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ID sylw: 108309

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms support the Plan’s Vision and objectives, which determine how development will be
delivered. The CEG and Mixed Farms proposals for East of Stratford-upon-Avon are considered against each of
these principles to demonstrate how the site’s development can help to achieve the vision.
A climate resilient and Net Zero Carbon South Warwickshire – The proposed development at the site will
contribute to a low carbon and climate resilient development from construction to occupation through
sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems
within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking
advantage of two key attributes, size (strategic growth) and location (on the edge of one of the largest and most
sustainable settlements in South Warwickshire), the site off Banbury Road will include numerous measures and
strategies to encourage local living and support the initiative of 15-minute neighbourhoods.
A Transport Note prepared by Vectos and appended to these representations at Appendix 1 outlines how the site
can contribute to climate resilience through:
 Creation of critical mass to allow good levels of internal living and enhancing existing communities;
 Making use of the excellent existing facilities for travel choice into Stratford-upon-Avon by active travel
modes;
 Placing cycling and walking at the highest priority, followed by public transport;
 Placing development in an area close to existing and emerging employment options accessible by walking,
cycling and public transport;
 Proposing improvements to public transport infrastructure;
 Providing future proofed development which is adaptable to meet the demands of electric and/or
hydrogen vehicles;
 Promoting local living and 15-minute neighbourhoods where people can meet their everyday needs
within a short walk or cycle;
 Creation of mobility hubs with facilities to encourage use for charging of electric vehicles, cycle parking,
remote working, carpooling and leisure.
The site can improve existing infrastructure and generally promote a culture of change towards active travel
which in turn aids the climate resilience of South Warwickshire.
A well-designed and beautiful South Warwickshire – Development at the site will provide for a mix of housing
types and tenures to encourage diverse and intergenerational communities; it will deliver both physical and social
infrastructure to benefit existing and future residents and support the growth of the town as a whole; create
homes with gardens that combine the best of town and country to create healthy communities; and, where
possible, retain and enhance existing landscape features including hedgerows and tree belts.
A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable
garden community, providing both a range of housing to meet identified needs, and community facilities, focused
around a mixed use centre with primary school, convenience and community facilities, mobility hub and potential
for live/work community hubs supporting both the development and surrounding villages. This will be set within a
substantial green infrastructure network which will allow enjoyment of the opportunities created and lead to
increased physical and mental health.
The sustainable travel initiatives set out within the Transport Note will help to foster a sense of community,
activating streets through cycling and walking creating a safe environment of active residents. Through the
proposals to create a substantial green infrastructure network, the community will be attractive for residents and
visitors to pursue active travel opportunities in a pleasant and safe environment.
A well-connected South Warwickshire - The site will take advantage of the excellent existing facilities for travel
choice into Stratford-upon-Avon by active travel and public transport modes and enhance these routes where
needed through careful design and investment in sustainable infrastructure which will promote longevity. This
means that the site can place walking and cycling at the highest priority, followed by travel by public transport,
and develop a community where there is little reliance on the private car and increased reliance on active and
public transport modes.
A biodiverse and environmentally resilient South Warwickshire – The conceptual framework for the site,
attached at Appendix 2 shows the retention of existing landscape features including hedgerows and tree belts
and, in addition, shows a considerable biodiversity parkland, public parkland, and a network of swales. The site
can be developed whilst delivering a 10% net gain of biodiversity in accordance with the requirements of the
Environment Act.
The 12 Strategic Objectives
In addition, the Plan includes 12 strategic objectives which reflect the area’s social, environmental and economic
issues. Where relevant, CEG and Mixed Farms provide comment below on how development at South East
Stratford-upon-Avon can help to meet the Plan’s objectives:
• SO1: Providing sustainable levels of growth in the area; and
• SO6: Contributing towards Net Zero Carbon targets.
The site is located on the edge of one of the principal and most sustainable settlements in South Warwickshire,
and one of the Urban Areas of the Plan area as shown on Figure 5 of the SWLP. It benefits from easy access to a
range of services and facilities. Critically, the entirety of the site lies outside of the Green Belt, is not subject to any
landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets.
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, or that non-Green Belt land including land classified as Grey Belt, is not
abundant enough to meet growth requirements – as set by the Standard Method – in full. CEG consider the
sequential approach to be particularly relevant in relation to Stratford-upon-Avon, given the availability of
sustainably located land (SG19) outside of the Green Belt.
The site is located adjacent to and north of the A422 Banbury Road and would form a natural extension to the
existing residential area to the east of Stratford-upon-Avon. It benefits from having direct frontage along the A422
thus enabling a new junction to be accommodated to access the development which links into existing footways.
A number of local facilities including Bridgetown Primary School, recreational pitches, convenience food stores,
pharmacies are in the immediate vicinity of the site. The town centre of Stratford-upon-Avon offering a range of
high street retailers, restaurants and leisure facilities is within 2km of the site. Local buses travel along A422
Banbury Road as well as A4390 Trinity Way. Local bus stops are within an acceptable walking distance from the
site along Banbury Road making public transport a genuine option for travel.
Further, given the scale of potential growth a viable public transport strategy can be delivered as set out by the
Transport Note, which outlines the potential for Demand Responsive Transport (DRT), a flexible service which
allows residents to book a journey using an on-demand bus service, diversion of an existing bus service (15) into
the site; or providing a new bus service to serve the site and local area to further enhance the site’s sustainability
and provide wider public benefits.
The site benefits from excellent pedestrian infrastructure with continuous footways on both sides of A422
Banbury Road into Stratford-upon-Avon. Similarly, both A422 Banbury Road and the A4390 Trinity Way provide
cycle infrastructure in the form of on-carriageway cycle lanes (A422) and a shared traffic-free cycleway/footway
on the norther side of the A4390. The shared route extends from the roundabout junction with A422 Banbury
Road to the immediate west of the site to the roundabout of the A4300/Severn Meadows Rd roundabout further
west. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages.
The site’s location outside the Green Belt, adjacent to a principal urban area and with a lack of constraints ensures
that it lies in a geographical location where the SWLP objective to promote sustainable growth can be met.
• SO2: Delivering homes that meet the needs of all our communities; and
• SO10: Improving the health, safety and quality of life of our communities.
Development at SG19 – East of Stratford-upon-Avon would deliver approximately 1,200 new market and
affordable homes in a variety of types and tenures to assist the area in meeting its housing needs.
• SO3: Providing infrastructure in the right place at the right time; and
• SO11: Connecting people to places.
Development would help facilitate the delivery and provide financial contributions towards the Eastern Relief
Road (ERR) around Stratford-upon-Avon, as required. This would deliver significant social and economic benefits
locally and at the sub-regional level.
The Infrastructure Delivery Plan (IDP) published within the evidence base of the SWLP draws upon The Stratfordupon-
Avon Transport Strategy confirming at page 34 that ‘Stratford-upon-Avon frequently suffers from traffic
congestion, particularly during the morning and evening weekday peaks, as well as congestion associated with
tourist traffic, predominantly on summer weekends, bank holidays and during major events.’
Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider
the substantial benefits that can be delivered through large scale growth to the south east of Stratford-upon-
Avon, in particular supporting the delivery of the ERR, a strategic piece of infrastructure which would connect
Banbury Road to Wellesbourne Road, noting that paragraph 11a of the NPPF states that plans should positively
seek opportunities to meet the development needs of the area. As set out within the Transport Note, this
proposed ‘Movement Corridor’ will simplify journeys of all modes towards Wellesbourne, where major economic
growth is planned without adding further pressure to routes in Stratford-upon-Avon town centre.
At Wellesbourne, only approximately 5km from the site, the University of Warwick propose an ‘innovation
campus’, the outline planning application was submitted in December 2024 supported by an adopted SPD for the
site If approved, this development will generate:
 4,113 full time operational jobs
 1,748 part time operational jobs
 314 temporary jobs during the construction phase
 £1.34 billion of operational gross value added
In addition, at Wellesbourne Mountford Airfield, Gladman Developments Ltd have submitted an application for
aviation led development which would deliver general industrial, storage and distribution, commercial, research
and development and light industrial floorspace in addition to accommodation for airfield tenants. Overall,
165,000 sqm of employment floorspace is proposed and this would generate:
 Between 1,228 and 1,625 operational jobs
 217 temporary jobs during the construction phase
 Between £68.8 million and £91.1 million per year to the local economy
The opportunity to improve connections between the largest settlement in Stratford-on-Avon and the significant
economic investment and associated benefits at Wellesbourne can only be capitalised on through the allocation
of land East of Stratford-upon-Avon for development and subsequent delivery of the ‘Movement Corridor’
between Banbury Road and Wellesbourne Road, alongside the delivery of homes to meet the demand for
sustainable co-located employment and housing.
Development at SG19 – East of Stratford-upon-Avon could, if necessary, contribute towards expansion and
improvement to schools, healthcare, sports and community facilities and waste management. Improvements to
local utility facilities and infrastructure would also be required to facilitate development, benefitting both existing
and new residents.
 SO5: Making effective use of land and natural resources
The NPPF is clear that the priority is to make effective use of land in meeting the need for homes and other uses
in a way that prioritises previously developed land. However, the SWLP is clear at Section 4.1 (Spatial Growth
Strategy) that there is insufficient brownfield land available to meet the South Warwickshire’s growth
requirements and so it is important that the SWLP looks to accommodate growth on sustainable sites which are
capable of delivering housing growth in effective ways, minimising impacts on natural resources. One way of
achieving this is to allocate land in sustainable locations adjacent to well-located settlements offering an array of
services to future residents, such as Stratford-upon-Avon.
As set out earlier in the response to this question, the NPPF clearly sets out a sequential approach for plan-making
when selecting land for allocation. As the SWLP accepts, there is insufficient brownfield land available to meet
development needs (and CEG and Mixed Farms acknowledge it is likely that some Green Belt land will need to be
considered for allocation) it is important that before assessing and allocating Green Belt land, sustainably located
non-Green Belt options should be considered first.
Therefore, the site’s location outside the Green Belt, adjacent to a principal urban area and with a lack of
constraints ensures that it lies in a geographical location where the SWLP objective to make effective use of land
can be met.
 SO7: Creating attractive places
Development at East of Stratford-upon-Avon would be delivered in accordance with national and local planning
policies and guidance which seek to create attractive places. CEG and Mixed Farms are confident that a
sustainable and well-designed extension to Stratford-upon-Avon could be delivered through allocating a
comprehensive parcel of land to the South East of Stratford-upon-Avon, which would allow for placemaking
principles such as walkable neighbourhoods, designed character areas and green infrastructure to be fully
explored, as per NPPF paragraph 77 which states:
“The supply of large numbers of new homes can often be best achieved through planning for larger scale
development, such as new settlements or significant extensions to existing villages and towns, provided they are
well located and designed…”
CEG and Mixed Farms control the largest element of SG19 and this is beneficial for both placemaking and ease of
delivery, with no complex delivery agreements required to ensure that at least 1,200 dwellings can be delivered
on the site within a single ownership.
 SO8: Protecting and enhancing our heritage and cultural assets; and SO12: Protecting and enhancing our
environmental assets.
The SWLP ensures that appropriate environmental considerations have been made when considering and
assessing the options to accommodate future development. East of Stratford-upon-Avon, if allocated, can be
delivered alongside mitigation to ensure that heritage and cultural assets are sufficiently protected in line with
SO8. This is explored further in the response regarding the Interim SA.
CEG and Mixed Farms’ element of SG19 can be delivered without causing impact on environmental assets – there
are no ecologically important sites within or adjacent to the site, it lies entirely within Flood Zone 1; although
there is a small area of the site to the south which is susceptible to surface water flooding. This can be
satisfactorily mitigated through design, layout and specific drainage design. Development can be delivered to
secure the mandatory levels of biodiversity net gain (BNG), and mitigation for any protected species, should any
be discovered, can be secured via planning application in the future.
The detailed masterplanning of the layout, design and landscaping of a scheme on land controlled by CEG and
Mixed Farms in isolation ensure that any remaining impacts are suitably mitigated.