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.
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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.
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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)
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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. Any application would be accompanied by an appropriately detailed heritage statement covering issues relating to conservation and archaeology. Similarly any application on the site would be accompanied by a detailed hydrology investigation identifying the most appropriate drainage strategy. None of these issues are considered to be ‘show stopping’ constraints which would render allocation H20 undeliverable.
17 With regard to criteria (1) of H20 Gladman consider that the requirement of a 50m buffer around the ancient woodland of Brett’s Wood is not supported by guidance. Sworders submitted a letter from Lockhart Garratt with their submission stage representation which considered in detail the context and need for applying a buffer to the Brett’s Wood ancient woodland. Gladman consider that this remains a robust assessment of how buffers around ancient woodland should consider more than simply a wide ranging buffer of 50m.
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North Warwickshire Local Plan Examination
18 Since the Lockhart Garratt letter guidance2 was further updated on the 5th November 2018. With relation to buffer zones the guidance states:
‘A buffer zone’s purpose is to protect ancient woodland and individual ancient or veteran trees. The size and type of buffer zone should vary depending on the scale, type and impact of the development.
For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone. For example, the effect of air pollution from development that results in a significant increase in traffic.
A buffer zone around an ancient or veteran tree should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5m from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter.’
19 Gladman therefore consider that the criteria (8) is not effective or in accordance with National Policy, we consider that in ought to be changed to read.
‘the provision of at least a 15m buffer will be retained and maintained to the ancient woodland of Brett’s Wood. The exact extent and nature of the buffer will be determined through the application process with reference to the relevant national guidance and site specific circumstances.’
2 https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences (retrieved 05/03/2019)
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North Warwickshire Local Plan Examination
Appendix 1 – Land ownership plan
6
© Appendix 2 – Sworders Masterplan Meml CS Moor Wood OAK DR
2 1
14 2 16 11a
2 11 Woodside House 1 ROAD
24 5
6 1
MOOR
CRESCENT 3 WOOD 7 161.6m 2 10 MOOR
MOORWOOD LANE 1
29
12 11 6 1 1 ASH DRIVE
HAYES ROAD
26
24
5 1
26 13 4 Def Whinchat
11 2
1c 1b
Nursery Hill 2
2-4 Primary School 7 158.0m 141.2m
Wood View 1a 34 1
CS 13
El
Path (um) 163.6m Four Winds 5-10 166.9m B 4114
2 Sub Sta
Moorwood House 24
79 12 BLUEBELL CLOSE
13 15 11
Def
19 1 25 153.1m
73 6 12 Inniscarra Hillview 75 Ford WALNUT CLOSE Spinney 20 69
44 16 168.0m Homelands 1
Garth Sherrall FB 21 61 Moorwood Lane (Path)
63 16a
28
9 Kriens 8
Holly Bank 148.4m ANSLEY COMMON 137.2m
16b
30
17
16 59 11 15
Works 22 16 2 54 56 El 53 9
TCB 46 45 Sub 21 Warwick House Wood View 47 21 26
Nursery 18 Sta Antlers 60 LB Hill 23 23a WEST VIEW 25 Farm 33 CS 25a
48 41 59 Side Dismantled Railway MEADOW Seasons
164.8m Sherwood Rise 2 35
House 1a HAWTHORN WAY 1
ROAD
52 33 40 THORN 9
Path (um) 10 17 31 Factory Track 30
3 9 184 CLIFFE 14
Oakdene 50 Willow Lodge SCHOOL HILL 22 23 29 Kenanne House 27a
27
1 41 5 1 170 24 15 WAY 5 57
137.5m 11 31 162 18 Garage 132.2m 2 9 56 7 ROAD
2 8 150 10 28
26 1 BEECH CLOSE
4 30
189 140 24 2 38 4 16 CR
1 24
Ward Bdy 183 16
2 20 ESS
NURSERY 2 ST 5 LB Def JOHNS 138 32
8 21 LAUREL DRIVE 12 LAUREL DRIVE
6 COLESHILL ROAD HAZEL
19 CS 26 10 22
ROAD 9 CLOSE 34
Hall 31
18 126 SH
NI 7 28 COR 33 LIMES 1
CL 39 Issues 1
162.6m COPPICE 102 18 8 2
98 25 41
181
7 3 35
17 22
PO 90 21
16 37 171 CLOSE
2 169 2 134.1m 9
12 COLESHILL ROAD 1
1
Path (um) 19 11
1
151 13
88 1 3 SILVERBIRCH 28
15 84
74 72 3 17 80
29
147 66 12 1 3 64 15 5 8
El Sub Sta 2
130.1m CS 145 11 Hill Crest
CLOSE Shelter Ward Bdy 123.8m ORCHARD
58
Track 6 133
10 2 4
8 19
56 6 TCB LAUREL DRIVE 7 17 7 Allotment Gardens 113 2
10 4 16 38 36 SCHOOL HILL 46 MOORBROOKE 123 44 121 4 11
15 97 30 1 MOORWOOD LANE 3 14
115
The Wash House 83
15 161.8m 2 81 127.7m 12 1
1 Def
Ansley Hall 65 Shelter Club
20
Church 71 53 3 Wind
Dancer 2
Woodwinds Windrush 69 63
B 4114 75
53a 45 105a
81 117 LB 129
The Coach House 16 131 105 89 145
125.2m 2 121.2m 121.6m 116.0m COLESHILL ROAD
LB Stanley Brick House 116.4m
Ansley Park 43
86 82 92 Chancery
El Sub Sta 88 80
98
102 Court 84 134
Ansley Hall House 148
100
76 14
166
118.7m PH to
ANSLEY COMMON 150
9 1 98a
1
114.8m 11
3
96 The Cottage 94
1
27 172 1
15 13
Sports Pavilion 71 CS Ruin
9 Estate
6 Bretts Hall Ansley Park 1
6 7
67
Sports Ground Play Area 5
2 23 66 WILLOW 25 12 Sinks 18 CLOSE
24
61 FLETCHERS DRIFT LANE Def 19 59 12
Sports Ground 29 Path (um) 114.4m
1.22m RH 20 El Sub Sta 54 30 26
Def CP & ED Bdy
Bretts Hall Estate Ward Bdy
1 48 1.22m RH
32 10 2 Def Def
31
Issues
Def ALDERS LANE
1 to 3 to 1
34
ED Bdy 5 42
36 9
39
1.22m RH 38 13 CP & ED Bdy 11 Bret's Hall Wood Def 116.1m
1.22m RH Def
FW Bar Pool Brook 1.22m RH 1.22m RH 43 Pond 1
Bret's Hall Farm 51 2 3 49
Acorn Wood WAGGESTAFF DRIVE
Def 53
El Sub Sta 17 CP & ED Bdy PLOUGH HILL ROAD LILLEBURNE DRIVE
59 10 1
13 61 48
to
67 Def
69
1.22m RH 16 2
27
114
18
14 129 120.2m 35
31 1.22m RH
CD 58
85
42
40 30
1.22m RH 102
91
Pond Def 64
32
34 66a
96
97 66
Path (um) 113
6 68
SMALLMAN ROAD
8 Tk B 111
Nuneaton Common
126.2m 109 1
98 Thisledome Community Def Def 84 14 CP & ED Bdy Stretton Centre & Garden
Lodge 7
Pond 100 9 107
Def Pond
74 106
1.22m RH 107 82
70 103
66
109
Park Farm 110
131.2m
112 76 Def 97
Ruin 128
Plough Hill 93
117 83
121
Pond 89 132
Path (um)
136 138 1.22mFF
Issues 67 Nuneaton Common
Pond 135.1m
Bowling Green
146 Wood Barn Farm 148
Pond
Plough Inn
(PH)
Issues
135.1m 174 to 176 to 174
Thornyfield Wood
Pond Track El Sub Sta
Mast
203
PLOUGH HILL ROAD Pond
205
127.5m
245
247
Shires
249
251 Plough Hill
SCHOOL LANE Golf Centre
271 Driving Range Plough Hill Farm Cottage Pond 123.5m
Path (um) 287
Golf Course FB Issues FBs
FB 301
120.3m
Path (um)
Pond
Path (um)
13
12
11 5
7
Pond SCHOOL LANE Freesland Farm
128.2m
Dismantled Railway
PLOUGH HILL ROAD
Whitegates CG 3
Def 1 The Elms 133.1m
SCHOOL LANE
Galley Common School THE ROOKERY
Nursery 1 Pond
2
Path (um) 1a
Galley Gap 136.2m
The Hermitage 4
Path (um)
ED Bdy
10
Barn Moor Wood 15 106
15
Cattle Grid 17
10 5
176
MARLOWE CLOSE Cattle Grid 18 Hill Farm
CHESTERTON DRIVE
20 81
Hill Farm 6 12
174 1 60 116 Galley Common 4 48
142.3m 6
BROWNING CLOSE
2 BLAKE CLOSE 3
1 11 War 28