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ID sylw: 106614

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

As we set out in further detail at Section 3 of these Representations, we do not agree that all of the identified Strategic Growth Locations are supported by sufficient
infrastructure to enable their delivery. It is clear that the SWLP recognises at a high level that such provision is integral to the delivery of significant housing and employment sites.
It is noted as part of the consultation that an Infrastructure Delivery Plan (IDP) is being prepared alongside the Local Plan to help identify future infrastructure requirements,
costs and when and how infrastructure will be delivered. Part 1 of the IDP forms part of the technical evidence base for the PO Consultation draft of the SWLP.
Whilst we appreciate that further work is to be undertaken to determine details of the infrastructure needs for the preferred option, we are concerned at the lack of information contained within the Part 1 IDP. In our view, evidence regarding infrastructure requirements for the strategic growth areas or potential new settlements is a fundamental requirement for their promotion. Linked to this, we consider it a significant failing of the emerging Plan to prioritise or highlight areas which suffer from a lack of infrastructure, or conversely those areas which benefit from existing infrastructure.

Whilst we broadly support the identification of Priority Areas, we do not agree with the specific delineation of Priority Area boundaries insofar as they relate to Henley-in-Arden. Specifically, the draft SWLP does not evidence or justify the identification of land to the north of Henley-in-Arden, but outside of the existing urban area, as falling within Priority Area 1, while land to the south falls within Priority Area 2 / 3. It is apparent that the boundary of Priority Area 1 has been tightly drawn to reflect existing built development in the southern part of Henley-in-Arden but extends beyond existing built development to the north. The justification for this is not clear and we would argue that this amounts to an artificial manipulation of the boundary of the Priority Area, with the effect of rendering a greater proportion of parcels of land to the north of Henley-in-Arden which have been promoted for development and which are identified as falling with ‘SG23’ (as discussed in more detail later) as falling within the area.
We fully support the recognition set out above that the existing urban areas across South Warwickshire do not offer sufficient capacity to meet development needs. This reflects Government rhetoric that whilst the first port of call for development should be brownfield land, it is clear that the delivery of brownfield land for residential development will not be enough to meet our housing needs. In our view, it is critical that the SWLP makes clear at the outset that development will need to extend beyond existing urban limits.
This is further evidenced by the 2022 Urban Capacity Study, which sets out at Section 4.6 that greenfield land must be released to meet South Warwickshire’s housing needs and that “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development” (our emphasis). In short, it is in our view essential that the SWLP is clear from the outset that the only way to meet development needs will be to build on current greenfield sites including the Green Belt, in sustainable locations.
Figure 6 goes on to identify the Emerging Spatial Growth Strategy Options, comprising Strategic Growth Locations (24 no. in total) and Potential New Settlements (12 no. in total). Land to the north of Henley-in-Arden is identified as comprising Strategic Growth Location SG23. As set out in further detail later within these Representations(Section 3), we do not support the identification of land to the north of Henley-in-Arden as a Strategic Growth Location, particularly when the benefits and disbenefits of its allocation are weighed against those of land to the south of Henley-in-Arden. We also have concerns in respect of the identification of Potential New Settlements A1 and A2 to the north west of Henley-in-Arden.