Revised Development Strategy

Object

Representation ID: 55408

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

Gallagher Estates Ltd own and control a significant part of the land defined collectively as "southern sites
(area south of Warwick and Whitnash)" proposed as strategic urban extension sites in the RDS (as shown on Plan submitted in Appendix 1 )

Outline Planning Permission was granted on 23rd July 2013 (with conditions) for the development of the West Warwick Gates site (ref W13/0607) for " [inter alia] Up to a maximum of 220 dwellings.

In addition English Care Villages (ECV) has recently secured planning consent for a care retirement community on land owned by Gallagher Estates at Earls Rivers Avenue adjacent to Gallagher House, Gallagher Way.

The principle of development of these sites is now established and should now be recorded as commitments in the emerging Local Plan.

Support

Representation ID: 60228

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The NPPF reflects the emphasis which the Government is placing on ensuring that the development the country needs is delivered and contains an additional test of soundness for Local Plans which reflects this, stating that a plan should be:

"Positively prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is practical to do so consistently with the presumption in favour of sustainable development."

There is [therefore] an increased responsibility on the authority to ensure that the requirement for development is properly evidenced in a transparent and robust manner when making decisions about their strategy.

Very much support and endorse the approach of the District, as set out in paragraph 1.3 of the RDS, to ensure that there is a robust and up to date evidence base and, welcome the acknowledgement that there will be a need to take account of the as yet unavailable findings of the Joint Strategic Housing Market Assessment (JSHMA)

The paragraph 1.3 acknowledgements contained within the RDS are an encouraging response to the concerns previously made to the Preferred Options of May 2012. At that stage there appeared to be no means by which the Duty to Co-Operate could be satisfied which would undoubtedly have been an inadequate basis on which to allow the Plan to move forward.

Welcome the fact that Warwick District is now recognising its statutory obligations with regard to the Duty to Co-Operate with neighbouring authorities in the preparation of the Warwick Local plan in order to maximise its effectiveness with regard, in particular, to the strategic planning matter of housing provision.

The findings of the Inspector considering the Coventry Local Development Plan- Core Strategy (withdrawn in April 2013)were no doubt instructive in this regard. In short, he concluded that the Council had failed to meet the legal requirements of the Duty to Co-Operate.

Whilst the progress in seeking to meet the Duty to Co-Operate is encouraging it is also important to note that the District does have additional neighbouring authorities particularly Stratford upon Avon District and Solihull MBC.

This is pertinent as both Solihull and Stratford are, at present, progressing Local Plans that incorporate a level of new housing development which is significantly lower than their arising needs which could have implications for Warwick District.

Would stress that in addition to the Joint SHMA work currently underway, the Authority must also be in a position, on submission of the Plan, to be capable of demonstrating that they have met the Duty to Co-operate with both Stratford and Solihull.

Support

Representation ID: 60229

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

Support the references to facilitating and providing for growth both in respect of the local economy and housing needs.

However, note the reference under the heading of "social" to the delivery of 550 new homes per annum on new allocated sites.

This annual requirement does not appear to correlate with the information provided in Section 4 of the RDS and therefore clarification is required.

Suggest deletion of a precise figure as part of the vision in future iterations of the Local plan which will remove any concerns about a prejudicial approach to the process.

Support the principle under the heading "Environment", to avoid coalescence between settlements.

Consider that this has been reflected effectively in the RDS in terms of the newly proposed spatial distribution of development. This, more effectively, avoids coalescence of settlements having regard to Paragraph 80 of the NPPF by no longer proposing development to the north / north west of Leamington Spa on land located within the Green Belt.

Object

Representation ID: 60230

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The recognition that the quantum of development set out in RDS1 is interim (emphasis supplied) only is welcomed.

This is on the basis that the Authority, in proposing 12,300 dwellings, is at risk of under providing for arising need and failing to boost significantly the supply of housing contrary to the provisions of the NPPF.

The Authority must take on board any implications arising out of the Joint SHMA work.

Additional concerns about the interim figure are:

They are based on the 2011 interim sub national population projections. They assume a continuation of the 2010 based projections in fertility, mortality and migration. The 2011 projections indicate that in the period 2011 to 2021 there will be an increase of 625 households per year.

The most recent household projections that go beyond 2021 are the CLG based 2008 based household projections. These projections suggested the need for the provision of 15,500 households over the period 2011 to 2029. This is equivalent to 861 dwellings per annum.

The main reason for the difference between the 2008 and 2011 based projections is that the 2011 based projections show a slower growth in households compared to the 2008 projections. It is not, though, likely that this reduced household formation rate will continue into the future as economic conditions improve, thus beyond 2021 it would be reasonable to assume that household formation rates will increase and there will be an increased growth again beyond 2021.

This is especially the case in a district such as Warwick where the housing market will be more robust than elsewhere in the West Midlands.

The likelihood is therefore that the figure of 625 dwellings per annum, which is predicated on the existing conditions assumed in the 2011 projections continuing, will increase as households begin to form more readily following an improvement in their economic circumstances.

It is also important to recognise that household projections do not equal dwellings required. In order to arrive at a figure for dwellings required there is a need to add an allowance to deal with unmet need or backlog (concealed households and reduction in sharing households), take account of second homes and also add a figure for vacancies.

This accords with the requirement in the NPPF to address the need for all types of housing and also to cater for housing demand.

[In this context], the Warwick District Housing Market Assessment (HMA) of March 2012 is instructive and demonstrates that, as of 2012 there was an unmet net affordable housing need of 1,144 households.

These need to be added to the projection as does a suitable allowance for second homes and vacancies.

When this process is undertaken it is likely to direct the Authority to a figure in excess of the 11,500 new homes proposed at paragraph 4.1.5.

The Authority has also produced other evidence, including the Economic and Demographic Forecasts Study (December 2012) which has identified a need for additional homes ranging from 13,300 and 13,800 between 2011 and 2029.

Policy RDS2 sets out how the proposed interim housing requirement is proposed to be met., and includes a large windfall allowance of 2,800 dwellings.

Remain unconvinced that such a windfall allowance is justified in terms of paragraph 49 of the NPPF and have concerns that the Authority will be unable to demonstrate a supply of 12,300 dwellings if this approach to windfall development is to persist.

Support

Representation ID: 60231

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The distribution strategy put forward by the Authority in RDS3 seeks to focus development within, and on the edges of, the existing urban area. In so doing it seeks to protect the Green Belt where there are non Green Belt options available and seeks to avoid development in areas which would lead to the unacceptable coalescence of settlements.

The approach goes on to suggest a proportionate amount of growth in the rural areas, based on a hierarchical approach to the suitability of rural settlements.

This strategy is consistent with the NPPF in terms of sustainable development paras 151 and 152 refers.

The distribution strategy put forward by the District Council can deliver a considerable number of positive impacts in environmental, social and economic terms. The spatial strategy is therefore supported.

The distribution approach will perform mindful of paragraph 7 of the NPPF, an economic role by providing land of the right type in the right place proposing development that can assist in delivering infrastructure particularly in the proposed strategic urban extension sites to the south of Warwick and encouraging higher skilled economic sectors directing employment growth in the vicinity of the Warwick Technology Park.

The strategy also performs a social role by providing housing in locations that are accessible to services and can support strong, vibrant and healthy communities.

Lastly the strategy provides an environmental role. This includes: maintaining and enhancing landscape and townscape quality and promoting biodiversity by enhancing connectivity and diversity of habitats and wildlife corridors and positively encouraging energy efficiency.

In particular the distribution strategy proposed at RDS3 provides a clear prioritisation that land outside of the Green Belt on the edge of existing urban areas is to be used in preference to locations within the Green Belt which closes the gap between existing settlements and could potentially lead to their coalescence.

This addresses a concern previously raised at Preferred Options stage. The NPPF, at paragraph 85, is clear that Green Belt boundaries should only be altered in exceptional circumstances. It is the case that the updated evidence base provided by the Council (summarised at 4.3.4 to 4.3.12) demonstrates that the previous perception that additional development should be accommodated in the Green Belt to the north west of Leamington as an exceptional circumstance cannot be substantiated.

In reality the evidence base supports the release of further land to the south of Warwick, outside of the Green Belt, as a sustainable approach.

Support

Representation ID: 60232

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

This is a site with recent planning permission for up to 220 dwellings, open space and play space consistent with the RDS and should be shown as a commitment opposed to a Local Plan site proposal.

The site:

* In accordance with paragraph 5.1.32 of the RDS contribute significantly to the 5 year supply of housing land;

* can deliver an appropriate and justified development in a manner consistent with national policy. The site is deliverable / developable in the terms identified at footnotes 11 and 12 of paragraph 47 of the NPPF; and

* is available now, offers a suitable location for development

Gallagher Estates are committed to the delivery of the site. All constraints have been properly taken into account through the application process and a sustainable development in economic, environmental and social terms incorporating up to 220 dwellings and attendant open space and green infrastructure can be provided in a manner consistent with the emerging RDS.

It is also of note that the Council has granted planning permission on land adjacent to the West Warwick Gates site for a care village. It has therefore been established that this parcel of land, located at Earls Rivers Avenue adjacent to Gallagher House off Gallagher Way is suitable, deliverable and developable consistent with the provisions of the NPPF.
Additional Proposed Housing Site:

In addition Gallagher Estates own and control a small parcel of land located between the existing property known as Longacre and Gallagher Way.

Given that the land at West Warwick Gates and the Earls Rivers Avenue is committed residential development it would be appropriate for this small isolated pocket of unused land to be allocated for residential development in the next iteration of the Local Plan.

Support

Representation ID: 60233

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The inclusion of the land at Lower Heathcote Farm within the RDS is appropriate, justified, effective, deliverable, consistent with national policy and soundly based:
* The site is proposed to accommodate 720 dwelling and a range of additional other uses including a local centre and community facilities, primary school, potentially land for a secondary school, extensive green infrastructure including a country park;
* It can be delivered in the manner envisaged by the RDS. The site is deliverable / developable in the terms identified at footnotes 11 and 12 of paragraph 47 of the NPPF;
* Gallagher Estates are committed to its delivery;
* All constraints of the site can be properly taken into account and a development incorporating up to 720 dwellings and a range of other uses can be provided;
* The site is available now, offers a suitable location for development now and there is every prospect that a number of houses can be delivered on the site within five years.
* There is the potential to bring forward the site in the short term and the land will then contribute to the 5 year supply of housing land.
* The delivery of this site will direct growth in a sustainable manner in the spirit of the NPPF and its clear presumption in favour of sustainable development.

Support

Representation ID: 60234

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The inclusion of the land defined as South of Gallows Hill within the RDS is appropriate, justified, effective, deliverable, consistent with national policy and soundly based:

* This site is proposed to accommodate between 430 and 630 dwellings and a range of additional other uses including opens space and a potential option for in the order of 7 to 8 hectares of employment land;
* Gallagher Estates control the eastern part of this proposed site as shown on the location plan (submitted Appendix 1);
* The land to the west is controlled by Hallam Land Management and William Davis who Gallagher Estates understands are to submit an outline planning application for the development of 250 dwellings:

* A planning application is also to be submitted for the land controlled by Gallagher Estates:

* Both sites can be delivered in a manner envisaged by the RDS incorporating housing and extensive open space:

* The Gallagher land can be brought forward for development in a manner that does not prejudice the remaining land within the proposed allocation being developed:

* The land, as identified at Appendix 1, is deliverable / developable in the terms identified at footnotes 11 and 12 of paragraph 47 of the NPPF:

* Gallagher Estates are committed to the delivery of the site:

* All constraints of the site can be properly taken into account:

* The site is available now, is in a suitable location for development and there is every prospect that a number of houses can be delivered on the site and the land to the west within five and so contribute significantly to the 5 year supply of housing land.

Support

Representation ID: 60235

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

In environmental terms these sites have a positive impact.

* They promote biodiversity and geo diversity and protect the historic environment.
* The built form of the sites can be defined by the landscape and topography setting and do not give rise to any loss of important views.
* Opportunities for positive enhancements through the approach of providing comprehensive green infrastructure including the provision of a country park to the south of Lower Heathcote Farm as envisaged at Paragraph 5.1.10 of the RDS.

* Large areas of the sites will be given over to high quality, useable open space incorporating green corridors.

* Offer opportunity for positive enhancements in terms of avoiding impact for food risk and prudently using natural resources.

* The location of the sites in providing improved levels of housing in locations easily accessible to employment opportunities provides a positive economic impact.

* A range of housing can be provided consistent with creating balanced and mixed communities.

* There is also the opportunity to encourage sustainable travel as the proposals offer the opportunity for improved public transport and the provision of pedestrian and cycling routes throughout the sites linking to the green infrastructure network and services and facilities beyond the site boundaries.

In social terms the sites:

* provide a positive impact on social factors. This includes improving the availability of sustainable transport and creating balanced and mixed communities. I
* will give rise to positive impacts arise in terms of promoting safe communities, improving health and improving community participation. Due to the range of services in the area including the primary school, provision for open space, sport and recreation as part of the extensive green infrastructure and the provision of a local centre as part of the Lower Heathcote Farm proposal which can act as a focus for community activity.

The Lower Heathcote and south of Gallows Hill sites are therefore sustainable in the terms set out in the NPPF.

The sustainability advantages of the sites are also recognised in the Final Interim SA Report produced by the Council alongside the RDS.

Support

Representation ID: 60236

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

In environmental terms these sites have a positive impact.

* They promote biodiversity and geo diversity and protect the historic environment.
* The built form of the sites can be defined by the landscape and topography setting and do not give rise to any loss of important views.
* Opportunities for positive enhancements through the approach of providing comprehensive green infrastructure including the provision of a country park to the south of Lower Heathcote Farm as envisaged at Paragraph 5.1.10 of the RDS.

* Large areas of the sites will be given over to high quality, useable open space incorporating green corridors.

* Offer opportunity for positive enhancements in terms of avoiding impact for food risk and prudently using natural resources.

* The location of the sites in providing improved levels of housing in locations easily accessible to employment opportunities provides a positive economic impact.

* A range of housing can be provided consistent with creating balanced and mixed communities.

* There is also the opportunity to encourage sustainable travel as the proposals offer the opportunity for improved public transport and the provision of pedestrian and cycling routes throughout the sites linking to the green infrastructure network and services and facilities beyond the site boundaries.

In social terms the sites:

* provide a positive impact on social factors. This includes improving the availability of sustainable transport and creating balanced and mixed communities. I
* will give rise to positive impacts arise in terms of promoting safe communities, improving health and improving community participation. Due to the range of services in the area including the primary school, provision for open space, sport and recreation as part of the extensive green infrastructure and the provision of a local centre as part of the Lower Heathcote Farm proposal which can act as a focus for community activity.

The Lower Heathcote and south of Gallows Hill sites are therefore sustainable in the terms set out in the NPPF.

The sustainability advantages of the sites are also recognised in the Final Interim SA Report produced by the Council alongside the RDS.