BASE HEADER

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ID sylw: 108020

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

The Gaydon/Junction 12 M40 area is acknowledged as being a location of strategic importance in both SWLP and the Economic Strategy. The SWLP identifies it as a ‘Strategic Growth Option’ and the South Warwickshire Economic Strategy refers to it as being within a ‘Economic Core Opportunity Area’. Indeed, the South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy”.
SG13 is considered to the most appropriate location for economic growth in the short, medium and long term by concentrating commercial investment in an area that requires minimal infrastructure investment. Both the 100ha JLR site, which is expected to be released to the wider market, and CEG’s site east of Gaydon (30ha) (also part of SG13) have the capacity to meet the Council’s strategic employment need in full. However, CEG also request that the triangular parcel of land south of the B4100 is also included SG13.
The accompanying zoning masterplan demonstrates how sites within SG13 can come forward for a mix of employment uses that can satisfy the need identified within the Alignment Paper. For reasons set out below, SG13 is considered logical by virtue of its sustainability and immediate access to the Strategic Road Network but also when compared with other locations, particularly along the M40/ M42 corridor it is the least constrained area.
Beyond Banbury Road (B4100) is the principal design and engineering centre for JLR and AML. Directly to the north-east of the Site is 100ha of land specifically allocated for the expansion JLR in the Stratford-on-Avon Core Strategy under Policy CS.22 and policy GLH (Gaydon/Lighthorne Heath now known as “Upper Lighthorne Heath”).However, it is acknowledged that the 100ha JLR site will likely be released to the wider market as part of the SWLP.
Furthermore, the site is accessible to significant emerging advanced engineering research and development investment at the University of Warwick’s Wellesbourne Innovation Campus. The planning application at the Campus (which is consistent with the adopted Wellesbourne Innovation Campus Masterplan SPD) will provide for up to 4 million sq.ft of research and development floorspace through the collaboration of leading industry investment and academic research. The site currently accommodates Lotus, Rimac and the West Midlands Manufacturing Group and is becoming a recognised regional and national automotive battery research and testing facility.
To the north-east, beyond the JLR/AML site, is Lighthorne Heath, a historically small village built to originally support RAF Gaydon which now comprises a mixture of private and social housing together with a 3000 dwelling new settlement.
731 homes are now occupied within the new settlement (December 2024) and therefore with a community quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
The Core Strategy recognises the eventual sustainability and significance of Lighthorne Heath through the supporting text to policy CS.15, which confirms that;
“In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.”
The settlement hierarchy for Stratford-on-Avon District clearly recognises the transformative nature of this new settlement to the local area. It is therefore considered that given the existing and anticipated future rate of completions and the services and facilities now being delivered on the at the allocation, Lighthorne Heath should be considered as a Main Rural Centre within the settlement hierarchy, alongside Alcester, Bidford-on-Avon, Henley-in-Arden, Kineton, Shipston-on-Stour, Southam, Studley and Wellesbourne.
AML’s headquarters within Gaydon provide the main production facility together with research and development. Further to Aston Martin Lagonda’s presence, JLR operate their advanced design and engineering centre at Gaydon. The design and research centre and extensive test track facilities have been established over the last 30 years
The Core Strategy recognises the importance of the site, specifically stating that:
“The Gaydon Site is a key economic asset within the District and the wider region, employing several thousand people, together with indirect employment in relation to logistics and suppliers. The site is located adjacent to an established highway network, including the M40 which is an important transport gateway into Coventry and Warwickshire.”
The importance of this location is further reflected in both the emerging SWLP and the December 2023 and South Warwickshire Economic Strategy. The SWLP Preferred Options document identifies the Gaydon Area/M40 Junction 12 as a Major Investment Site which sits within a wider ‘Economic Core Opportunity Area’. This area includes Gaydon and the M40 corridor and comprises the main towns of Stratford-upon-Avon, Warwick, Whitnash, Leamington Spa and Kenilworth, the A46 corridor, the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre and Stoneleigh Park.
Draft Policy Direction 13 of the SWLP also confirms the area will be the focus for new employment development in the South Warwickshire Area, building on existing employment hubs, harness the potential offered by co-locating businesses and research facilities and support the strategy for attracting significant inward investment to the area. The South Warwickshire Economic Strategy identifies the same area as ‘Core Investment Opportunity Area’. The focus for the area is attracting inward investment to drive the South Warwickshire economy as well as encouraging inward investment in the most accessible parts of South Warwickshire. Indeed, the emerging South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy, whilst acknowledging national and local planning policies (e.g. Green Belt)”.
The SWLP preferred options also identifies the M40/A46 corridor as a Road Opportunity Area based on the West Midlands Strategic Employment Sites Study (WMSESS) which recommends the identification of 1-2 mixed/B8 sites (50-100ha each) and 1 B2 site (25ha) to deliver 125 ha of strategic employment i.e. sites of over 25 ha and largely dedicated to units of over 9,300sqm. This clearly recognises the potential of this corridor to play an enhanced role in delivering strategic economic growth in South Warwickshire.
SG13 and in particular CEG’s land interests are therefore strategically positioned to drive significant inward investment within this ‘Core Economic Area’, supporting the automotive cluster whilst also increasing the provision of jobs, complimenting the role of Upper Lighthorne in the settlement hierarchy.
The NPPF sets out at paragraph 145 that ‘…Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced through the preparation or updating of plans.’
For plan-makers to reach a point where exceptional circumstances can be demonstrated, paragraph 146 confirms that this can include ‘…instances where an authority cannot meet its identified need for homes, commercial or other development through other means’.
And at paragraph 147 ‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.’
This assessment of whether all other reasonable options have been examined will take account, according to paragraph 147, of whether the strategy:
“a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
The NPPF clearly sets out a sequential approach to allocating land for development within the Green Belt – essentially dictating that utilising Green Belt land should be a ‘last resort’, where there are no other options to accommodate the required growth.
As detailed within CEG’s responses to Chapter 3, the site is considered to be inherently sustainable location for commercial development. However, it is also considered to be sequentially preferable to other locations within the area, specifically Green Belt locations that have been identified for economic growth. Therefore, SG13 should be identified as the economic hub for the SWLP by utilising the existing economic activity and the potential for supply chain synergies and the attractiveness of the location for businesses based upon the automotive sector.
Land within CEG’s control has the capacity to deliver circa 125 ha of employment in a relatively unconstrained location and with limited highways improvements which would only be required after a significant amount of development has already been delivered therefore allowing delivery of economic growth at the earliest opportunity. This is currently being assessed but it is anticipated that some 2 million sqft (60ha) of land could come forward before any further major highway infrastructure is required.
An assessment of alternative junction locations on the M40 has been undertaken. These locations have been chosen as a result of the SWLP, clearly recognising the potential of the M40 corridor to provide further commercial space within the sub-region and the area being identified in the WMSESS as Opportunity Area 8, with a specific need in the Alignment Paper of 75- 125ha.
M40 Junction 15 and 14
The junctions and land surrounding them are located near to the existing labour force in Warwick and there are existing employment units close to Junction 15, off Edgehill Drive. Junction 14 does not currently allow the egress of vehicles travelling west along the M40, nor the entry of vehicles wishing to travel east. Substantial M40 junction improvements would be required to meet occupier requirements and to accommodate the vehicle movements associated with large scale employment development. The area to the west of Junction 15 is within the Green Belt, the boundary of which follows the route of the A46, broadly north to south. Both Sherborne and Barford Conservation Areas are located close to both junctions to the south/south east, whilst 3 Scheduled Monuments also lie within this area. Warwick Castle Registered Park and Garden forms an important heritage constraint to the North East of Junction 14, the grounds of which are also within the boundary of the Warwick Conservation Area. Areas of land to the west and south of Junction 14 and east of Junction 15 suffer from flood risk, with a significant
area of land falling within either Flood Zone 2 or 3 associated with the River Avon. As per paragraph 147 of the NPPF, exceptional circumstances would need to be demonstrated to release land from the Green Belt and that it is sequentially preferable to alternative locations. The identified constraints, particularly Green Belt and Flood Zone 3, are considered to have a significant impact on the suitability of this location for large scale commercial development and is therefore not sequentially preferable to Junction 12.
M40 Junction 13
The junction and surrounding land are located relatively close to the village of Bishop’s Tachbrook, with Leamington located to the North. In terms of access to workforce, the village of Bishop’s Tachbrook when compared with Lighthorne Heath, is considered to be less sustainable. As previously set out, 731 homes are now occupied within Lighthorne Heath (December 2024) and therefore a community is quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
Junction 13 does not currently allow for vehicles travelling east on the M40 to exit the motorway and not does it allow users to join the motorway in order to travel west. Substantial M40 junction improvements would be required in order to accommodate the vehicle movements associated with large scale employment development. A large area of ancient woodland and Local Wildlife Site is located to the south, also containing a Scheduled Monument. A further Scheduled Monument is also located to the south east of the junction. To the north lies Bishops Tachbrook Conservation Area. The configuration of the motorway junction is considered to be a significant constraint affecting the suitability of this location for large scale commercial development.
The above assessment confirms that junctions within the opportunity area are constrained, particularly by Green Belt. Furthermore, those junctions that are not within the Green Belt are also not considered, in their present form, to be suitable for employment of the scale proposed. For example, Junction 13 does not allow two-way access onto the M40 and would therefore need substantial upgrades. The SWLP recognises that significant upgrades would be required to facilitate the strategic employment growth options identified at Junction 13 (Land at Red House Farm) and 15 (Wedgnock Park Farm).
Junction 12 is unconstrained compared to other junctions within the Opportunity 8 area and importantly can come forward with minimal infrastructure investment. It would augment the existing automotive economic hub providing a major sub-regional / regional focus for economic growth that could be delivered in the short, medium and long term within the Local Plan period.
This analysis therefore further supports that Junction 12 is the most appropriate location for employment development within the M40 corridor where there is existing infrastructure capacity and where delivery is not reliant on significant and complicated upgrades.
In view of the above, SG13 should be included within the draft plan as part of a focused strategy of economic growth building on an already established automotive hub.
Interim Sustainability Appraisal
The site is assessed in the Interim Sustainability Appraisal of the South Warwickshire Local Plan (the “interim SA”) alongside 23 other potential Strategic Growth Locations (“SGL”) considered as Reasonable Alternatives. According to paragraph 5.1.1 of the Interim SA the SGLs are expected to meet a proportion of the identified housing and employment needs for the SWLP period 2025-2050.
SG13 (Gaydon Lighthorne Heath) is considered as a mixed use site across 836 hectares. CEG controls around 130 ha of SG13 with no legal restrictions which could affect development. It is proposed that CEG’s land interests will come forward as primarily employment land.
Of the 24 SGLs considered within the Interim SA, three (including SG13) have been identified as potential locations for employment growth, the others being SG07 and SG09.
The Interim SA confirms at paragraph 2.7.3 that Green Belt is not considered as a ‘policy off’ position is adopted. CEG consider that in further comparing the SGLs following the work of the Interim SA, reference must be made back to the NPPF which sets out a sequential approach to the use of land for development. As the SWLP accepts that there is insufficient brownfield land available to meet economic development needs it is important that before assessing and allocating Green Belt land, sustainably located non-Green Belt options should be considered first in line with the sequence as set out at paragraphs 145 to 147. SG07 is its entirety located within the Green Belt and is therefore sequentially less preferable to accommodate development than SG13 which lies entirely outside of the Green Belt.
In considering the scoring of SG13 for Economy, it scores just a single positive impact. However, other options such as SG08 score a major positive impact on employment provision. The Interim SA explains that spatial growth options expected to provide more than 1,000sqm of employment floorspace scored a major positive impact. Given SG13 contains the JLR allocation of a 100ha which has been identified within the SWLP as an employment site and Land East of Gaydon which is approximately 30ha and capable of providing up to 80,000sqm, it is considered that it should be rescored to having a major positive impact. The single positive impact does not reflect the Interim SA’s own methodology.
Furthermore, where negative scores are awarded in the Interim SA due to environmental or physical constraints present on the site, CEG confirm that sufficient mitigation can be secured through development, for example in relation to local wildlife sites, biodiversity, ancient woodland, landscape and heritage. Development can be designed with the appropriate buffers in place.