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ID sylw: 108311

Derbyniwyd: 07/03/2025

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

Asiant : Nexus Planning

CEG and Mixed Farms support the policy direction in so far as it relates to the plan period of 25 years. The
approach to planning for a longer period than the minimum required by the NPPF will enable a more cohesive
growth strategy to be prepared ensuring that large scale development has a better chance of delivering the
housing and employment growth required for South Warwickshire as set out within paragraph 77 of the NPPF
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…”
Draft Policy Direction 1 looks to the Coventry & Warwickshire Housing and Economic Development Needs
Assessment 2022 (the ‘HEDNA’) to set its ‘minimum’ housing requirement whilst considering flexibility for up to
2,188 dwellings per annum in line with the 2024 Standard Method. Paragraph 62 of the NPPF states:
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing
need assessment, conducted using the standard method in national planning practice guidance. In addition to the
local housing need figure, any needs which cannot be met within neighbouring areas should also be taken into
account in establishing the amount of housing to be planned for.”
Therefore, CEG and Mixed Farms are unequivocal that the SWLP should plan to meet at least the Standard
Method figure of 2,188 dwellings per annum in order avoid any issues of soundness regarding the minimum
figure selected. In addition, and of more relevance to ‘Draft Policy Direction 4 – Accommodating Growth Needs
Arising from Outside South Warwickshire’, the housing requirement must also take into consideration any unmet
needs which cannot be met within neighbouring areas, such as Birmingham and other areas within the Greater
Birmingham and Black Country Housing Market Area (GBBCHMA) and the Coventry and Warwickshire HMA.
Whilst it is acknowledged that at this time it is difficult to identify the exact levels of unmet need from
neighbouring areas, it is important that Draft Policy Direction 1 accounts for the potential unmet needs which
may arise in future. For example, Birmingham’s unmet need of circa 37,900 dwellings as identified by the
Birmingham Development Plan (BDP, adopted 2017) is unlikely to have reduced as a result of the 2024 Standard
Method figure for Birmingham which now stands at 4,448 dwellings per annum versus the BDP housing
requirement of 4,450 dwellings per annum.
The Greater Birmingham HMA Strategic Growth Study (February 2018) identified potential locations which could
be suitable to meet the unmet need from the GBBCHMA – with land to ‘South of Stratford-upon-Avon town’
considered as one of 10 non-Green Belt options. Although the Study concluded that four other urban extension
options should be taken forward for detailed consideration, one of these (South of Dudley) is located within the
Green Belt and therefore ‘South of Stratford-upon-Avon town’ is sequentially preferable in terms of the approach
encouraged by national planning policy. Furthermore, of the new settlement options considered by the study, all
four new settlement locations taken forward are located within the Green Belt. Whilst the Study considered land
to the south of Stratford-upon-Avon, CEG and Mixed Farms consider that land to the east has similar
characteristics and can also deliver significant infrastructure to capitalise on the economic growth proposed at
Wellesbourne.
Through the identification of the site as a Reserve Site in the Revised Preferred Options Consultation of the
Stratford-upon-Avon Site Allocations Plan – ref: STR.D (SAP)); it is accepted that land in the south east of
Stratford-upon-Avon is suitable to meet unmet need arising from the GBBCHMA; and this approach should be
carried forward into the SWLP.
Draft Policy Direction 1 sets out that against the 2024 Standard Method figure, the SWLP must still find land for
28,257 dwellings in addition to existing commitments of 17,068 dwellings and a windfall allowance of 9,375
dwellings (375 dwellings per annum, 274 from Stratford-on-Avon and 101 from Warwick). CEG and Mixed Farms
encourage the SWLP to ensure that the figure to be derived from existing commitments is robust to ensure that
the SWLP allocates sufficient land to deliver the necessary housing to accommodate growth.
Stratford-upon-Avon and specifically SG19 are excellently placed to accommodate housing need arising from
both within and outside of Stratford-on-Avon district as set out within these representations.