BASE HEADER

No

ID sylw: 108108

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

We do not agree that all of the identified Strategic Growth Locations or Potential New Settlements 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. It is noted that the IDP will also help to coordinate planning and investment in new infrastructure by the two districts and other infrastructure providers and key stakeholders. 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. The absence thereof essentially renders the promotion of certain sites or locations for development over others unsound.
In our view, this amounts to a failure to accord with paragraph 16 of the NPPF, which sets out at part b) that plans should be prepared positively, in a way that is aspirational but deliverable.
Linked to this, we consider it to be a significant failing of the emerging Plan that it appears to prioritise or highlight areas which suffer from a lack of infrastructure, over those which could be seen to offer better opportunities in terms of existing infrastructure.
There is insufficient urban brownfield land to accommodate South Warwickshire’s housing and employment land needs. The majority of the SWLP’s strategic growth needs will be met within priority areas 1 – 3”. We fully support this assessment and consider that robust priorities and strategies need to be developed to respond to this. It is clear that Priority Areas 2 and 3 will need to a significant amount of ‘heavy lifting’ in housing delivery, particularly in light of increased housing as a result of the new standard method (see below).
Critically, 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.

4.1 – Spatial Growth Strategy
• Spatial Growth Strategy

Clearly, whilst the emphasis on urban land chimes with national priorities for the reuse of brownfield land and should be supported, it is imperative that the SWLP is clear about the need to release greenfield land to meet development needs.
The Respondent particularly supports emphasis given to sustainable travel and to the provision of development in proximity to existing rail stations. Given the emphasis on mitigating the impacts of climate change (as per the first overarching principle set out within Section 3.1) and reducing the need to travel by private car in order to reduce carbon emissions, it is the Respondent’s view that in existing settlements in close proximity to existing railway stations – such as Hampton Magna, which lies immediately to the south of Warwick Parkway station – should be prioritised as locations for growth. More specifically, the Respondent’s Site off Old Budbrooke Road is an ideal candidate for future housing development in this regard given is location within walking distance of Warwick Parkway station.
The allocation of land off Old Budbrooke Road would, in our view, respond to national planning priorities as per paragraph 110 of the NPPF, which sets out that “The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”.
• Housing Need
Section 4.1 goes on to set out that “The Spatial Growth Strategy will accommodate South Warwickshire’s housing and employment needs for the period to 2050. T
The December 2024 iteration of the National Planning Policy Framework is clear at Paragraph 234 of Annex 1: Implementation that “for the purpose of preparing local plans, the policies in this version of the Framework will apply from 12 March 2025”. There are some exceptions, none of which apply to the SWLP. On this basis, it is fundamental that the SWLP sets out housing need in line with the new Standard Method.
As per the new Standard Method, housing need has increased in Stratford-on-Avon from 553 units per annum to 1,126 units per annum (+103%) and in Warwick DC from 653 units per annum to 1,062 units per annum (+62.6%). This significant increase in housing need further heightens the importance of the Council looking to suitable and sustainable greenfield sites to deliver housing, given the acceptance that urban land could not meet even the lower demand, which was assessed in 2022, as per the Urban Capacity Study.