BASE HEADER

No

ID sylw: 108159

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We object to Draft Policy Direction 1.
As drafted, the policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the NPPF, and associated update to the Standard Method, were in draft form only and subject to change. However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to the Standard Method requirement and make no reference to the HEDNA.
As such, the SWLP should be taken forward having regard to Table 3 (Housing calculation 2024 NPPF Standard Method), which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62, whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF paragraph 69.
In terms of the Strategic Growth Location (SGL) options, the Emerging Spatial Growth Strategy Paper November 2024 proposes 24 locations identified for potential strategic growth. At this stage, to be able to consider reasonable alternatives, the identified strategic growth locations could accommodate significantly more land for employment and housing need, and it is not anticipated that all areas will be allocations within the SWLP. It is expected that the SWLP evidence base will continue to grow while the plan is being drawn up, and there are a number of key pieces of evidence expected after the Preferred Options consultation which will further inform the eventual selection of sites for allocation -this will include the Sustainability Appraisal, Estimation of Emissions, Green Belt review and Infrastructure Delivery Plan.
A Sustainability appraisal for this Reg 18 consultation has been undertaken, and the SGL’s have been assessed for likely impacts on the 13 SA objectives (all currently desktop) as follows:
SA Objective 1: Climate Change- no single SGL can be identified as the best or worst option for climate change due to limitations of current information.
SA Objective 2: Flood Risk – the majority of SGLS are predominantly located on greenfield land and likely to lead to loss in vegetation coverage and permeable soils which contribute to capturing rainwater and slow run-off rates. SG18 is not currently identified within the best


performing option (Coventry Airport and East of Lillington) or the worst performing option, West of Warwick.
SA Objective 3: Biodiversity, Flora, Fauna and Geodiversity – all SGLs have potential to result in adverse impacts on biodiversity. 5 SGL’s including West of Stratford-upon-Avon (SG18) lie withinclose proximity to a SSSI (within the IRZ) which indicates that consultation with Natural England will be required prior to development. SG18 is also located within close proximity to a LNR which is likely to adversely impact upon them. All SGLs coincide with LWs and have the potential to result in the direct loss and/or degradation of these habitats. The worst performing option is South of Coventry SGL.
SA Objective 4: Landscape – the majority of SGLs have potential for adverse impacts on landscape. Coventry Airport is considered to be the best performing option and West of Studley is expected to be the worst performing.
SA Objective 5: Cultural Heritage – All SGLs will have potential to result in adverse effects on heritage features and settings of conservation areas. The best performing is East of Gaydon, and the worst Southeast of Whitnash.
SA Objective 6: Pollution - All SGLs are identified to result in adverse effects to some extent with the exception of East of Lillington. The East of Stratford-upon-Avon (SG18) and West of Stratford-upon-Avon slightly coincide with the Stratford-upon-Avon AQMA, whilst the Coventry Airport and South of Coventry SGL’s lie adjacent to the Coventry AQMA. 20 SGLS are located within 200m of a main road and the West of Stratford-upon-Avon, and 4 other SGLs are located within 200m of a railway line within may impact end users in terms of noise and air pollution. The best performing option is identified as East of Lillington, and the worst is West of Stratford. This SGL lies in proximity to the AQMA, and A roads leading to the town centre and could hence worsen poor air quality within the AQMA.
SA Objective 7: Natural Resources – all 24 SGLs are expected to result in adverse impacts. 23 of SGLs comprise of land of Grade 3 and above. 23 also coincide with Mineral Safeguarding Areas. Coventry Airport is identified as the best performing option, with Bidford-on-Avon identified as the worst performing option.
SA Objective 8: Waste – the large scale residential-led development across the Plan area is likely to result in an increase in waste. No single SGL can be identified as best or worst option at this time.
SA Objective 9:Housing – all 21 residential-led and mixed-use SGLS are likely to result in a significant net gain in housing. There is currently limited information available to form ranking against this objective.
SA Objective 10:Human Health – all 24 SGLs are likely to have adverse impacts on access to one or more health receptors. 17 SGLS are located beyond 5km to a hospital with A&E services. 20 SGLs are located beyond the 800m sustainable distance to an existing GP surgery. 18 are located outside of a 1.5km distance to leisure facilities. The West of Studley SGL is identified as the best performing option with East of Gaydon the worst performing option.
SA Objective 11: Accessibility – Mixed effects have been identified against this option. East of Lillington has been identified as the best performing option for accessibility and the North of Wellesbourne and Alcester SGLS being joint worst options.
SA Objective 12: Education – all 21 SGLs with residential capacity are identified to result in negative impacts on sustainable access to education based on existing school provision. The best performing option is West of Studley and North of Leamington, the worst is East of Gaydon.
SA Objective 13: Economy: - positive effects are expected on the economy from the majority of SGLs. All except North of Henley-in Arden are located within 5km of an existing key employment location.