Preferred Options
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Preferred Options
2. Our Vision for the District
Representation ID: 46998
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
In response to the strategic objectives set out within the consultation document, we support the inclusion of paragraph 2.5 and the overarching commitment to deliver a range of new housing in sustainable locations across the District. We also wish to highlight that housing plays an important role in underpinning new economic development and also in supporting existing services and facilities. Overall, this strategic objective is considered to be consistent with paragraph 50 of the National Planning Policy Framework (NPPF) document which highlights a need to deliver a wide choice of high quality homes and widen opportunities for home ownership.
In response to the strategic objectives set out within the consultation document, we support the inclusion of paragraph 2.5 and the overarching commitment to deliver a range of new housing in sustainable locations across the District. We also wish to highlight that housing plays an important role in underpinning new economic development and also in supporting existing services and facilities. Overall, this strategic objective is considered to be consistent with paragraph 50 of the National Planning Policy Framework (NPPF) document which highlights a need to deliver a wide choice of high quality homes and widen opportunities for home ownership.
Object
Preferred Options
PO1: Preferred Level of Growth
Representation ID: 47001
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
Paragraph 47 of the NPPF requires local authorities to effectively assess the full needs for housing in the Housing Market Area (HMA). The District Council appears to have prepared a Strategic Housing Market Assessment (SHMA) that considers the needs of the District only. This is a fundamental flaw in the Council's approach, which could raise issues about the soundness of the plan. This needs to be rectified prior to producing the Submission version.
On this basis, we therefore neither support nor object to the proposed level of growth proposed in PO1 since the evidence is lacking.
Paragraph 47 of the NPPF requires local authorities to effectively assess the full needs for housing in the Housing Market Area (HMA). The District Council appears to have prepared a Strategic Housing Market Assessment (SHMA) that considers the needs of the District only. This is a fundamental flaw in the Council's approach, which could raise issues about the soundness of the plan. This needs to be rectified prior to producing the Submission version.
On this basis, we therefore neither support nor object to the proposed level of growth proposed in PO1 since the evidence is lacking.
Support
Preferred Options
PO3: Broad Location of Growth
Representation ID: 47004
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
In terms of the location of future development, we support PO3 'Broad Location of Growth' and in particular the reference made to concentrating growth within, and on the edge of, the existing urban areas. Furthermore, paragraph 7.10 rightly identifies that there is limited availability of brownfield land in the District and acknowledges that greenfield land will be required to meet housing needs.
In terms of the location of future development, we support PO3 'Broad Location of Growth' and in particular the reference made to concentrating growth within, and on the edge of, the existing urban areas. Furthermore, paragraph 7.10 rightly identifies that there is limited availability of brownfield land in the District and acknowledges that greenfield land will be required to meet housing needs.
Object
Preferred Options
Relevant Issue & Strategic Objectives
Representation ID: 47006
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
On the assumption that the figure of 10,800 new homes is correct (and we are not saying that it is), allowing for commitments and windfall sites, we acknowledge that the balance to be allocated in the plan is 6,986 new homes. In the context of paragraph 183 of the NPPF, which outlines the role of Neighbourhood Plans, the overall target for the delivery of new homes should be expressed as minimum figure rather than an absolute target, therefore providing a greater degree of flexibility for the Council.
On the assumption that the figure of 10,800 new homes is correct (and we are not saying that it is), allowing for commitments and windfall sites, we acknowledge that the balance to be allocated in the plan is 6,986 new homes. In the context of paragraph 183 of the NPPF, which outlines the role of Neighbourhood Plans, the overall target for the delivery of new homes should be expressed as minimum figure rather than an absolute target, therefore providing a greater degree of flexibility for the Council.
Support
Preferred Options
Whitnash East (South of Sydenham)
Representation ID: 47007
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
We welcome the inclusion of the Golf Lane/Fieldgate Lane site as an allocated housing site as set out by PO4. It will play a key role in achieving the plan's objectives, being significant in size but small enough to be delivered without the need for costly infrastructure works. It should, however, be noted that the site is 4 hectares in size, is unconstrained and is therefore more likely to have a development capacity in the region of 100-110 units (allowing for some on-site public open space and landscaping) rather than 90 units as set out in the associated table.
We welcome the inclusion of the Golf Lane/Fieldgate Lane site as an allocated housing site as set out by PO4. It will play a key role in achieving the plan's objectives, being significant in size but small enough to be delivered without the need for costly infrastructure works. It should, however, be noted that the site is 4 hectares in size, is unconstrained and is therefore more likely to have a development capacity in the region of 100-110 units (allowing for some on-site public open space and landscaping) rather than 90 units as set out in the associated table.
Support
Preferred Options
Fieldgate Lane/ Golf Lane, Whitnash
Representation ID: 47008
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
We welcome the inclusion of the Golf Lane/Fieldgate Lane site as an allocated housing site as set out by PO4. It will play a key role in achieving the plan's objectives, being significant in size but small enough to be delivered without the need for costly infrastructure works. It should, however, be noted that the site is 4 hectares in size, is unconstrained and is therefore more likely to have a development capacity in the region of 100-110 units (allowing for some on-site public open space and landscaping) rather than 90 units as set out in the associated table.
We welcome the inclusion of the Golf Lane/Fieldgate Lane site as an allocated housing site as set out by PO4. It will play a key role in achieving the plan's objectives, being significant in size but small enough to be delivered without the need for costly infrastructure works. It should, however, be noted that the site is 4 hectares in size, is unconstrained and is therefore more likely to have a development capacity in the region of 100-110 units (allowing for some on-site public open space and landscaping) rather than 90 units as set out in the associated table.
Support
Preferred Options
On the Edge of Warwick, Leamington Spa & Whitnash
Representation ID: 47009
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
In terms of the wider portfolio of sites identified for development in PO4, we note that over 60% of the housing required on the edge of Warwick, Leamington and Whitnash areas has been identified on just three sites. Whilst we have no specific objection to the inclusion of these sites, it does seem to us that there is an over-reliance on a small number of sites to meet the requisite number of homes over the plan period.
In terms of the wider portfolio of sites identified for development in PO4, we note that over 60% of the housing required on the edge of Warwick, Leamington and Whitnash areas has been identified on just three sites. Whilst we have no specific objection to the inclusion of these sites, it does seem to us that there is an over-reliance on a small number of sites to meet the requisite number of homes over the plan period.
Support
Preferred Options
Fieldgate Lane/ Golf Lane, Whitnash
Representation ID: 47010
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
The continued inclusion of smaller deliverable sites in sustainable locations such as the Golf Lane/Fieldgate Lane site is of strategic importance if housing needs are to be met within the plan period.
The continued inclusion of smaller deliverable sites in sustainable locations such as the Golf Lane/Fieldgate Lane site is of strategic importance if housing needs are to be met within the plan period.
Object
Preferred Options
C. Development on Brownfield Land
Representation ID: 47011
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
With regard to the structure of PO4, the relationship between points A (allocated sites) and C (development on Brownfield land) needs to be clarified, as it appears to suggest that the Council will be looking to introduce a policy that promotes the development of brownfield sites before the allocated sites. Paragraph 17 of the NPPF promotes the effective use of land by reusing land that has previously been developed, but does not go as far as suggesting that brownfield sites should be prioritised over the release of greenfield. Refer to representations attached.
With regard to the structure of PO4, the relationship between points A (allocated sites) and C (development on Brownfield land) needs to be clarified, as it appears to suggest that the Council will be looking to introduce a policy that promotes the development of brownfield sites before the allocated sites. Paragraph 17 of the NPPF promotes the effective use of land by reusing land that has previously been developed, but does not go as far as suggesting that brownfield sites should be prioritised over the release of greenfield. Refer to representations attached.
Support
Preferred Options
Fieldgate Lane/ Golf Lane, Whitnash
Representation ID: 47012
Received: 26/07/2012
Respondent: Richborough Estates Ltd
Agent: Turley Associates
In terms of previous site assessments, the 2011 Strategic Housing Land Availability Assessment (SHLAA) recognised the development potential of the site, subject to assessment/mitigation of transport safety concerns. Further assessments have been undertaken (refer to representations attached), which demonstrate that development of this site would not undermine highway safety.
In terms of previous site assessments, the 2011 Strategic Housing Land Availability Assessment (SHLAA) recognised the development potential of the site, subject to assessment/mitigation of transport safety concerns. Further assessments have been undertaken (refer to representations attached), which demonstrate that development of this site would not undermine highway safety.
