Issue and Options 2023
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New searchQ-W2 56. 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.
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Q-T1 57. 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. 58. 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 59. 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 60. 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 61. 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. Kineton). 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.
7. Richborough Estates is concerned with the quality of the Sustainability Appraisal (SA), specifically the Evaluation of Small Settlement Locations (Chapter 5 and Appendix C). 8. The first issue is the lack of transparency about the methodology to identify Small Settlement Locations which appears just to be based upon a list of locations provided by the Councils. There is not a background paper nor a technical note which assists in understanding the criteria relating to accessibility and positioning in the settlement hierarchy. As an example, how does South of Coventry qualify as one of the “….22 small settlement locations….” identified by the Council (paragraph 3.7.1). This is a general location not a settlement. Having said this, Richborough Estates is fully supportive of Kineton being a chosen Small Settlement Location for growth. 9. The second issue relates to how the scale of growth and the locations identified on the settlement plans included at SA Appendix C were assessed. Was it reasonable that “The small settlement locations are designed to accommodate between 50 and 500 units at a dwelling per hectare scale of 35dph” (Figure 3.4). This upper end of the scale of growth assessed is more appropriate to Main Settlements and not Smaller Settlement Locations. The maximum scale of growth assessed should be consummate with size of the settlement. 10. Potentially assessing a significant scale of the growth at a single settlement, or location at a settlement, is unrealistic and has skewed or distorted the outcome of the assessment process. Such an outcome is unhelpful in circumstances where there are clearly opportunities for lower levels of growth at the Smaller Settlement Locations, including on smaller and discrete sizes of site, which would not result in the same negative outcomes,. Indeed, choices about the suitability and appropriateness of some sites have already been established through Neighbourhood Plans and these choices should be embedded into the Local Plan. 11. Having read through the SA there are also some concerns about its content and conclusions. Just as simple examples, SA Figure 6.1 identifies Wilmcote as a Main Town which is clearly not the case. At Paragraph 5.6.5 the SA states that “The location at Kineton has the potential to also adversely impact the Cotswolds AONB and therefore this location is worst performing overall”. However, factually it is hard to understand this assessment given the AONB is some 4 kilometres from Kineton and for a large part MOD Kineton is in between the settlement and the boundary of the AONB. There are other examples which raise significant concerns about the approach and judgements reached in the SA and whether they have contributed towards objectively supported outcomes rather than skewed and distorted conclusions. 12. Although not unique to this SA and it is accepted there will be a transition period, the phasing out of internal combustion engines in favour of electric propulsion will have an effect on the assessment process where the concern is to minimise travel because of carbon reductions, whether for carbon or air quality reasons. The SA should at least recognise this trend, especially where new homes and business will have electric vehicle charging opportunities built-in at the outset.
13. Viability is a critical issue and should not be underestimated, especially for new settlement proposals where the infrastructure required is both significant in scale and cost. However, it is not just infrastructure costs which affect viability but the increasing cost of construction whether caused by inflationary pressure or regulations. There are also costs associated with, for example, providing on-site Biodiversity Net Gain, not just monetary but also reducing the extent of built development which affects the value of the overall site. Further, there may be additional cost burdens for all development associated with policies which will be included in the Local Plan or there is an unreasonable expectation about the proportion of affordable homes provided as part of allocated housing schemes. 14. In addition, there is an increasing desire at national and local level to push the infrastructure cost burden onto the landowner to mitigate all impacts and for a proposal to make an ever greater contribution, in whatever form, to the wider community. Alongside any Planning Obligations (assuming this regime remains in its current form), there also is the payment of the Community Infrastructure Levy. All these costs, combined with capital gains tax being paid on land transactions (which may well increase), is increasingly raising a question with landowners about whether it is worthwhile for their land to be developed for much needed housing or employment rather than retain a long term income for the current use? 15. For clarity, through this response Richborough Estates recognises that a fair and reasonable contribution should be paid towards appropriate infrastructure, but the Councils equally need to recognise that there are increasingly significant cost burdens associated with the development of land, whether inside or outside the control of the Councils.
