was defined as High/Medium in the previous 2011 Assessment). It is worth remembering that paragraph 73. a) of the National Planning Policy Framework (NPPF) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the development at Land west of Shottery and SUA.2. SA Objective 5: Cultural Heritage notes the potential major impact of Stratford-upon-Avon Southwest on the setting of Anne Hathaway’s Cottage. This is reflected in the Heritage and Settlement Sensitivity Assessment. However, it is acknowledged that parts of the area could accommodate development, and therefore harm can be avoided if only part of the BL was proposed for development. The northern part of this BL can be developed without harm to the setting of the heritage assets. SA Objective 10: Health notes that Stratford-upon-Avon Southwest is not within the sustainable target distance of a GP Surgery. However, a Health Centre is a consented element of the Land west of Shottery Development to the immediate north east of the BL, and once completed will change the assessment. The next iteration of the SA should acknowledge the proposed Health Centre in its assessment. SA Objective 11: Accessibility concludes that BLs (other than Northeast) have very poor connectivity. However, Stratford-upon-Avon Southwest has good connectivity to the urban area and its facilities via active travel modes. These routes are shown within the Transport Appraisal and Strategy that is submitted with these representations. With regard to SA Objective 12: Education, Stratford-upon-Avon Southwest falls within the sustainable target distance for all schools, and therefore performs equal best. Notwithstanding, it is to be noted that a new primary school also forms part of the Land west of Shottery Development to the immediate north east of the BL. Further, with regard to SA Objective 13: Economy, Stratford-upon-Avon Southwest falls within the sustainable target distance for employment, and therefore performs equal best. Stratford-upon-Avon Southwest performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, there are parts of the BL that do not result in any negative impacts against the Objectives.

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The following comments are made in respect of Bloor Homes site, which is referenced as Areas 4 and 5 within the Stratford South West Area. Although, please note built development is only proposed on Area 5. In respect of Connectivity, the site has been assessed as ‘D’. However, no account has been taken of the Land west of Shottery mixed use development which includes 800 new homes that are currently under construction by Bloor and Bovis Homes and will be completed within the next 10 years. As identified above, paragraph 73. a) of the NPPF requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The assessment of connectivity must have regard to planned investment, which in this case relates to the Western Relief Road. The Transport Strategy appended to these representations demonstrates how this site would be connected through the West Shottery development under construction and into the existing urban area. It is therefore considered that active and sustainable modes of travel from Areas 4 and 5 to the town can be made into the urban area, and that connectivity is not a barrier that would prevent the area from being a strategic allocation. In respect of Landforms, it is noted there are no physical constraints on Areas 4 and 5. In respect of local facilities within 800m, it is noted that the report highlights the absence of Healthcare and Places to Meet for Areas 4 and 5. However, both facilities are consented within the Land west of Shottery Development to the immediate north east of the Areas. We have no reason to believe they will not be delivered and once completed will mean all facilities are within 800m. The area will then perform equal best. When taking account of the evidence above, Areas 4 and 5 are suitable locations to accommodate a strategic allocation, as there are no barriers to connectivity to the town, no constraints, and facilities are available within 800m. Further, the proposals incorporate a significant area of green infrastructure that could form an extended Country Park west of Shottery. This area would have many benefits, including the delivering of biodiversity net gain as evidenced within the report submitted with these representations.

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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Bloor Homes consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Birmingham’s unmet needs, this should include Stratford-upon-Avon given its rail links.

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, 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 19. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Bloor Homes 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. 20. 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.

Option S2-C: Intensification 17. Intensification is a way to optimise brownfield land and realise its effectiveness. However, Bloor Homes 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. 18. 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.