Issue and Options 2023
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New searchQ-S1: While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down. Q-S3.2: While the Respondent recognises the importance of re-using Brownfield land, having considered the options presented in the Consultation Document, Option S3.2a is considered most appropriate in South Warwickshire, with Brownfield sites prioritised only where they are sustainably located and in line with the identified growth strategy. To do otherwise could result in unsustainable patterns of development that would conflict with the overarching vision and strategic objectives of the plan. Q-S4.1: Yes. The Respondent agrees that growth of existing settlements should be part of the overall growth strategy for South Warwickshire. As opposed to new settlements, sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter time frame. Turning to Henley-in-Arden, the Respondent’s site represents a sustainable and logical extension that is capable of being developed without technical impediment and would assist in supporting existing facilities and services at the town. Such matters are discussed in further detail in the site-specific representation at Section 3.0 of this Statement. Q-S5.2: Broadly yes. The Respondent is generally supportive of the inclusion of new settlements in the overall growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery. The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy. Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period. The Lichfield’s Start to Finish (Second Edition) 2020 report may be a helpful starting point in this regard, although any assumptions that are made will need to be fully evidenced having regard to site specific constraints and circumstances. To improve choice and competition and help to mitigate the risk and implications of such sites not coming forward within the timescales envisaged it is recommended that a buffer is applied to the housing need, with a greater number of small-medium sites allocated at sustainable settlements to ensure adequate housing delivery in the short-medium term. Q-S8.1: No. The sustainability of settlements falling outside of the chosen growth strategy will vary to a significant degree and should not therefore be treated as equal. Settlements such as Bishop’s Itchington, which is defined as a Local Service Village under Policy CS15 of the current Stratford-on-Avon Core Strategy, have the potential to accommodate significantly more growth than is being suggested in the current Consultation Document and in the interests of maintaining the vitality and viability of such settlements should not be ignored in the development of a preferred strategy; particularly where they have a good range of facilities and access to public transport services. In such cases it would seem irrational to restrict development via an unnecessarily arbitrary approach. In the Respondent’s view, a comprehensive settlement audit should be undertaken for those settlements that fall outside the identified growth strategy to better understand their functionality and relative sustainability. The results of which can then be used to inform an appropriate distribution strategy across these settlements in a less arbitrary and more transparent way. To do otherwise would put at risk the vitality of such settlements in conflict with Paragraph 79 of the NPPF. Q-S9: Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed further in the response to Q-P1.2.
The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “….. whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (Section 4.6, Page 37, own emphasis) While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the Urban Capacity Study (Paragraph 4.6).
Appendix 2 (Connectivity Analysis for Henley-in-Arden) of the Settlement Analysis indicates particularly poor connectivity to the west, north-east and east of the town which the Respondent would agree with. In respect of land to the north of the town, it is the Respondent’s view that this land should not be graded as high as it has, particularly considering the influence of the dismantled railway embankment that acts as a permanent, physical and visual barrier to rest of the town. If land to the north has been accurately Graded as ‘C’ then, in the Respondent’s view, land to the south should, in turn, be accorded a higher grade (B) in recognition of the absence of any such physical barrier. The respondent also draws attention to the error in the Henley-in-Arden Density Analysis which indicates an area of Green Infrastructure as an ‘Urban Neighbourhood’. There are also notable inconsistencies between the density assumptions made in the settlement analysis versus those made in the Urban Capacity Study; a rationale for which should be provided for the avoidance of doubt.
Yes. The Respondent considers it sensible to look to rail corridors as a preferred approach to the identification of potential locations. However, given the problems and delays that can often occur with the provision of new rail services and stations, it considered that the intensification of existing rail services should be considered before new ones. The Respondent’s site to the south of Henley-in-Arden is an ideal candidate for future housing development in this context given its location within walking distance to Henley-in-Arden Station.
