Issue and Options 2023

Site Context To support the promotion of Bellway’s Sites, a Vision Document (May 2021) has been submitted with these representations. As stated in our response to the SWLP consultation below, we consider that Long Itchington should be identified for growth given its location on a key transport route, the range of shops, services and facilities provided and that it is one of the few sustainable settlements that is not located within the Green Belt, AONB or Special Landscape Area. These designations are a key determining consideration when spatially planning for growth, where paragraph 141 of the National Planning Policy Framework (‘NPPF’) makes clear that all other reasonable options outside of the Green Belt have been examined before exceptional circumstances apply. Paragraph 177 of the NPPF sets out a similar sequential approach to protecting the AONB. When allocating sites within Long Itchington, a flexible approach can be taken to the delivery of Bellway’s sites determined by the approach taken in the plan and the number of dwellings directed to the sustainable settlement. The options for delivery of the site and the scale of opportunity are set out in the submitted Vision Document and summarised below: • Option 1 - Northern site only (SHLAA Long.9)- Circa 45 – 55 dwellings (30 – 35dph). • Option 2 – Northern and Southern sites (SHLAA Long.9 and Long.18) – Circa 80 – 100 dwellings (30 – 35dph). • Option 3 – Northern and Southern sites as well as land to the south of the canal (SHLAA Long.9, Long.18 and Long.21)– 100+ dwellings as well as potential community uses and / or school if required. The key benefits of allocating Bellway’s sites for residential development within Long Itchington are considered to be as follows: - The land is immediately adjacent to the settlement boundary and is surrounded by existing development along the southern and western boundaries. Therefore it is considered to make a logical extension to Long Itchington. - The land is directly adjacent to Southam Road which connects the site via public transport to Leamington Spa, Rugby and Daventry. - Enhanced pedestrian connections between the site and village centre could be provided. - Affordable housing in accordance with policy requirements could be provided. - Public open space, tree planting and landscaping will be provided within the site and along the retain Public Right of Way and canal. - Enhancements to the canal towpath could be delivered. - Attenuation and SUDS features could be provided for surface water management and biodiversity enhancements. - Biodiversity Net Gain could be delivered across the sites. - Additional development around the village could help support local businesses through increased patronage. Bellway will work with Stratford-on-Avon District Council (‘SADC’), Long Itchington Parish Council and the local community through the local plan process to develop a scheme which assists in meeting the needs of the local community, District and wider Housing Market Areas.

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The consultation version of the SWLP does not state when the plan period will commence, it just states that the plan will cover the period up to 2050. The Urban Capacity Study states that the plan period is between 2025-2050 (paragraph 1.1). Consideration should be given to the length of the plan period if the Councils choose to allocate any new settlements or large urban extensions. Paragraph 22 of the National Planning Policy Framework (‘NPPF’) states that “where larger-scale development such as new settlements form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery” (Savills emphasis). In light of this, the Council’s may wish to extend the plan period beyond 2050.

Long Itchington has been assessed within the Sustainability Appraisal (‘SA’) as one of twenty two ‘Small Settlement Locations’ (‘SSLs’) which have been identified using 20 minute neighbourhood principles and scaled accordingly. All SSLs have been identified to be capable of delivering between 50 and 500 new dwellings and significant areas of greenspace to facilitate effective green infrastructure planning. Bellway supports the inclusion of Long Itchington in this assessment and consideration of development being directed to this sustainable location. Bellway also agrees with the SA that the settlement is capable of accommodating over 50 dwellings within the SWLP period. Long Itchington is one of the few sustainable settlements across South Warwickshire which is not constrained by Green Belt, an Area of Outstanding Natural Beauty or Special Landscape Area (‘SLA’). Bellway consider that this should be a key consideration when assessing where housing growth should be directed to. Appendix C of the SA includes a detailed summary of the Long Itchington assessment. Bellway consider that the assessment needs to be undertaken on a site by site basis around settlements as flood risk, Agricultural Land Classification, landscape and biodiversity implications identified in Appendix C may not be applicable to all sites around a settlement. For example, land to the north of Long Itchington was previously assessed as having a higher sensitivity to development as it was within the former Leam Valley SLA designated in the District Local Plan Review (2006). The key reason why this land was not retained as an SLA in the adopted Core Strategy was because the neighbouring districts did not designate any SLAs which made the Leam Valley SLA limited in size, it is considered by Bellway’s Landscape Consultation (IDP Landscape) that the technical considerations that supported the designation of the Leam Valley SLA have not changed. Therefore Bellway considers that the landscape to the south of Long Itchington is no more sensitive to development and should be considered appropriate when allocating sites for development in the SWLP. The SA’s assessment of Long Itchington’s accessibility to health, secondary education and railway stations could be mitigated through improvements to public transport and pedestrian connectivity. Therefore, these should not be used to justify no or limited growth being directed to this sustainable settlement. Consideration should be given by the Council to any Vision Documents and technical work submitted by developers / promoters that confirms how key site constraints could be appropriately mitigated. It is important to note that Figure C.14.1 within Appendix C does not include all of Bellway’s land that has been submitted through the SWLP process for development. The southern part of Bellway’s land interests (SHLAA reference Long.21) is excluded. It is unclear if the boundary within Figure C.14.1 is the only land being considered for potential development but consideration should be given to the southern part of SHLAA reference Long.21 and whether it could be included as part of a future allocation and utilised for community benefits as part of a wider residential scheme.

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Q-I2: Please select the option which is most appropriate for South Warwickshire: Bellway supports option I2a. Paragraph 16 of the NPPF requires plans to be shaped by “early, proportionate and effective engagement between plan-makers and…infrastructure providers”. Paragraph 20 goes on to require strategic policies to make sufficient provision for infrastructure. The NPPF (paragraph 34) also requires plans to set out what contributions are expected from development towards infrastructure. Therefore understanding infrastructure requirements, and how they are considered alongside the housing requirements of South Warwickshire across the plan period, are key for the SWLP to address. It is important for infrastructure providers to be engaged at an early stage of the SWLP process so that it is clear that proposed allocations are deliverable within the plan period and contributions requested will not impact on the viability of a scheme. Q-I3: Please select the option which is most appropriate for South Warwickshire At this stage, Bellway has no preference on whether the Councils pursue Option I3a (establish a South Warwickshire CIL) or Option I3b (produce separate CILs). However, currently Warwick and Stratford-on-Avon District Councils have separate charging schedules in place. Should a joint levy be pursued, market considerations of both areas should be considered and it is likely that levy charges will need to vary depending on the location of the development. No matter which option is pursued, it is important to consider the viability of individual sites when determining the CIL levels to charge and whether there is scope for exclusions to apply to larger strategic sites (Planning Practice Guidance (‘PPG’) Reference ID: 25-021-20190901). Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability At Examination, there is a requirement for plans to meet the NPPF’s test of soundness (paragraph 35) and be legally compliant. Any requests for contributions should be made in compliance with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010, and confirmed at paragraph 57 of the NPPF. There is a greater emphasis in national policy on testing viability at the plan making stage. A Viability Assessment will be required to demonstrate that the proposed policies and strategic sites within the SWLP are viable (PPG Reference ID: 10-002-20190509 and 10-005-20180724). Plan makers are required to engage with developers and infrastructure providers in order to confirm costs and values included within the viability assessments (PPG Reference ID: 10-006-20190509). It is imperative for the viability assessment to be kept up to date and to be informed by reasonable assumptions on all costs expected. Key statutory consultees must be involved in order to inform the assumptions made on costs (e.g. education, NHS, highways).

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Q-S1: Please select the option which is most appropriate for South Warwickshire (Green and Blue Corridors) Bellway support Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. It is considered that the Councils should identify the green and blue infrastructure assets they seek to protect and enhance in the first instance and then identify their preferred development options. This will ensure that the growth strategy is not unduly constrained at a later date. Q-S2: Please select all options which are appropriate for South Warwickshire (Intensification) Bellway supports Option S2c: Do not have a policy which encourages intensification. Given the scale of the District and the range of urban and rural areas as well as the SWLP being a part 1 strategic plan, we consider that the SWLP should not apply a blanket approach to densities and intensification at this stage. Chapter 11 of the NPPF encourages effective use of land but there are a number of criteria that must be taken into account when considering densities including the need for a certain type of housing, local market conditions, viability and prevailing character of an area (paragraph 124). Policy wording within the SWLP could ‘encourage’ intensification on sites in certain locations but the final density of a site should be agreed on a site by site basis. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Bellway supports Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Paragraph 119 of the NPPF is clear that planning policies should make as much use as possible of previously developed land. Furthermore, paragraph 120 states that planning policies should give substantial weight to the value of using suitable brownfield land. However, although significant weight is placed on the development of brownfield land, the NPPF (paragraph 11) is also clear that “plans should promote a sustainable pattern of development”. Therefore it is important that only brownfield sites in sustainable locations are prioritised. Brownfield land in an unsustainable location (not adjacent to an existing settlement) should not be allocated above a greenfield site which is adjacent to an existing sustainable settlement such as Long Itchington. Notwithstanding the above, the Urban Capacity Study (October 2022) is clear that there will not be enough urban sites to meet South Warwickshire’s housing needs across the plan period. Greenfield sites will be required and the prioritisation of greenfield or brownfield sites should only be based on realistic assumptions on when they are likely to be delivered. For example, a greenfield site with a housebuilder promoting it is likely to be able to be delivered before a brownfield site with an existing use still occupying the site / buildings. Q-S5.2: Do you think new settlements should be part of the overall strategy? No - Bellway consider that future growth should be directed to existing settlements as they are already well established and offer immediate opportunities to deliver development. Should a new settlement be pursued then significant evidence should be prepared to assess the level of infrastructure required to deliver it and realistic assumptions on its delivery should be made. The SWLP proposed plan period may also require extending as the NPPF (paragraph 22) encourages plans to have at least a 30 year plan period where new settlements are proposed. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. and Q-S5.4: If not, what approach would you take? As set out in our response to Q-S5.2, Bellway consider that existing settlements should be the focus of growth. Should any new stations or significant development around new stations be proposed then sufficient evidence should be prepared around costs and delivery of housing. Issue S6 (A review of Green Belt boundaries) – no specific question included in the SWLP. There is no specific question relating to Issue S6 in the SWLP which we assume is an error given every other issue has a question attached to it. There is significant national policy protecting the loss of Green Belt land (NPPF Chapter 13) and exceptional circumstances are required to justify amendments to Green Belt boundaries within a plan (NPPF paragraph 140). In light of this, Bellway considers that non-Green Belt locations should be identified for growth in the first instance. There are suitable, available and deliverable sites adjacent to existing sustainable settlements outside of the Green Belt, such as Long Itchington, that should be considered for growth before any significant Green Belt release. Q-S9: Please select the option which is most appropriate for South Warwickshire (Settlement Boundaries and Infill Development) Bellway supports Option S9b - review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries Bellway considers that settlement boundaries should be reviewed if there are any allocations proposed adjacent to them.

The Urban Capacity Study (October 2022) confirms that it has been undertaken as a theoretical exercise only. It is important to note that the study has not been informed by a Housing and Economic Land Availability Assessment (‘HELAA’). Therefore, the urban sites assessed in the study and have not yet been assessed by the Council so the urban capacity could actually be significantly lower than the 19,950 dwellings (excluding the additional 3,400 from potential car park redevelopment) quoted. It is important for the HELAA to be finalised and published as soon as possible so that we can better understand what the urban capacity is and what additional housing may be required elsewhere. Viability of delivering and relying on brownfield sites and the potential impact on affordable housing delivery will have to be a key consideration. In addition to reviewing the additional urban sites identified in the Study, it is also considered that the Councils should undertake a review of all of the adopted allocations which are not yet the subject of applications or delivered any dwellings (7,655 dwellings in total) and should provide evidence to justify why those sites are still considered to be deliverable within the SWLP plan period. Currently the 7,655 dwellings from existing allocations without planning permission form part of the total 19,950 dwellings identified in the Study. Table 2 within the Study shows the net developable area ratios which have been used (less than 1ha = 100%, up to 4.99ha = 90%, up to 9.99ha = 80% & 10+ha = 65%). There is no justification on how these ratios have been calculated. Bellway consider that the ratios are not realistic. There is no national planning guidance which sets out which ratios should be utilised. However, having reviewed other examples across England, Telford and Wrekin Council used 100% gross to net ratio less than 0.4ha, 75-90% up to 2ha and 50-75% over 2ha. It is considered that the range utilised by Telford and Wrekin Council offers more flexibility than the figures quoted within Table 2. Regardless of whether all of the sites are deliverable or not, the Study has identified that there will be a significant number of dwellings which will need to be identified on additional sites outside of the urban area. We await further confirmation of the proposed housing requirement figure and findings of the HELAA before commenting further on what we consider the shortfall of dwellings is.

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