Issue and Options 2023
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New searchQ-D2 51. A Design Guide Framework for South Warwickshire could be devised providing clear principles and standards for new development. More detailed Design Guides for specific areas, including character areas if intensification is to occur, can be produced, could be written by those bodies preparing Neighbourhood Plans if it was felt additional local guidance was required. Q-D3 52. Inclusion of a minimum density policy needs some further thoughts because increasingly housing schemes are including larger areas of green and blue infrastructure to deliver sustainable drainage, retaining features on-site, play spaces, space for new trees, segregated foot/cycleways and providing for biodiversity gain. If a minimum density policy is to be introduced then it needs to be based upon the area which will accommodate the housing itself not the whole of the site. In any event, the density of development of a scheme should be design led, which also means having regard to the character of the area and whether the site could create its own character without harming the area within which it sits. Q-D5 53. In reality there is little merit in having a strategic policy concerning heritage because this is already well addressed in the NPPF. As with Green Belt policy, a reference to the NPPF would be appropriate.
Q-W2 54. The threshold for any Health Impact Assessments being required should be a high threshold (e.g. 150 dwellings) because it is usually the scale of the proposal which has the greatest effect on healthcare provision.
No answer given
Q-T1 55. As a point of clarification for paragraph 4.2.1(d), and although reference is made to the TCPA’s Guide to 20 Minute Neighbourhoods, there needs to be clarity that the 20-minute time period is for a single journey and not a return journey. The only specific example of a 10-minute journey both out and back equating to 20 minutes is in Melbourne. 56. Other than for new communities, it is difficult to achieve a 20-minute neighbourhood for extensions to Main Settlements or Smaller Settlement Locations because the day-to-day facilities are not always available with the immediate area. A typical example of this is a secondary school which are not a high frequency type of facility. The critical point is that there is good access to a range of day-to-day facilities on foot and cycle and, if appropriate, higher order facilities by public transport. Q-T2 57. Richborough Estates is supportive of policies that support sustainable and active travel options. A hierarchical approach would, however, include the increasing role of mobility through technology and different modes of travel. For example, the role of the internet in meaning people do not actually need to travel to work or shops should be fully considered alongside e-scooters and e-bikes as reducing the effort needed for people to use active travel options, which more people are more willing to travel a longer distance compared to mechanical scooters and bikes.
Q-B3 58. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 59. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy
General Comments 2. As a starting point, it is recognised that the Part 1 Local Plan is intended to set out the overall strategy for the pattern, scale and design quality of places in South Warwickshire. The Part 1 Local Plan is also intended to make sufficient provision for housing and employment. However, there is a lack of clarity about where specific allocations for growth, of whatever scale, will be made. This comment arises because at page 2 of the Consultation document reference is made to a Part 2 Local Plan “…could include allocating sites and the provision at a local level…”. Clarity is required about whether the Part 1 or Part 2 Local Plan (or indeed Neighbourhood Plans) will be positively identifying allocations outside the Main Towns. 3. As a further point of clarity, albeit specific to Stratford on Avon District, some Neighbourhood Plans have responded positively to Policy CS16 of the Core Strategy and have formally identified reserve housing sites (e.g. Wellesbourne). Although the District Council is still proceeding with the preparation of the Site Allocations Plan (SAP), clarity is required that current reserve housing sites allocated in the Development Plan will be taken forward whether into the SAP or this Local Plan. 4. A corollary is that E8.1 raises a specific question about whether “Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP”. The same question should have been asked about reserve housing sites.
Q-V3.1 and Q-3.2 5. An important contextual point for the Vision and Objectives is that the National Planning Policy Framework (NPPF) at paragraph 7 states that the objective of achieving sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. Richborough Estates does not take issue with the generic Vision for South Warwickshire. However, there does need to be greater clarity in the Vision concerning the Local Plan delivering the necessary opportunities over the plan period to meet the current housing and employment needs. 6. There are specific objectives which do not obviously follow from the Vision such as reference to net zero carbon targets, creating attractive places and a healthy, safe and inclusive South Warwickshire. Having homes for people to live in and the availability of jobs is also an important part of sustainable growth, meeting the needs of the community and reducing the need to travel outside South Warwickshire.
