Gladman Developments Ltd Matter 9 – 'Category 2' Settlement Allocations
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North Warwickshire Local Plan Examination Gladman Developments Ltd Matter 9 – ‘Category 2’ settlement allocations including H19 and H20 9.27 Allocation H20, land south of Coleshill Road (Hartshill) or land south of Ansley Common Gladman are promoting a significant part of site allocation H20, representations on the site were previously made by Sworders on behalf of Mr P Woolliscroft and Mr & Mrs K Ford. Gladman will be in contact with other landowners of the allocation to ensure a coordinated development is brought forward. These representations were given the examination number SLP331. The answers set out below therefore expand upon the points raised by Sworders through their examination representation, and where appropriate, expand these points to cover the issues raised by the Inspector. Qu (a) Local Plan paragraph 14.70 sets out that ‘access to site will need to be investigated and solutions implemented comprehensively’. Would that impede delivery? 1 Gladman and Sworders have both given consideration as to how a safe form of access into the site for both pedestrian and vehicles can be achieved. Initial considerations show that on the land as currently included within the allocation there are a number of options by which access could be achieved. A ‘worst case’ scenario would see the need for third party land to be optioned to allow access to be taken onto Ansley Common or the consideration of a land swap with the allotments currently in place being replaced elsewhere within the allocation to extend access through St Johns Road. However there remain other options for access which would not require third party land. Gladman would note that a requirement to secure third party land for access or other highway improvements is not unusual in the process of bringing forward sites, and therefore even if this ‘worst case’ scenario became a requirement Gladman do not believe that acquiring such land would impede the delivery of the site within the plan period. 2 As considered within the representations submitted by Sworders at the submission stage there remains existing land within the same ownership which, should allocation H20 be extended north, would allow for a direct access onto the B4114. For clarity the ownership and masterplan are included as Appendix 1 and Appendix 2 to this statement and were previously submitted as part of the submission stage consultation. This approach would clearly require the extension of the red edge boundary of allocation H20. 1 North Warwickshire Local Plan Examination 3 Whilst therefore there are a number of access options under consideration, as would be expected at this stage of the consideration of the site, there are no apparent ‘show stoppers’ in achieving a site access, indeed as expressed above there are a range of access options which can be pursued. There are therefore no access problems which would impede delivery of the site within the plan period. Gladman consider the issue of the site access being implemented comprehensively in regard to our answer to (b) below. 4 Gladman do have concerns however that criteria 1 of policy H20 is overly onerous. Whilst the policy text is noted there does not appear to be any firm evidence for the requirement for the link road connecting Plough Hill Road and Coleshill Road, indeed the provision of the road to meet the criteria would not only require the provision of land currently outside of the allocation but also potentially of land within the adjacent Nuneaton and Bedworth Borough Council area. 5 The masterplan shown in Appendix 2 shows how the first part of a potential link road could be brought forward through the extension of site H20, with the corresponding increase in development to circa 500-600 units. However, because of the issue of land in the adjoining district, it can only be reasonably expected that site H20 can safeguard a potential additional route through the site through the provision of a road to the boundary edge of the allocation (if expanded). It should be noted that the Nuneaton and Bedworth Local Plan has recently completed additional post main modification hearings, and whilst the adoption date for the plan currently remains unknown the plan is well advanced and does not contain a corresponding allocation for the delivery of a road within the administrative boundaries of Nuneaton and Bedworth. 6 For those reasons and to ensure that H20 is effective we consider that criteria 1 should be amended to read ‘the aspiration for a through road from Plough Hill Road to Coleshill Road.’ Qu (b) Should the reference to development taking place ‘comprehensively’ along with reserve site RH2 be amended given the different timings for delivery of the two allocations? 7 Yes. Gladman consider that in order to ensure that the delivery of site H20 is not needlessly delayed it will be necessary for the wording to be amended. The main concern appears to be that access into H20 does not prejudice the access of site RH2. However, it is important to note that at the present time RH2 is only a reserve site where as H20 is allocated and required to meet the Councils housing requirement. Nevertheless, Gladman understand that the Council do not wish the development of H20 to in anyway prejudice the development of RH2, as such the need to consider the development of that site through a concept plan is noted. Given that the sites are not physically connected we presume that the chief concern of the Council in this regard can only relate to the access of both sites. 2 North Warwickshire Local Plan Examination 8 The wording suggested by Sworders in their submission stage representation is intended to change the focus of the policy to make clear that consideration through the design and masterplanning phase will be given to RH2 to attempt to incorporate it, but that delivery of H20 cannot and should not be connected to RH2. 9 The policy may require further clarification in this context. For reference the Sworders proposed amended text was: ‘Development will take place comprehensively and be in accordance with an agreed Concept and Master Plan that has been designed to incorporate site RH2’ Gladman would suggest a further amendment for clarity and effectiveness to read: ‘Development will be in accordance with an agreed Concept and Master Plan that has been designed to incorporate site RH2’ Qu (c) Should H20, as with H19, refer to the Hartshill neighbourhood plan particularly in respect of demographics? Should the requirements of H20 and H19 be consistent) 10 Gladman believe that policy LP7 – Housing Development of the plan gives sufficient guidance on the housing mix which ought to be provided within allocations within the Local Plan. It already repeats the aspiration in paragraph 14.68 of the plan, with regard H19, which discusses the Hartshill Parish Plan (HPP) and Neighbourhood Plan (HNP) and identified need for housing for older people. 11 The requirement for the need to consider housing for older people is noted and Gladman consider that policy LP7 is robust in this regard, we consider however that any reference to the HPP or HNP in this regard should not be made. The HPP is dated April 2005 and as such the document is not considered to be up to date. The HNP was adopted in March 2017 and as such is of more relevance, however it must be noted that the HNP has come forward prior to the North Warwickshire Local Plan and must therefore be consistent with the strategic policies contained within that plan1. The HNP in Policy H6 sets out the aspirations of the plan for Housing Mix, this policy goes further than the Local Plan in specifically requesting bungalow provision. The explanatory text in 6.9 then goes further with reference to 1-bedroom bungalows being provided. The justification given for this approach is that the population of North Warwickshire and Hartshill is ageing, the HNP correctly identifies this as a national issue. 1 Paragraph 184 – NPPF (2012) 3 North Warwickshire Local Plan Examination 12 Gladman therefore see the need for LP7 of the Local Plan and its reference to older peoples accommodation but we do not consider that reference to the HNP is appropriate as the evidence within it is limited and would have a detrimental impact on site delivery and viability through the promotion of an overly specific housing type without sufficient evidence to back up demand for such properties. Qu (d) notwithstanding discussion on matters 7 and 10, are infrastructure (transport, health, education) requirements sufficiently evidenced and precise? 13 Gladman consider that for the purposes of an allocation in the Local Plan, given the scale and nature of the site, sufficient information is present with regard to transport, health and education to understand that the site will be deliverable within the plan period subject to discussions on levels of contributions for health, education and any offsite highways works required. The detail of those discussions can come at the appropriate time through the planning application stage where consultations with the appropriate bodies can be undertaken and detailed discussions held. 14 Gladman understand that there have been no critical objections from transport, education or health providers that would cast doubt on the ability of the site to come forward. Qu (e) Are the effects of the allocation appropriate in respect of heritage, drainage, and in relation to Brett’s Wood (ancient woodland)? 15 As with regard to our response to (d) we consider that any issues surrounding these issues, should they arise, are minor and as such can be considered through a future planning application process. 16 There are no designated heritage assets on the site, and none within close proximity to the boundary of the site.