Publication Draft

Object

Representation ID: 65719

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the Council's allocation strategy may have been to firstly review previously
developed land sites, this cannot be enforced as a delivery policy. A 'brownfield
first' approach is not consistent with the Framework, which does not advocate this
priority or inflexibility.

The Spatial Strategy should not be used negatively to prevent sustainable development. Policy DS4 has identified the broad locations which are to deliver growth over the Plan period, and allocated specific sites accordingly, therefore the Council should not promote a hierarchical approach to the delivery of their allocations.

Object

Representation ID: 66698

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The policy confirms that the Council is planning to provide for 12,860 new homes between 2011 and 2029. Barwood raise strong objection to this policy. In the first instance Barwood object to the Council setting a definitive target for housing growth.

Warwick may have to provide housing growth for the wider HMA and until the LPAs have fully assessed whether they are capable of delivering the required growth, Warwick cannot definitively state that they are planning for their full objectively assessed housing needs. Barwood believe that the Publication Local Plan is unsound as it plans for an artificially supressed level of housing growth in conflict with the objectively assessed housing needs of the Housing Market Area.

Support

Representation ID: 66699

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Barwood supports the allocation of Tachbrook Country Park (Policy DS13) to ensure Leamington and Bishop's Tachbrook remain separated.

Support

Representation ID: 66700

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Barwood support this policy which sets out the Council's strategic approach to housing, aiming to ensure the District has the right amount, quality and mix of housing to meet future needs.

Object

Representation ID: 66701

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? No

Sound? Not specified

Duty to co-operate? No

National guidance sets out a prescriptive set of requirements in relation to the Duty to Cooperate and it is confirmed that robust evidence is required to demonstrate how this has been complied with.

The Sub-Regional Approach to Delivering the Housing Requirement report identifies that further work is required to ensure the HMA has a robust subregional
evidence base to support collaborative work on a sub-regional spatial strategy.

The Council's approach to the Local Plan's housing spatial strategy is premature given the significant uncertainties which the joint HMA evidence base could deliver.

This approach lacks certainty and is dependent on a number of significant pieces of technical evidence that are not yet complete.There can be no assurance that the Council's assumptions will translate to the HMA's unmet housing requirements being provided for.

Barwood conclude that the legal compliance of the Plan has not been satisfied on the basis that the Duty to Cooperate is not a matter which can be rectified at the Examination stage.

Object

Representation ID: 66702

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Local Planning Authorities with Green Belts in their area should only alter the Green Belt boundary in exceptional circumstances, through the preparation or review of the Local Plan.Green Belt boundaries should have permanence in the long term and be capable of enduring beyond the Plan period.The Council has not undertaken a strategic review of the Green Belt and therefore does not have the evidence base to selectively remove sites, such as Red House Farm, from the Green Belt.

The Council has identified that it is their intention to undertake a revised evidence base for the wider Housing Market Area which, importantly, includes a review of the Green Belt. This evidence base must inform this Local Plan as changes to Warwick's Green Belt cannot be implemented through a partial review.

Support

Representation ID: 66703

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

The policy approach of Policy DS15 is supported by Barwood. It is important that the masterplans for the strategic urban extensions are approved by the Council to
ensure site deliverability. However, Barwood consider that the policy lacks
clarification on the process by which the Development Brief or Masterplan will be
approved.

Object

Representation ID: 66705

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The assumption that all the urban brownfield sites, along with the small SHLAA sites, will yield 1,330 units with no allowance for non-implementation or slippage is
questionable.

To reflect the uncertainties connected to the deliverability of a number of the urban brownfield sites, Barwood recommends that a 10% reduction is applied to the number of dwellings which could be delivered on urban brownfield sites.

Further to the removal of both The Asps and Land South of Gallows Hill from the Local Plan, the Council has produced two draft evidence base documents entitled 'The Setting of Heritage Assets', one of which relates to The Asps and one related to Land South of Gallows Hill. Both documents are stated to be in draft and, to our knowledge, have not been subject to consultation or scrutiny.

Barwood's consultant team have previously, in our response to the Revised Development Strategy, provided a detailed and thorough response to the RMA work and English Heritage's commentary. The soundly based technical Heritage Setting Assessment prepared by EDP and submitted in support of The Asps planning application demonstrates the suitability of The Asps to accommodate a significant amount of development with (following mitigation) no harmful impacts on the landscape which is adjacent to it, or indeed to the historic setting of the town, the Castle Park and other relevant heritage assets.

Object

Representation ID: 66706

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Asps application proposals allocate in the region of 2 hectares of land for a
strategic Park and Ride with the capacity to accommodate up to 750 car parking
spaces, ideally located for traffic heading to Warwick and Leamington Spa. The
Asps presents the only deliverable option for a Park and Ride site, due to the comprehensively designed development which has fully considered how the Park
and Ride site will work in practice and a willing landowner.

The delivery of a Park and Ride facility on this site, as part of the development of
a comprehensive sustainable urban extension, is the only way in which the
Council's long-standing ambition to see such a facility provided in the District can
be delivered.

Object

Representation ID: 66707

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

This policy directs new housing growth in accordance with the Publication Local
Plan's Development Strategy. As identified through the Development Strategy
policies, the Publication Local Plan directs new housing growth to sustainable
locations including urban areas, growth villages and greenfield sites on the edge
of Warwick, Leamington and Whitnash.

Barwood considers that the allocation of The Asps site would be compliant with
Policy H1, as the site presents the opportunity to deliver a Sustainable Urban
Extension. This suitability of The Asps is further explored within Chapter 5 of
these representations.