Issue and Options 2023
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New searchQ-S1 14. At this stage, reliance should be placed upon the Local Nature Recovery Strategy. Q-S2 15. Richborough Estates is aware of the potential changes to the NPPF concerning increasing density of development and protecting the character or areas by not having too greater density of development. 16. Richborough Estates is supportive of intensification of development in the right locations which are generally geographically within the urban areas. However, the consequence of intensification is twofold. First, the nature of the accommodation provided tends to be smaller dwellings, usually flats, rather than providing a cross section of new homes which is easier to achieve on medium/large sites. Secondly, and although design codes are mentioned, the character of the area inevitably changes, if the density of development is higher than the existing urban fabric, especially within suburban areas. 17. In reality, the density of development should be driven by the character of the surrounding area not just an attempt through specific density targets to potentially overdevelop land within urban areas which leads to unattractive developments and housing types of the wrong type. Having said this, there is scope for medium/large sites, especially greenfield sites, to create their own character and be able to accommodate a different density of development from that which prevails in the surrounding area. Q-3.2 18. There is merit in directing growth to previously developed land within the built-up areas for housing purposes but not at the expense of diluting the employment land offer. Having employment opportunities available within urban areas is important to delivering a 20-minute neighbourhood concept. If employment land is lost to housing within the urban areas then all that happens is the future residents have to commute to the new employment allocations on the edges of settlements or, especially for logistics, remote locations adjacent to transport nodes. Q-S5.2 21. NPPF paragraph 72 refers to the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. “Significant” can mean a different scale of growth dependent upon the size of the settlement. However, a balanced approach to the dispersal of growth to range of settlements rather than just directing new development to a new settlement is to be preferred. 22. As has become increasingly evident through the Government’s Garden Communities Programme, the aspiration to deliver new garden communities is laudable but the cost of delivering a scheme is increasingly difficult without significant intervention in the form of financial assistance. Further, a new settlement is often in a more remote location away from existing settlements or seeks to expand a smaller settlement (e.g. Long Marston) but there is the need for investment by the public sector in delivering the services required to support a community (e.g.M40 improvements at Gaydon). As simple points, a school or healthcare building can be built but it requires the people to operate the facility. 23. By reason of the financial and implementation difficulties, which can extend to securing all the necessary land, a new settlement is not a logical or appropriate option for South Warwickshire at this time. Q-S5.3 24. Some growth along the rail corridors provides a sustainable strategy but consideration needs to be given to the scale of any development at particular settlements. For example, although both are suitable to accommodate new homes, the scale of growth at Kenilworth will inevitably be greater than at Hampton Magna because of the level of facilities and services available. However, it is worth noting that Warwick Parkway is an underutilised transport hub and consideration should be given to more growth at Hampton Magna to exploit the locational credentials of this hub. 25. Further, with the exceptions of parts of Warwick, Leamington Spa and Stratford upon Avon, the majority of the railway stations within South Warwickshire are associated with smaller scale villages located in the Green Belt and both the lack of facilities and Green Belt policy (especially as proposed to be amended in the NPPF) will act as a constraint to significant growth at these villages. Hampton Magna is an exception for the reasons given. Q-S8.1 32. The opportunity should be taken as part of this Local Plan to consider the growth needs and capacity of individual smaller settlements to accommodate growth. In this context, the approach is directed towards growth at the Category 1 and 2 Local Service Villages as identified in the Stratford upon Avon Core Strategy. Growth at Category 3 settlements and below should be a matter for Neighbourhood Plans. Q-S9 33. Settlement boundaries will need to be reviewed to accommodate development.
35. The best way to increase the supply of affordable housing is to increase the supply of viable and deliverable residential sites. The majority of affordable homes are delivered as part of housing schemes. Accordingly, the greater the level of housing to be provided across South Warwickshire the greater the prospect of delivering more affordable homes. 36. However, if the new settlement option is to be adopted then the concerns would be the viability of the scheme would inevitably squeeze the delivery of affordable homes. Similarly, the concerns about the costs of delivering housing schemes which have already been highlighted affect viability and have the potential to squeeze the delivery of affordable homes. 37. Richborough Estates commend a specific affordable housing target based upon the two constituent authorities because each has different circumstances. However, if there is to be a single target then it may well be that a higher localised target is adopted in the AONB given the affordability difficulties of purchasing homes in this particular area.
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38. Richborough Estates recommend that specific allocations are made to meet the specialist housing needs for older people
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Q-H1-1 and H1-2 34. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 39. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 40. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 41. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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Q-C3.1 42. It would be appropriate for a carbon off-setting approach to be established in South Warwickshire as a whole. There is an advantage to this approach because the opportunity exists to improve biodiversity thereby reinforcing the green and blue infrastructure network which are being considered.
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Q-C4.1 43. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 44. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 45. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
