Proposed Modifications January 2016

See attached

see attached

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

see attached