Shipston on Stour Neighbourhood Plan

Environment Topic - Audit and Issues Report

By Stephen Miles

For The Environment Topic Group

Interim report June 2015

Updated report and final issue version 03 September 2015

Contents

1. Background Page 1

2. Methodology Page 5

3. Audit findings Page 6

4. Cross topic group tasks Page 13

5. Sustainability appraisal Page 13

6. Recommended actions to permit audit sign-off Page 14

7. Update on recommended actions as 6. Page 15

Annex A: Designated Area map Page 16

1 Background

1.1 Scope and purpose of the audit

1.1.1 This document summarises the position reached as of the end of August 2015 regarding work on the local natural and built environment topic. The facts as researched and assessed that have led

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to positive ideas and potential policies and proposals are outlined, with a commentary on the potential relevance to the current and prospective development of the town. An overall conclusion is provided, and the key issues and opportunities to be considered per se and by the three other plan-making topic groups – economy, housing and infrastructure - are noted. Some aspects of the work remain inconclusive, and suggestions were made in the June 2015 interim report as to the priorities for further action and methods to draw this aspect of the plan-making to a close such that wider community engagement can soon happen. There was subsequent action in respect of the important edge-of-settlement issue notably a team workshop on 25 August 2015 at which a tenable approach to the issue was resolved and a set of three potential policies and proposals was agreed. Section 7 of this updated report summarises that meeting and outcome. The relationship with the emerging Town Design Statement was also resolved at that meeting.

1.1.2 The Infrastructure Topic Group comprised the following individuals: Phil Sykes; Phil Wragg; and Jo Wilding. Phil Sykes focussed on the natural environment, specifically ecology, landscape and the availability and quality of public rights of way and open spaces. Phil Wragg focussed on the riverside area issues and opportunities, including overlaps with flood risk management. Jo Wilding covered the heritage assets component of the built environment. There was close collaboration with the Housing Topic Group because a key implication of the prospective growth of the town through then current planning applications and appeals and the emerging draft Core Strategy was/is a significant additional impact on the surrounding landscape and more pressure on existing greenspace assets.

1.1.3 The topic group has made a considerable and sincere effort to research and assess the facts. It may well be that some aspects of the town’s environment have been missed or not given enough attention. We apologise if this is so, and trust that those individuals and organisations who may wish to add or modify will do so in good part.

1.2 Producing a Neighbourhood Plan

1.2.1 The decision by the Town Council [STC] to sponsor the preparation of a Neighbourhood Plan was made in November 2012. This followed in-depth soundings of the local community to gauge the appetite for such a project, whether substantial help would be volunteered, and what local people thought were important issues for the future of the town. A summary of this early stage of the plan-making process is in a comprehensive Scoping Report1 prepared for STC in November 2012. This document was the basis of a formal STC decision to proceed, starting with a submission to the Stratford-on-Avon District Council [SDC] for their authorisation to commence the project. That authorisation was given on 08 April 2013.

1.2.2 In May 2013, as part of the ongoing community engagement, notably at the yearly Wool Fair, STC sought community volunteers to form an independent project team to take forward the work. The proposed plan-making process utilised the publications from Locality2, one of the national advisors then hired by the Department for Communities and Local Government [DCLG] to promote interest and provide ongoing support. Assistance from Locality had been secured for the launch of the process, and this continued through 2013/4.

1.2.3 It was decided to sub-divide the plan-making work into four categories: economy; housing; environment; and infrastructure. Volunteers were appointed to these topic groups. Their initial task was to research and collate the important information such that the main issues were properly understood. When the facts and implications were known there would be discussion within and

1 Producing a Neighbourhood Plan Scoping Report issued by STC November 2012 2 Neighbourhood Plans Roadmap Guide: Locality 2012

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between the topic groups, and the resulting ‘evidence’ would be taken forward into emerging options for the future of the town.

1.2.4 It should be noted that from the outset, through the community engagement mentioned in S1.2.1, a number of key environmental concerns had been identified, refer to the Scoping Report Section 4.3. These included a) an improved green environment, specifically recreational and public open spaces and access to them and the nearby open countryside; b) conserving and sustaining the vitality, functionality and heritage value of the town centre; and c) whether or not significant additional housing development would be a good thing, as this would involve further encroachment into the valued landscape surrounding the town. This feedback gave some focus to the work of the environment topic group.

1.3 Town Design Statement

1.3.1 The environment topic work has run in parallel to the production of the Shipston Town Design Statement [TDS]. The current issue3 is Revision 4 dated May 2015. This document has been written by Chartered Architect Paul Richardson for STC. The process included some community engagement in 2012 when views on matters of design and character were invited. There is a lot of overlap between the terms of reference and contents of the TDS and the issues as explored by the environment topic group as part of the production of a Neighbourhood Plan. The environment topic group is thus very reliant on the validity, outcome and effect of the TDS document.

1.3.2 Whilst the TDS production has not been part of the formal Neighbourhood Plan process, it offers much very useful factual and descriptive information particularly on the character areas that make up the town and the evolution of the built form of the settlement. The proposed guidance and policies therein have not as of June 2015 been considered or adopted by SDC, and it remains to be seen whether they will be and thus what standing, if any, the TDS will have. Some of the proposed policies are in my professional opinion unlikely to be confirmed as they are untenable in development management terms, for example limiting new housing developments in unit numbers or proscribing development above a certain land contour level. It must also be said that some of the observations and conclusions reached are rather subjective and opinionated, reflecting perhaps a strong preference for historic as opposed to modern buildings, the latter for better or worse being the reality for much of the town. The Sheldon Bosley Hub building may be very ‘1960s period’ but it is a much valued and used facility! To avoid any issues implicit in the TDS the environment topic group has used the factual content as opposed to heeding the untested proposed guidance and policies.

1.4 Planning policy context

1.4.1 A Neighbourhood Plan is a community-led framework for guiding the development, regeneration and conservation of an area. It will likely contain a vision, aims, planning policies, and proposals for improving the area or providing new facilities, and possibly the allocation of key sites for specific types of development, green areas for special protection. This Neighbourhood Plan will include ‘site allocations’ further to a decision taken in July 2014 in conjunction with SDC. It may deal with a wide range of social, economic and environmental issues or may focus on a few pertinent matters. As described the Shipston-on-Stour plan is looking across a wide range of issues, guided by the launch-stage and subsequent community engagement. When completed and adopted such a

3 Shipston Town Design Statement ‘Draft Recommendations following public consultation in 2012’ Revision 4 May 2015

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plan will be part of the statutory development plan for the area. That statutory status provides far more weight when planning decisions are made than do other informal local documents such as parish plans and village/town design statements.

1.4.2 A Neighbourhood Plan must comply with European and National legislation, and must have appropriate regard to national policy and guidance and be in general conformity with existing strategic local planning policy. With regard to the latter it should be noted that at the time of writing an interim report from the Inspector on the examination-in-public of the SDC draft Core Strategy4 was published by SDC in March 2015. That interim report identified some major shortcomings, including some in the evidence backing the stated housing land supply requirement. Further technical work is ongoing to address this issue. It may well be that this has implications for the main rural centres including Shipston on Stour such that allocating additional housing land will be a consideration. This would overlap with already commenced work on the ‘site allocations’, and as has been noted the Neighbourhood Plan will embrace site allocations for the town. To say the least the position remains fluid.

1.4.3 Over the last 3 or so years there have been several relevant major planning applications mostly for large scale housing developments. A more detailed commentary can be found in the companion Housing Topic Croup report. These applications have mostly been for edge-of-settlement sites [this can include the previously developed site of the former Norgren factory]. The relevance to the emerging Neighbourhood Plan has been the ongoing in-depth analysis and debate about matters such as landscape and visual impact when these applications have been determined, including some applications subjected on appeal to public inquiries. The accumulated arguments and evidence have provided a useful resource for the environment topic group. In the absence of an adopted Core Strategy the saved Local Plan policies have been regularly tested and have generally speaking not stood up well.

1.4.4 The work locally of the community group known as SHARD [Shipston Against Runaway Development] should be noted as they have made representations in regard of several planning applications. Those representations have included in-depth reasoned submissions on such as the landscape and visual impact of proposals. Environment topic group member Phil Sykes has attended SHARD executive meetings to monitor their work and emerging information and channel their analysis into the work of the Neighbourhood Plan team. It must be stressed that this input from what is a residents’ action group has been carefully and transparently handled, to ensure that the incoming facts and arguments have been objective, and that the Topic Group thinking has not been unreasonably influenced.

1.5 The plan area and setting

1.5.1 The designated Neighbourhood Plan area is the Parish of Shipston-on-Stour, see the map at Annex A.

1.5.2 Without recounting some old history it should be appreciated that the Parish boundary is unusual, in that the eastern boundary is the River Stour, and the town is only on the west bank. In Brailes Road and Fell Mill Lane beyond the river are located a few nearby outlying houses, a small industrial estate, and importantly the local recycling and waste disposal facility. Functionally these are part of the town, and figure in the appraisal of facilities, though strictly they are outside the plan boundary. 4 SDC Proposed Submission Core Strategy submitted to Secretary of State 30 September 2014

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1.5.3 It should also be noted that the town is an important local services centre for a wide area of the Stour Valley and surroundings, including some settlements in neighbouring Gloucestershire. For example the Medical Centre has twice as many registered patients as live in the town. Such wider-area use of town facilities needs to be considered.

1.5.4 The Town Design Statement [refer S1.3] contains a helpful and thorough description and analysis of the development history of the town, including some useful maps showing the evolving built area over the past two hundred years. This is followed by a lengthy section where five colour-coded ‘character areas’ are defined, described and evaluated. This provides particularly useful factual information, though the narrative gets unhelpful at times when subjective critical comments are made about modern buildings and the more recently built housing estates.

2. Methodology

2.1 Guidance and precedents

2.1.1 The topic group has applied the guidance in the published Locality Roadmap Guide, in particular Worksheet 3 therein5 ‘Building the Evidence Base’. This gives sound advice on the need for a robust approach, and the sources of evidence. Of particular note has been the published evidence base supporting the emerging Core Strategy. Two reports are especially helpful. A report6 by technical consultant Arup, hired by SDC to review District-wide the provision and adequacy of recreational open spaces, contains an excellent summary list and commentary on the position within the town. This suggests that judged by pertaining planning and recreational standards there is a shortfall. A report7 for SDC by landscape consultant White Associates provides an analysis of the landscape and visual impact sensitivity of the main rural centres including Shipston on Stour to prospective housing and commercial development. This work used established methods to define and analyse the adjacent landscape and ascribe sensitivities. Some of the aforementioned planning applications and appeals have used the White Associates analysis, which together with consequent landscape and visual impact reports for the applicants and planning authority have provided an insight of the issues.

2.1.2 As noted the environment team allocated particular themes for their in-depth research. Their preferred method was to take as a starting point the recorded community feedback up to mid-2014. They then considered the work-in-progress at that time with two key initiatives: the Town Design Statement [TDS]; and the Shipston Area Flood Action Group [SAFAG] which included broad thinking about the riverside area and what might be created by way of a more useful and functional asset. The bodies of evidence and ideas from those projects were assessed, and it was wisely felt that duplication would be foolish, the ongoing work should be encouraged and monitored, and the outcomes might inform the plan-making work.

2.1.3 An information gap was identified in mid-2014 in respect of nature conservation, knowledge of local habitats and species. It had been noted that according to the published evidence base for the draft Core Strategy there were no recorded National or European designations locally. An ecologist from the Warwickshire Wildlife Trust was asked by the topic group to survey the Parish and report8 on the findings and significance.

5 Locality ‘Neighbourhood Planning Worksheet 5 Building the Evidence Base’ 20126 Arup: PPG17 Open Space, Sport and Recreation Assessment 2011 for SDC7 White Associates: Landscape Sensitivity Assessment 2011 for SDC8 Warwickshire Wildlife Trust: Survey Report to Environment Topic Group 2014

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2.1.4 The emerging Town Design Statement had not by late 2014 been sufficiently written-up to make a contribution to the topic group thinking so Jo Wilding9 researched the documented position with heritage assets and in March 2015 produced a working note on what is there and the significance. This information was fed into the two cross topic group workshops that were convened for February and March 2015.

2.1.5 Having identified the considerable range and quantity of evidence the preferred topic group approach was to take the already identified [from community feedback] concerns and issues, review those in conjunction with inputs of information and ideas from the other topic groups, and then review the evidence base such that a set of justifiable ideas, outline proposals and projects, and preliminary thoughts on guidance and policies could be put together. The key events for this work were the two all topic group workshops held on 17 February 2015 and 02 March 2015. Those events resulted in a published set of ideas for proposals and policies. A detailed note10 was issued in April 2015 summarising this information. This note is the basis for future wider-community engagement and the detailing and specification of the set of evidence-based proposals, guidance and policies that will from the draft plan.

2.1.6 In summary the environment topic content of that published note is:

An ambitious riverside initiative including better riverside land access and management embracing enhanced flood risk functionality, creating countryside access for recreation, a flagship part of a better tourism ‘offer’, with an emphasis on heritage value, habitat creation and conservation; include the London Road Sports Club land;

Designated sites for a ‘local nature reserve’ and a ‘local wildlife site’; Measures to locally increase resilience to flooding events; Put in place effective and enforceable design guidance and planning policies for edge-of-

settlement development, the aim being minimising inappropriate sprawl and mitigation of the effects where development is permissible;

Increasing the area of designated public open space assets, make what exists more useful, and create more legible, valued and useful access routes and corridors to and from the surrounding rural land;

Review the options for town centre traffic management and improved business vitality, tourism appeal, functionality and user experience in High Street and Market Place and connecting streets, alleys and car parking;

Promote alternative modes to the car, create better and safer routes for pedestrians and cyclists;

Further define, promote and protect the heritage and amenity assets that define the town’s character.

2.1.7 The above listed issues and opportunities were comprehensively reviewed by Phil Sykes and Stephen Miles on 02 June 2015. For each item three fundamentals were checked: that it had arisen through community engagement as a valid concern; that there is a basis in existing or emerging planning policy for intervention and action; and that the supporting evidence had been confirmed and evaluated. The following section of this report outlines the current view of the topic group on each listed item.

9 Jo Wilding: Built Environment Notes for Environment Topic Group 28 March 201510 Erry Lilley: Notes from Topic Groups Joint Workshops held 17/02 and 02/03 2015 issued 17 April 2015

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3. Audit findings

3.1 Riverside

3.1.1 The significance of the riverside corridor to the town lies in the very name ‘Shipston’, which has evolved from ancient names meaning ‘sheep wash town’. In particular a bankside area was where sheep were herded and prepared for market. Arguably there is too a wider significance derived from the site of the town nestled in the Stour Valley, with a characteristic landscape upstream and downstream. So the river, riverside land and valley setting have a special relevance for the town, and understandably figured large in the community engagement feedback to date and the attention of the environment topic group. Of note also is the considerable parallel work done by Sheelagh Saunders and colleagues to investigate and promote the idea of a riverside recreational walk. There is also an important overlap with the recent and ongoing work by Phil Wragg and SAFAG [Shipston Area Flood Action Group] which in conjunction with stakeholders such as the Environment Agency and land owners is promoting research and ideas for the prevention and mitigation of flood events [see S3.3. of Infrastructure Topic audit report March 2015].

3.1.2 The all-topic workshops in February and March 2015 resulted in a riverside ‘call for action’ at two levels. With the big picture it was recognised that the riverside locality near the Mill Street bridge and the overall riverside corridor through the Parish both offer great potential in different ways. The seminal significance and resource value of the river offers an opportunity for a major project to both harness water power through modern technology and to interpret and celebrate the history. A more modest and near term aim is to improve public access by way of waymarked trails upstream and downstream. Land owners have been contacted, with mixed outcomes regarding permissions to cross private land. The currently designated public rights of way are not hugely helpful for access, and in addition new footbridge crossings will be required to enable circular walks of a reasonable duration and distance. All that said, it may well be possible through negotiation with land owners and other stakeholders to create upstream and downstream waymarked circular walks of 30 minutes to one hour duration.

3.1.3 A proviso to the above aim is that in creating such leisure assets this must not cut across any initiatives arising from SAFAG and stakeholder actions, which are surely the greater priority.

3.1.4 The topic group also identified potential overlaps with nature conservation opportunities through the creation and management of wetland habitats along the river corridor. The main opportunity would be upstream at the edge of the Parish overlapping into neighbouring Barcheston, where there is an existing extensive area subject to flooding and with the basis of a wetland area. As with creating any public walks this conservation aim should be cross checked to confirm there is not a conflict with SAFAG aims.

3.1.5 The planning policy basis for intervention and action with the riverside corridor and Mill Street area is found in draft Core Strategy CS6. This calls for measures to protect and enhance the attractiveness and setting of the town.

3.1.6 It is also worth noting the considerable overlaps with the economy and infrastructure topics, refer to section 4 for more on this.

3.2 Nature Conservation

3.2.1 There are currently no designated sites in the Parish, either of national or local significance. The draft Core Strategy contains policy AS6 encouraging the local designation of ‘wildlife’ or ‘nature reserve’ sites. The previously mentioned 2014 Warwickshire Wildlife Trust [WWT] survey and report

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provides a basis for two suggested sites, one in each category, that the topic group is putting forward for consideration by the wider community and the land owners.

3.2.2 The proposed Local Nature Reserve site is a strip of land in the south of the Parish where the A3400 main road was diverted and straightened many years ago when still designated as a trunk road. The old route remains and the land between the old route and the current road comprises trees and shrubs, a paddock, and the Pig Brook watercourse part in open channel and part in a culvert. There has been virtually no management of this land, and it was of significant interest to the WWT ecologist who conducted the survey. The old roadway forms part of the public right of way between London Road and Willington, the latter reached by way of a footbridge over the River Stour. Thus public access to the edge of the designated site is readily achieved, with scope for an interpretation board. What is currently unclear is who owns the land. It may be a residual area of ‘highways land’ on the books of the County Council or Highways Agency [a legacy of the trunk road status]. Enquiries are being made.

3.2.3 The proposed Local Wildlife Site is an old orchard at Mount Pleasant, west of the town off the Campden Road. A key distinction to the Nature Reserve as mooted above is that a Wildlife Site does not have public access. The WWT surveyor identified the site as a suitable habitat for designation. The land owner is amenable to such a move. WWT is taking this designation forward so inclusion in the Neighbourhood Plan is primarily for information.

3.3 Public open spaces and countryside access

3.3.1 The Arup 2011 survey of public open spaces and similar assets for SDC identified that measured by the applicable standards the town is deficient in public open space and general public amenity land. The policy basis for intervention is in draft Core Strategy AS6 and CS24. Whilst some of the more recent housing developments have designed-in such spaces, including some with formal play areas, the older pre 1980s estates tended not to provide such assets, and the much older town centre area is unsurprisingly similarly lacking. The various upcoming housing developments such as those off the Campden Road will doubtless meet the required current standards and will include adequate provision.

3.3.2 As most areas of the town have views of nearby open countryside it seems to the environment topic group that two types of action may be called for. There could be an effort to better connect with the nearby countryside, and to create and enhance such ‘green links’ by way of suitable way marking, surfacing, planting and maintenance. Further, to redress the recorded public open spaces shortfall in certain areas of the town some additional sites, probably small ones, might be identified and suitably planted and maintained. The inventory of protected trees [those covered by preservation orders] was found to be surprisingly small, whilst many fine trees [including many within public land] perhaps worthy of better protection have been noted.

3.3.3 With the idea of enhanced connections to the countryside, the proposed riverside walk would provide public access to a substantial peripheral area. It would be even better if the riverside walk could ‘connect’ to the town centre by way of upgrading the landscaping in and around the Mill Street car park, through the public land component of the ‘gyratory island’, to join up with High Street [which might be the subject of changes - see Section 3.5]. Another possibility on the west side of the town is to connect with the prominent Hanson Hill. A public right of way - a bridle path – leads from the Campden Road between existing housing development up the slope of Hanson Hill and beyond towards Horseley Fields, Ditchford, and the village of Todenham. The public land where that path joins Campden Road is a large lay-by with very broad verges. Between that point and Telegraph

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Street is an existing network of footpaths. It would seem fairly straight forward to better define, surface and landscape this route, which would both encourage more pedestrian use, and would be a green link with the countryside. There may well be other such opportunities in the town.

3.4 Edge-of-settlement development

3.4.1 Perhaps the most prominent recorded issue for the wider community has been a concern about the scale and locations of major housing development proposals. In part this concern was simply because some local residents did not want more new houses per se – a not uncommon sentiment in this District and beyond. In part the concern was more considered, about the impact of such development on the town, and how large scale housing estate additions would harm the setting and character of the town. The companion May 2015 Housing Topic Group audit report summarises the scale of such proposals and the cumulative outcome. As noted earlier the draft Core Strategy still has a way to run, and the eventual total allocation of land for additional housing is not yet confirmed, so the apportioned housing land allocations for the Main Rural Centres – including Shipston on Stour – are not known either. This is the background to the issue of whether, and if so how, the Neighbourhood Plan should effectively deal with future edge-of-settlement development. Note that this is not entirely about additional housing development, it could be about commercial property development [look from a distance at the upper end of the Tilemans Lane business estate] or the further development of prominent public buildings such as the High School.

3.4.2 A good starting point to considering this difficult issue is to ask two basic questions: a) what in terms of restrictive policies and proposals can and should a Neighbourhood Plan include; and b) what evidence must be provided to support and justify the permissible policies and proposals?

3.4.3 Before attempting to answer those questions comment should be made about the approach taken by the environment topic group. That approach was essentially one of advocating containment, of ‘drawing lines in the sand’, such that development upslope of the 85 metres AOD contour line would be opposed, or that there should be no more large scale [defined as over 50 dwellings] housing developments. Such thinking mirrors that expressed in the draft Town Design Statement [refer to S1.3] though in fairness the TDS does also go pretty thoroughly and sensibly into the positive design guidance and design principles that potentially can make the best of edge-of-settlement developments. Producing some tenable content on this issue for the emerging Neighbourhood Plan starts with clear answers to the two basic tests as noted above.

3.4.4 So what policies and proposals should and can a Neighbourhood Plan include? A good starting point is the National Planning Policy Framework11 [NPPF] sections 76 and 77. This states that local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them. By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances. Section 77 qualifies: the designation should only be used a) where the green space is in reasonably close proximity to the community it serves; b) where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and c) where the green area concerned is local in character and is not an extensive tract of land.

3.4.5 If achieving such designations locally is an aim, what evidence and process is required to achieve and justify that aim? A good start would be to research some already adopted neighbourhood plans to establish whether and how they embraced this aim. Parallel to that the

11 DCLG: National Planning Policy Framework March 2012

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topic group should hold a workshop meeting including if he is willing Paul Richardson, author of the Town Design Statement [TDS], and a representative from SHARD to contribute their research-based ongoing thinking on the significance and value of the local landscape and town setting. This workshop needs to start by agreeing what in terms of the neighbourhood plan the aim actually is, what is wanted, and realistically what can be achieved. The lessons from other plans can be noted. Without pre-judging the outcome it would be good if the conclusions were that a few localised areas - not large tracts - of land at the existing settlement edge [assume that ‘in the pipeline’ developments happen] can be demonstrated by way of facts and analysis as being justifiable areas of restraint defined by the characteristics listed in S3.4.4 above. It is also essential that constructive design guidance as how best to design and deliver edge-of-settlement development is considered at the workshop, starting with the many sensible views expressed in the TDS. This will ensure that what emerges is a neighbourhood plan that accepts the probability of some additional future development in suitable locations as and when justifiable housing needs are to be met, and influences where and how that might most acceptably happen in practice. That approach would sit alongside the designated ‘areas of restraint’. A balanced and constructive approach.

3.4.6 It would be no bad thing to sound SDC policy planners to a) ensure they agree with the aims and will be comfortable with the outcomes; and b) to cross check the evolving housing land allocation quantum and the policy basis [which is in essence a continuation of the saved Local Plan policies for landscape and heritage assets protection].

3.4.6 Holding this workshop and getting a good outcome is a priority for the topic group and the wider neighbourhood plan team. It needs to happen before the team embarks on wider community engagement so that the team’s approach to edge-of-settlement development is very clearly stated and the facts and reasoning are properly explained.

3.5 Built environment

3.5.1 At the meeting between Phil Sykes and Stephen Miles on 02 June 2015 the topic group stance was summarised by Phil Sykes. The Town Design Statement [TDS] should be concluded and adopted by the SDC, thus contributing to the Neighbourhood Plan details about the town’s built environment and imparting a set of policies and guidance notes that should, by application in the development management process, help to make future development more fitting and relevant.

3.5.2 To achieve this outcome will require the formal adoption of the TDS by SDC as ‘supplementary planning guidance’, plus the transfer of the key policies and guidance within the adopted TDS into the Neighbourhood Plan. The current issues are a) that whilst SDC has helpfully reviewed an earlier draft TDS they need to comment on the latest May 2015 version; and b) that as currently drafted some of the design guidance is perhaps overly prescriptive and expressed as mandatory requirements, including some standards that would in practice be dealt with as technical performance requirements and not planning matters.

3.5.3 The topic group is seemingly relaxed about the Neighbourhood Plan not being overly focussed on the protection of heritage assets, the existing legal context being felt to be robust and having performed adequately for many years, and will therefore continue to do the required job. Where this stance may need some further thought is in relation to the Neighbourhood Plan guiding some redevelopment and renewal within the town centre. There are two main circumstances. First, there could be a case for the plan including encouraging policies and guidance to ensure that small and medium scale redevelopment in the historic core area is well designed and integrates suitably. An example would be a future project such as was built at the Old Bakery off Telegraph Street. There

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are varying opinions about that outcome, raising it here is not a judgement, but it is an interesting project that intensified development and added new town centre housing in a mixed-use environment, no mean achievement. The second circumstance is where the neighbourhood plan contains essential proposals and projects, including possibly some ‘site allocations’ with significant implications for heritage assets. An example could be advocating major changes to the traffic management and functionality and townscape of the High Street and Market Place area, to be done principally to improve town centre vitality and boost the local economy. Or a project to upgrade the green environment near the Mill Street car park and make more of the riverside as a leisure and tourism asset. Both projects will at the design stages require a full exploration of the relationships with heritage assets and how such considerations site with other aims and objectives such as economic benefits and the technical standards to be met.

3.5.4 The point is that either the topic group really should get more involved in built environment issues, especially heritage assets; or if reliant on the TDS to cover that ground the topic group as a minimum should guide the TDS to a conclusion very soon and import the resulting policies and guidance into the neighbourhood plan. If the latter course is preferred then the imported policies and guidance will need to be put in the cross-topic context such that the broader aims of projects and proposals benefit and heritage assets conservation does not unduly hold back progress.

3.5.5 The topic group, in parallel with economy and infrastructure group colleagues, have considered the potential for making significant changes to the traffic management, functionality and townscape character of the High Street and Market Place area of the town centre. This was looked at 12in 2010 by Warwickshire County Council primarily in terms of better traffic circulation, including a public consultation event in Townsend Hall. The outcome of that exercise was a mixed response of those in favour and those against, the latter including a number of traders concerned about the impact on their businesses. The neighbourhood plan team has re-visited that previous work, which included options for better traffic circulation, and a preliminary design and budget. The team discussion has included thinking about ‘shared space’ approaches, whereby pedestrians and vehicles would jointly use an improved, landscaped space. Sustaining and ideally improving the vitality and trade would be perhaps the main aim, including raising the game in terms of the tourism and heritage appeal of the town. Relevant too is the desirability of sustaining a mix of users such that retailing, professional services, residential and pubs and restaurants can co-locate and thrive. Recent planning control changes make it easier to switch flexibly between certain use classes, such as offices and residential. The angles the environment group will focus on will be landscape design and heritage assets. This will not be an easy project to consult about and define, but it has figured from the outset of the neighbourhood plan engagement as something many respondents want to see on the agenda.

3.6 Flood risk management

3.6.1 This subject is also covered in some depth in the Infrastructure Audit and Issues report. The reason for also including it as an environment topic is to note the various relationships with emerging thoughts on environmental policies and proposals. Reference has been made to the SAFAG agenda and progress, and is it important that the aims of that group and their stakeholders is always fully considered by way of dialogue. Better flood risk management is really a ‘given’ aim for the neighbourhood plan and must not be compromised.

3.6.2 There are two particular issues that have emerged from the environment topic work that need highlighting. First, with the volume of consented additional mainly housing development that will be

12 Warwickshire County Council: consultations and preliminary options designs [reports and drawings 2010 [with Richard Taylor for Infrastructure Topic Group]

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built over the next few years, and the possibility of more in the future, as has been noted those developments would mostly be well upslope, with the adequate surface water management provided for individual developments and in the aggregate. It is not entirely clear that this aim is being achieved, and suitable policy content in the Neighbourhood Plan is desirable. This will give a local dimension to the generic policy in the emerging Core Strategy. Most likely the drainage requirements will be met on-site so as not to compound downslope issues or cut across future mitigation and upgrades and/or changes to the drains or river channel.

3.6.3 The second issue that has emerged is concern about the condition of the existing network of surface water drains and watercourses that collect storm water and discharge to the River Stour. From what has been said this is a complex matter. The network has been extended piecemeal as the town has expanded. Where and how the connexions were made, and the capacities and condition of the sewerage, do not seem to be well understood. There is certainly a need to have better information about the sewers network per se, the legal position in terms of ownerships and discharge rights, prospective changes to the river channel and wider catchment as with the SAFG agenda, and not least the additional drainage requirement – hopefully minimal – that will derive from new upslope developments. There is potentially the making of a neighbourhood plan project to get to the bottom of this issue, view to the inclusion of appropriate policies and proposals, and ensuring that related projects that might emerge such as an enhanced riverside will be suitably cross-referenced.

3.7 Promoting alternatives to the car

3.7.1 A cross topic generic issue that the team has considered, particularly so the environment group, is what should and could be done to encourage the use of alternatives to using the car for local trips within the town. Reference has already been made to the scope for better signed and defined pedestrian routes to and from the adjoining countryside. Such routes might also apply to cyclists and mobility scooter users.

3.7.2 The main message from the environment topic group is that this consideration should be put at the heart of the shaping of policies and the scoping of proposals. With much new peripheral development, primarily housing but including potentially a supermarket and new health centre, there will be increased traffic, and it is desirable to mitigate this by creating and promoting alternatives. Further thought will be given to appropriate policies, and the design guidance in the related Town Design Statement will be helpful.

3.8 Sustaining the town’s character.

3.8.1 Arguably the overarching issue for the environment topic group has been and remains the challenge of conserving the character and setting of the town as it expands and becomes ever more so a town where people live rather than work, and the average age of population is high and increasingly so. The cross topic workshops – see S2.1.5 – produced a set of statements. Those centred on better collating information about the heritage and amenity assets within the town, and raising awareness by promoting those assets much more vigorously and effectively. A key role for the Town Design Statement [TDS] was noted.

3.8.2 This report is an audit, it ‘takes stock’ and offers views on what has been done and what has been achieved. I have to say that in my opinion the recorded suggestions and ideas about conserving and protecting the assets that comprise and define the town’s character will not make much of a difference. It is perfectly sensible to gather and present information on heritage assets, and to seek

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to protect those assets. Better dissemination of the information is a good idea too. But what is the point? Has that question been asked? I’m not sure it has so I am asking it now.

3.8.3 I think three things need to be more evident in the environment topic contents for the neighbourhood plan in order to make a difference and to sustain the town’s character:

There has to be more emphasis in the environment contents of the plan on regeneration and renewal and managing change as opposed to preservation and restraint and not trying out new ideas and projects;

There has to be a focus on a small number of practical and do-able initiatives that will be recognised and valued as making a difference by the wider town community and visitors; and

The policies in the plan should be few in number, kept simple, targeted at the key concerns and issues, and they should be a balance of ‘carrot and stick’ such that the underlying aim is both restraint and progress, starting with the latter.

3.8.4 These characteristics are actually all there, but some are buried deep or some have hardly been addressed. I will return to them in the concluding Section 6 of this report by way of suggesting what actions by the topic group will quickly conclude this stage of the plan-making. I will also, having been critical, suggest what might emerge to meet the bullet points above.

4. Cross topic group tasks

4.1 There needs to be consideration by the three other topic groups of this report such that a) the findings are acknowledged and accepted; and b) so that cross-topic issues and opportunities are carefully considered and potential proposals and projects are identified.

4.2 It is most important that ‘green infrastructure’ [see Infrastructure Topic Group Audit and issues report February 2015 S1.3.3 for a list of what is included in this category] is researched, appraised and reported. This task should be completed as soon as possible by the Environment Group.

5. Sustainability Appraisal

5.1 A final and generic issue for all topic groups is how most effectively to guide and embed sustainable development13. This bears on all of the mentioned environment topics. A very good starting point is for the topic groups to jointly decide how they will use ’sustainability appraisal’ as a policy formulation tool. This methodology will figure in the plan-making by ensuring that the draft plan as a minimum is consistent with the other existing and emerging plans produced by the District Council.

5.2 The main point is that sustainability appraisal is a very helpful tool14 well worth doing and not just because a ‘box has to be ticked’. An early discussion across the topic groups should look at the application of the tool and get it moving before in-depth consideration of issues leads to emerging possible policies and proposals. An input from the District Council is required to ensure their approach is understood and they will ‘buy-in’ to what is done locally.

13 Definition: an approach to development that aims to allow economic growth without damaging the environment or natural resources so compromising the ability of future generations to meet their own needs. Locality Roadmap Guide Glossary of Terms 2012.14 Levett-Therivel ‘DIY SA: Sustainability Appraisal of Neighbourhood Plans’ August 2011

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6. Recommended actions to permit audit sign-off

6.1 The somewhat back-to-front approach used by the environment topic group has been noted, starting with issues and ideas then collating and researching the evidence. This audit has concluded that whilst this is not a conventional way to work, when the evidence base has latterly been cross-checked there is indeed a ‘joining-up-of-the-dots’ such that the emerging ideas for policies and proposals can in the main be justified. That said there are two evident weaknesses. It would be sensible to address these now, before further wider community engagement starts.

6.2 The first weakness is the considerable reliance placed on the emerging Town Design Statement [TDS]. The topic group needs to decide what the relationship with the TDS is going to be. If that linkage is simply one of using and cross-referencing the comprehensive and useful factual evidence in the TDS to inform the topic group thinking and conclusions that is fine. If so that working assumption needs to be clearly stated. If the relationship is based on an assumption that the policies and guidance in the TDS will become accepted by the District Council, that is not yet known, and it could be some time before it is known, and if accepted the TDS has been formally adopted as supplementary planning guidance. So an action now for the topic group is to take a view on which option to run with. I suggest the more certain option is the former. But this is for the topic group to decide, based upon comments from the TDS author and the District Council.

6.3 The second weakness is the work done by the topic group on the important edge-of-settlement development issue, forming views on the best approaches to defining peripheral land areas of restraint, how to go about defining those areas, and what policies and guidance might be included in the Neighbourhood Plan. The work done to date has not really got to grips with this key issue for the town. A good way forward would be to set up a workshop style meeting between the environment topic group, the TDS author, the Housing Topic Group lead, and possibly a representative from SHARD if they are willing [to impart the work being done on landscape and visual impact]. Prior to that meeting the District Council should be sounded about the validity of including within the Neighbourhood Plan this type of designation and policies – including the use of ‘site allocations’ to define edge-of-settlement areas of restraint and further opportunities. This meeting needs to happen as soon as possible.

6.4 These weaknesses can be addressed and good outcomes most likely can happen. They do not diminish the otherwise sound analysis that has been done. There are some great ideas and prospective projects to take forward into wider community engagement. Of those ideas arguably the three priorities for dialogue with the other topic groups and thence putting to stakeholders and the wider community are:

A Riverside initiative: defined by big ambitions, a visible and conspicuous set of on-the-ground improvements to celebrate the essence of the town and become a significant visitor attraction and amenity;

A town centre public realm centred on High Street and Market Place: taking forward previously gathered information and preliminary design ideas, the aim being changes that will radically improve vitality, visibility and attractiveness to the hub area of the town; and

A demonstration project to better link and the surrounding countryside via existing peripheral housing, to the town centre: this connection to be well landscaped, safe and attractive to use, and

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providing an alternative to the use of the car by encouraging pedestrian and cyclist use. A possibility is a route from Hanson Hill to High Street using existing if in places down-at-heel paths and tracks.

6.5. If the two weaknesses are sorted out soon, and the three above noted priority opportunities are fleshed-out by way of further engagement, together with the other proposals and policies that have been identified, a strong environmental content will be evident within the emerging Neighbourhood Plan, positively taking forward those themes and issues that figured in the earlier community feedback. This is a good basis for this topic component of the plan.

7. Update on recommended actions in Section 6

7.1 Section 6 above identified two weaknesses that needed to be addressed. The first was the relationship with the emerging Town Design Statement [TDS]. The second was to put together a coherent and reasoned approach to dealing with the identified edge-of-settlement issues. There was good work done by the topic group in July and August 2015 to make progress on these matters. In particular a workshop style meeting was held on 25 August as recommended in the June 2015 interim report. That workshop was preceded by a meeting between Phil Sykes and Stephen Miles to agree the required steps and prior research for that workshop meeting.

7.2 As noted in Section 6.2 above there was a choice to be made by the topic group between relying on the TDS being concluded and adopted as supplementary planning guidance, or using the factual contents in the TDS Draft 4. The topic group decided to do the latter. This was a pragmatic decision as the Neighbourhood Plan work can move ahead independent of the TDS progress and outcome. On this basis the considerable and very useful factual information within the emerging TDS was imported to the workshop meeting on 25 August and no doubt it will be used more widely by the team as well.

7.3 The second noted weakness has been adequately addressed. As recommended in Section 6.3 above the advised workshop meeting took place. There was a good understanding demonstrated of two key matters: a) the need to regard the settlement edge as a transitional and evolving zone where the built area meets and merges with the rural surroundings, such that there is not a definite boundary, and thoughts of ‘lines in the sand’ proscribing future development are misguided. And b) the need to think both of areas of restraint and areas of future development opportunity as justified by hard evidence on the characteristics and significance of the landscape. Of particular value was the June 2015 independent report to SHARD on the landscape character and significance of an edge-of-settlement area to the Southwest of the town. That report15, by consultant Landscape Matters, demonstrates the need for rigorous detailed field research and analysis to best understand the significance of the landscape, and thus define the basis for suitable policies and proposals.

7.4 The outcome of the 26 August workshop meeting was a set of three potential policies and proposals:

The protection of ‘valued landscape’ as designated ‘Local Green Spaces’ where there is evidence and reasoned justification in line with NPPF paragraphs 76 and 77;

The designation of ‘areas of opportunity’ for appropriately located and designed development within the edge-of-settlement zones such that modest built area extensions might happen; and

15 SHARD: SW Study Area Shipston-on-Stour – A landscape and visual sensitivity appraisal. Landscape Matters, June 2015.

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The designation of two ‘arcs of opportunity’, one northern from Campden Road to Stratford Road, one southern from the sports and social club off London Road along the river corridor and across London Road to the cemetery and allotments off Shoulder Way Lane. These arcs would link and better access green spaces and reinforce the landscape with major structural planting, the aim being improved amenity for the community and conserving the valued setting of the town.

The topic group was very enthusiastic about these potential policies and proposals, and has embarked on additional field research, applying the lessons from the Landscape Matters work and also a Historic Environment Workshop for the Neighbourhood Plan team held in July 2015 and facilitated by Warwickshire County Council.

7.5 It is also worth noting that the recommendation in Section 6.5 above has been acted upon and the topic group will in September 2015 be conducting further survey and interpretation work to better record and understand the significance of the town’s heritage assets, such that the three prospective projects – Section 6.4 refers – can be scoped more thoroughly by way of informed dialogue with the main stakeholders.

7.6 With the noted actions it is clear the topic group has addressed the concerns listed in Section 6 and on that basis this ‘audit and issues report’ can be signed-off. There remains work to do to produce justified policies and proposals, but the basis is there and on the record as such.

Written by Stephen for Phil Sykes of the Environment Topic Group

June 2015 Updated September 2015

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