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ID sylw: 108658

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The Growth Strategy overly relies on the creation of new settlements and thus greenfield and Green Belt land.
• 12 potential settlement locations are identified of the four identified as ‘More Suitable’ two are located in the Green Belt.
• It is not clear what evidence base is relied upon to justify the exceptional circumstances required by the NPPF to justify a review and release of Green Belt land.
• As per the NPPF this justification should include making as much use as possible of suitable brownfield sites and underutilised land.
• Based on the information published with the SWLP Jan 2025, exceptional circumstances have not been demonstrated.
• The NPPF highlights the importance of allocating a sufficient amount and variety of land. Moreover, the benefit of mixed-use schemes.
• The future of Core Strategy Policy AS.11 and the Former Southam Cement Works is not clear in the SWLP consultation. Unlike the previous Reg 18 consultation, there is no schedule confirming the relationship to the SWLP Part 1 to the Core Strategy, with the policies to be saved, replaced etc.
• Based on the HELAA, the Former Southam Cement Works appears to be sifted out of the SWLP based on arbitrarily HELAA methodology.
• The site scored one ‘Red’ rating relating to minerals and as such was discounted.
• This ‘Red’ rating does not reflect the provisions of the Core Strategy AS.11, NPPG nor the Adopted Minerals Plan.
• It does not consider the current operational status of the site, its operational lifetime, nor how this relates to SWLP plan period and the fact that there is potential for the site to contribute to housing and economic growth in the short, medium and long term whilst maintaining operational interests.