Yes

ID sylw: 106205

Derbyniwyd: 07/03/2025

Ymatebydd: Sir Richard Hamilton Will Trust

Asiant : Carter Jonas

The general spatial strategy of the SWLP appears sound. The strategy seeks to focus development in sequentially preferable locations, in terms of their access to services and facilities. The more sustainable settlements with close links between housing, jobs and services are likely to have the ability to support more growth. However, the Trust believe that it is essential that appropriate services and infrastructure are provided alongside new development.

The Trust supports the principle of Growth Strategy Priority Areas and finds the hierarchical approach as set out in the SWLP to be drafted from a reasonable basis. It is especially important that the Councils have aligned the hierarchy across the two districts.

The Trust notes that the Growth Strategy Priority Areas considers:

• The provision of employment, retail services, education facilities in the settlements.
• The proximity to other settlements which may offer different or a wider variety services and facilities.
• The availability and quality of public and active transport connections.

It is important for the continued sustainable growth of the communities in the districts, and the economy, that economic growth, remains a key part of the growth strategy.

Other

ID sylw: 106614

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

As we set out in further detail at Section 3 of these Representations, we do not agree that all of the identified Strategic Growth Locations 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. 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. Linked to this, we consider it a significant failing of the emerging Plan to prioritise or highlight areas which suffer from a lack of infrastructure, or conversely those areas which benefit from existing infrastructure.

Whilst we broadly support the identification of Priority Areas, we do not agree with the specific delineation of Priority Area boundaries insofar as they relate to Henley-in-Arden. Specifically, the draft SWLP does not evidence or justify the identification of land to the north of Henley-in-Arden, but outside of the existing urban area, as falling within Priority Area 1, while land to the south falls within Priority Area 2 / 3. It is apparent that the boundary of Priority Area 1 has been tightly drawn to reflect existing built development in the southern part of Henley-in-Arden but extends beyond existing built development to the north. The justification for this is not clear and we would argue that this amounts to an artificial manipulation of the boundary of the Priority Area, with the effect of rendering a greater proportion of parcels of land to the north of Henley-in-Arden which have been promoted for development and which are identified as falling with ‘SG23’ (as discussed in more detail later) as falling within the area.
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.
This is further evidenced by the 2022 Urban Capacity Study, which sets out at Section 4.6 that greenfield land must be released to meet South Warwickshire’s housing needs and that “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development” (our emphasis). In short, it is in our view essential that the SWLP is clear from the outset that the only way to meet development needs will be to build on current greenfield sites including the Green Belt, in sustainable locations.
Figure 6 goes on to identify the Emerging Spatial Growth Strategy Options, comprising Strategic Growth Locations (24 no. in total) and Potential New Settlements (12 no. in total). Land to the north of Henley-in-Arden is identified as comprising Strategic Growth Location SG23. As set out in further detail later within these Representations(Section 3), we do not support the identification of land to the north of Henley-in-Arden as a Strategic Growth Location, particularly when the benefits and disbenefits of its allocation are weighed against those of land to the south of Henley-in-Arden. We also have concerns in respect of the identification of Potential New Settlements A1 and A2 to the north west of Henley-in-Arden.

Other

ID sylw: 106617

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

Section 4.1 of the PO Consultation Document sets out that “Sustainable Travel and Economy”, previously identified as Option 4 within the I&O Consultation, is identified as the chosen Spatial Growth Strategy for the SWLP.
The Respondent supports in particular the 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 Henley-in-Arden – should be prioritised as locations for growth. More specifically, the Respondent’s Site at Henley-in-Arden is an ideal candidate for future housing development in this regard given it location within walking distance of Henley-in-Arden railway station.
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.

Other

ID sylw: 106679

Derbyniwyd: 07/03/2025

Ymatebydd: William George and Patricia Anne Winter

Nifer y bobl: 2

Before a brick is laid, the infrastructure needs to have been planned in the finest of detail and completed before any building work is undertaken.

This infrastructure, of course, means full transport planning to include roads, rail/tramway and cycling paths, together with the requisite schools and colleges, doctors and dentists surgeries, health and social care provision and any other NHS facilities such as cottage hospitals or a dramatic upgrade to existing hospitals.

It is critical to consider anything else essential to support a healthy, coherent, and properly functioning society as we move towards the middle of the twenty-first century.

No

ID sylw: 106721

Derbyniwyd: 27/02/2025

Ymatebydd: Clare Teasdale

A dispersed housing strategy is the best way to accommodate future housing needs without destroying our countryside or overloading infrastructure. It promotes fairer economic distribution, stronger communities, and a more sustainable approach to growth. Instead of giving large developers free rein to build massive estates in a single location, the focus should be on smaller, better-planned developments across multiple sites—ensuring that growth is community-driven, not profit-driven.
I hope those responsible for shaping this plan are willing to consider alternative, more sustainable solutions rather than simply following the path laid out by large developers and consultants.

No

ID sylw: 106754

Derbyniwyd: 04/03/2025

Ymatebydd: P Beauchamp

No further comment supplied.

No

ID sylw: 106874

Derbyniwyd: 07/03/2025

Ymatebydd: Graham Hames

We already have too many houses in the area. Council should be lobbying government to reduce population by reducing legal immigration.

Yes

ID sylw: 106945

Derbyniwyd: 03/03/2025

Ymatebydd: Coventry and Warwickshire ICB

The Coventry and Warwickshire ICB strongly supports the principle of an evidence-led sustainability strategy, rather than one driven solely by site options. The ICB expresses concern regarding the potential overwhelming impact of dispersed small-scale developments on primary care already operating at capacity. A fragmented approach could overwhelm existing PC sites and create challenges in securing adequate developer contributions for infrastructure expansion. The ICB recommends exploring strategies to cluster small-scale developments around existing settlements to achieve economies of scale and facilitate sustainable growth in the primary care infrastructure. The ICB welcomes the large scale new settlement approach recognising the settlement must be of sufficient scale to enable a viable Primary Care delivery site to be an option.
The ICB is pleased that the “Sustainable Travel and Economy" Spatial Growth Strategy is committed to ensuring the provision of infrastructure alongside housing and employment growth.

Other

ID sylw: 107061

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Non-Strategic Employment Need

24 Strategic Growth Locations have been identified, outlined in Table 5 of the SWLP. These strategic locations could accommodate more than South Warwickshire’s non-strategic employment need (alongside assisting in accommodating South Warwickshire’s housing need). We understand that not all these locations will be allocated, and that the locations situated in the Green Belt will require exceptional circumstances for their release. To note, SG07 (Strategic Growth Location) is also proposed as a potential strategic employment site in Draft Policy Direction 12.

NBBC would be in favour of this preferred approach being explored further as South Warwickshire progress with developing the SWLP, taking into consideration the implications of Green Belt locations, the Sustainability Appraisal outcomes and the new 2024 NPPF Standard Method housing figures.

Furthermore, Coventry City Council's Regulation 19 consultation on their Local Plan declares a shortfall in employment land need. NBBC believes that Coventry should undertake further work to identify supply within its administrative boundary. In the event South Warwickshire accept there is a shortfall deriving from Coventry’s local need, NBBC supports the findings of the ELR regarding accommodating Coventry’s unmet need. The ELR identifies sites to the south of Coventry and the west of the A46 such as Land South of Dalehouse Lane, Kenilworth (16ha) (CFS95) and Land South of Coventry (East) (49ha) (CFS94) which could contribute to Coventry’s unmet need, subject to assessment. Therefore, should it be established that Coventry has unmet employment land need, SG01 and SG03 would be suitable.

Other

ID sylw: 107072

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Assessments required for sites that are taken forward to the Regulation 19 (Pre-Submission) stage
For sites within the CNL and sites within the CNL’s 3km buffer zone that the Councils are considering taking forward to the Regulation 19 (pre-submission) consultation stage, we recommend that the following assessments should be undertaken:
• An updated landscape sensitivity assessment (LSA) specifically for the sites that are being proposed, including consideration of landscape and visual effects in relation to the CNL.
• For sites that, individually and / or collectively, would increase the number of dwellings in the settlement by 10% or more, an assessment of the potential increase in traffic movements on roads within - and along the boundary of the CNL that would result from the proposed allocation.
9
• An assessment of whether the allocation is likely to further the purpose of conserving the natural beauty of the CNL (including: (i) whether the allocation would have a (net) beneficial, harmful, neutral or negligible effect or no effect; and (ii) what reasonable and proportionate action could be taken to further this purpose, over and above avoidance and mitigation of harm).
For sites within the CNL, specifically, that remain in consideration, we recommend that an assessment should be undertaken to identify whether the site constitutes major development, in the context of paragraph 190 of the NPPF. If it is deemed to constitute major development, a further assessment should be undertaken to identify whether exceptional circumstances apply to justify the proposal.

No

ID sylw: 107161

Derbyniwyd: 06/03/2025

Ymatebydd: Richard Poynter

A dispersed housing strategy is the best way to accommodate future housing needs without destroying our countryside or overloading infrastructure. It promotes fairer economic distribution, stronger communities, and a more sustainable approach to growth.

Instead of giving large developers free rein to build massive estates in a single location, the focus should be on smaller, better-planned developments across multiple sites—ensuring that growth is community-driven, not profit-driven.

I would appreciate a response on this, as it’s clear that the current approach is not in the best interest of our communities. I hope those responsible for shaping this plan are willing to consider alternative, more sustainable solutions rather than simply following the path laid out by large developers , consultants and a Labour government that just wants to build 1.5 million homes without any thought or consideration for existing residents.

No

ID sylw: 107198

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

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 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.
We consider that 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 a significant failing of the emerging Plan that it currently appears to prioritise or highlight areas which suffer from a lack of infrastructure, whilst conversely, promoted sites in areas benefitting from existing infrastructure have not at this stage been taken forward. We return to this later in our consideration of the sites adjacent to and in proximity to Bishop’s Itchington, at Section 3.
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”.
It is critical that the SWLP makes clear at the outset that development will need to extend beyond existing urban limits.
It is in our view essential that the SWLP is clear from the outset that the only way to meet development needs will be to build on current greenfield sites in sustainable locations.
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.

No

ID sylw: 107223

Derbyniwyd: 05/03/2025

Ymatebydd: Andrew Sweeney

Asiant : Mrs Eleanor Lovett

It is evident based on the changes to national policy introduced in the revised Framework, that the emerging Plan housing need should be based on the housing requirement calculated using the standard method. However, Paragraph 62 goes on to specify that ‘In addition to the local housing need figure, any needs that cannot be met within neighboring areas should also be taken into account in establishing the amount of housing to be planned for’. As a result, it is not sufficient for the emerging Plan to seek to meet the standard method figure only, but where evidence confirms that neighbouring authorities are unable to meet their emerging housing needs, provision should be made to accommodate some of this within South Warwickshire.
It is understood that at this point in time, there is a lack of up-to-date evidence on the emerging housing needs for neighbouring authorities.
Further consideration should also be given to the need to plan for an increased level of housing in order to address The emerging Plan’s approach to planning for a 25 year plan period, and therefore up to 54,700 dwellings is supported in principle, noting that this is generally consistent with the requirements of national policy in particular Paragraph 22 of the Framework.
The supporting text in the draft Plan sets out the approach to accommodating housing and employment needs, establishing that full use will be made of suitable urban brownfield land before development is considered elsewhere.
In order to comply with national policy, it is critical that the emerging SWLP allocates a range of sites, including smaller sites of less than 1ha such as the Site being promoted through these representations at Springbrook Lane.
The preparation of the Plan should also give regard to the introduction of Grey Belt to national policy.

Other

ID sylw: 107267

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

As outlined above, the Cotswolds National Landscape (CNL) Board:
•
does not broadly support the proposals relating to Draft Policy Directions 1,2 or 4 or the proposals relating to Strategic Growth Location 17.
•
does broadly support the proposals relating to Draft Policy Directions 3, 5 and 6.
There are some additional proposals in Chapter 4 that we do not broadly support, as outlined below.
Windfall allowance
Firstly, we are concerned about the proportion of the overall housing need that the Councils anticipate being met by a ‘windfall allowance’ (i.e. sites that are not allocated in the Local Plan). Table 3 indicates that 9,375 dwellings out of the 54,700 that are needed over the plan period will be provided via a windfall allowance (i.e. 17%). When existing commitments (17,068 dwellings) are taken out of the equation, the windfall allowance makes up 25% of the remaining housing need. This seems like a high percentage, particularly given that there are supposedly more sites currently in consideration than the Councils will actually need to meet the identified housing need.
Paragraph 75 of the NPPF states that:
•
Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.13
If there are more sites in consideration than the Council will actually need then, presumably, the Councils could set a lower windfall allowance percentage.
Priority Area buffer zones
Secondly, we are concerned about the way that Priority Area ‘buffer zones’ are shown in Figure 5 (Spatial Growth Strategy Priority Areas). For example, the Meon Vale area is identified as being a Priority Area 1 zone. This Priority Area 1 zone is surrounded by a Priority Area 2 buffer zone, which extends into the CNL and includes the CNL settlement of Upper Quinton. In the Board’s opinion, the CNL should not be included within this buffer zone, not least because National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. The same principle applies to the Priority Area 3 buffer zone around Moreton-in-Marsh, which extends into the CNL, including the CNL settlement of Barton-on-the-Heath. We consider that the mapping of the Priority Area buffer zones should be more nuanced to take account of this by not extending these buffer zones into the CNL.

Other

ID sylw: 107383

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

Warwickshire Wildlife Trust are extremely concerned regarding the Preferred Options Local Plan for South Warwickshire.
Particularly the housing allocations and largescale new settlements that are on and close to important ‘Local Wildlife Site’, SSSIs, Nature reserves, Ancient Woodlands and in the Greenbelt. We are concerned regarding the loss of threatened habitats and the impact increased traffic/lighting/noise and activity in these areas, would have on legally protected species and important wildlife habitats.


The Local Plan includes new settlements and land for large-scale housing and employment next to and on important Local Wildlife Sites, and in a large number of cases on existing Green Belt land. These areas act as vital refuges for wildlife in a landscape which is already fragmented by roads, housing, and development.
The housing targets set out in the plan, importantly seem to have been grossly exaggerated over and above the needs assessment. Putting additional pressure on important legally protected species and wildlife sites.

Yes

ID sylw: 107411

Derbyniwyd: 16/02/2025

Ymatebydd: Moreton Morrell Parish Council

Agree

No

ID sylw: 107503

Derbyniwyd: 07/03/2025

Ymatebydd: Palmer Family

Asiant : Newton LDP Limited

The polices set out in the SWLP as currently drafted, are neither positively prepared nor consistent with national policy. Relying on outdated evidence to justify an annual housing requirement of 1,679 dpa and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, undermines the plan.
To address this, the emerging policy should specify that provision will be made for at least 2,188 dpa, equating to a minimum of 54,700 dwellings over the plan period. Evidence shows that this target is achievable, with over 2,188 completions in six of the last eight years across South Warwickshire. Adopting this higher figure would not undermine the plan's effectiveness

Other

ID sylw: 107541

Derbyniwyd: 06/03/2025

Ymatebydd: Burton Dassett Parish Council

We, Burton Dassett Parish Council would support the general concept of the SWLP if and only if:

1) All brownfield sites are included in achieving the goal of strategic growth aspirations and housing needs and the use of brownfield sites is prioritised over greenfield, given their likely close proximity to existing road and rail infrastructure and services including health care, education, retail and leisure.

2) The additional development is designed to encourage growth prospects for that area, rather than simply providing a dormitory for workers to commute from, to existing centres. Where existing centres need more people, build more dwellings within the curtilage of that centre, so public transport can be easily extended rather than created from scratch.

3) The proposals do not fundamentally change the character of the surrounding area unless the growth in economic and social benefits from that change can be shown to justify the change. Do not "ruin" the character of a small community/environment by simply adding 100 dwellings and nothing more.

4) All developments are in proportion to the likely growth prospects for the area.

5) Where consideration is being given to the housing needs of the area.

The PC would not support the SWLP where the proposed sites would conflict with the following points:

1) The use of prime agricultural land - SG13/14 G1,F1/2/3 seem to conflict with this.

2) Where flooding is already an issue and will be exacerbated - SG14 G1,F3 seem to conflict with this.

3) Lack/overload of local infrastructure at sites - primary/secondary schools, doctors surgeries, hospitals, grocery and retail outlets, rail links (Network Rail does not intend opening a new station at Deppers Bridge, nearest rail link would be at Banbury or Leamington Spa and the railway next to G1 is for MOD, Kineton use only) as well as utilities - water, sewage, mains gas, electrical supply. The SWLP is looking at reducing the reliance on cars, but the current suggestions would only increase their usage in areas where there is lack of public transport - SG13/14 G1,F2/3 seem to conflict with this.

4) Unsuitable road network, access is only by B roads or country or single track roads. SG13/14,G1 are next to or near the M40 and increase in traffic would put a considerable strain onto an already congested Junct.12 at peak hours, it being the nearest junction for JLR, AM and the Upper Lighthorne development - G1,F2 seem to conflict with this.

5) All sites, would see an increase in light pollution, detrimental to the whole of these areas.

6) Would seriously impact the views from Burton Dassett Country Park, a Special Landscape Area looked after by Warwickshire County Council and/or Chesterton Windmill. Both sites, from their raised positions have far reaching views over open countryside and these sites would impact the character of the area - SG10/11/13/14 G1,F1/3 seem to conflict with this.

7) Cultural and historic assets. These developments run alongside the Fosse Way where there are potential Roman sites. At G1 the Old Salt road (a single track lane) runs alongside this proposal where both medieval and Roman sites have already been found during the recent construction stage of a solar farm - SG10/11,F1 seem to conflict with this.

8) Avoid the swamping of existing villages, irreversibly changing their character to the detriment of existing residents, particularly Gaydon, already blighted by multiple threats of inappropriate development - SG13/14 seem to conflict with this, would swamp the village making it an undesirable place to live.

For all the above reasons we would not support the SWLP as presented.

Other

ID sylw: 107561

Derbyniwyd: 26/02/2025

Ymatebydd: Finham Parish Council

We are aware Kings Hill has already received Outline Planning Permission, has been carried over to the new plan, and is not part of this consultation. However we are re-iterating our desires for the site and hope you can consider the below.

1) No bus gate on Green Lane immediately next to Finham Primary School. This would increase traffic congestion and accident risk.
2) No roundabout at junction of Green Lane/Howes Lane. This would encroach on what little greenery will be left and allows insufficient room for large lorries.
3) Preserve our ancient hedgerows along the south end of Green Lane.
4) Preserve our trees along Green Lane especially those with Tree Preservation Orders.
5) Provide a green corridor along Green Lane, particularly around the back of the primary school to contribute to the biodiversity requirements of the site.
6) Preserve the Anglo-Saxon remains close to the Kings Hill Lane/Green Lane junction.
7) New children’s play area as close to Finham as possible, ideally on site of the proposed bus gate.
8) Ensure the promised Primary and Senior schools will be built early in the building phase to avoid stretching the resources of current local schools.
9) Ensure the promised clinic will be built during the first phase of building.
10) Provide commitment for a new Community Centre building.

Finham is the most affected area by housing development on Kings Hill and therefore the FPC should be kept informed of all developments, changes and proposals that will affect Finham residents. FPC would like an update on the progress of CIL discussions between yourselves, the developers and Coventry City Council and would hope to influence spend.

Yes

ID sylw: 107571

Derbyniwyd: 06/03/2025

Ymatebydd: Stratford Society

The Society strongly endorses the intention of the SWLP to support Neighbourhood Development Plans in making housing and employment allocations. While it is acknowledged that not every brownfield site outside urban areas may be suitable for small-scale redevelopment, these should be considered in the first instance.
This chapter states plainly that, in the Green Belt, anything other than small-scale development would be inappropriate since these areas lack the infrastructure for larger development such as schools, medical facilities, meeting places, open spaces and shops. Instead, efforts should be made to develop a prosperous rural economy through diversification of agricultural businesses.

No

ID sylw: 107705

Derbyniwyd: 01/03/2025

Ymatebydd: Simon Jackson

1. Principle.

1.1 The main thrust of the SWLP appears to be predicated on the premise that twice as many houses are needed than the present SDC Core Strategy assumes,
1.2. By contrast, it appears that Bhr’m and Coventry need only half the number,
1.3. It follows that the ethos and principle of the Duty to Cooperate regs are prejudiced because the SWLP includes an element of the Bhr’m and Coventry overspill.
1.4. Generally, the SWLP is proposing a number of totally unsuitable sites for development in South Warwickshire (see following Planning Reasons).

2. Planning Reasons.

2.1. The aggregate of current agricultural land – assessed as Grade 3a & b? – that will be lost under proposed housing development will impact adversely on farming and food sustainability,
2.2. Such development in open countryside will have unacceptable, harmful impacts – including visual, recreational, amenity, bio and geo-diversities,
2.3. The risk of flooding due to the predominantly clay base of the land in question - viz SG17 and SG14,
2.4. Flooding risk exacerbated by run off from increased hardstanding and roofing,
2.5. The character and appearance of the existing communities which the proposed development sites will abut will be severely compromised due to associated infrastructure requirements such as roads, amenities etc – viz SG13 and SG16.

Other

ID sylw: 107769

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The SWLP is seeking to allocate strategic sites. Bellway has no objection to this approach but considers that the SWLP needs to be clear that additional sites which are not in these strategic locations but adjacent to other sustainable settlements in the Districts will be supported and may be allocated in the Part 2 plan.
Long Itchington is identified as a Category 1 (most sustainable) village for sustainability in the adopted Stratford on Avon Core Strategy. Long Itchington is sustainable and, although it may not be an appropriate location for strategic scaled growth, it will be able to accommodate major housing development. Settlements which are not currently proposed to be the subject of ‘strategic’ growth in the SWLP should not be dismissed as unsuitable for any level of growth across the plan period. The SWLP should be planning for all scales of growth.
The Sustainability Appraisal (SA Preferred Options) only assesses the Strategic Growth Locations but we consider that all sustainable settlements, such as Long Itchington, should be assessed for their potential to accommodate growth.

Other

ID sylw: 107794

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The SWLP is seeking to allocate strategic sites. Bellway has no objection to this approach but considers that the SWLP needs to be clear that additional sites which are not in these strategic locations but adjacent to other sustainable settlements in the Districts will be supported and may be allocated in the Part 2 plan.
Long Itchington is identified as a Category 1 (most sustainable) village for sustainability in the adopted Stratford on Avon Core Strategy. Long Itchington is sustainable and, although it may not be an appropriate location for strategic scaled growth, it will be able to accommodate major housing development. Settlements which are not currently proposed to be the subject of ‘strategic’ growth in the SWLP should not be dismissed as unsuitable for any level of growth across the plan period. The SWLP should be planning for all scales of growth.
The Sustainability Appraisal (SA Preferred Options) only assesses the Strategic Growth Locations but we consider that all sustainable settlements, such as Long Itchington, should be assessed for their potential to accommodate growth.

No

ID sylw: 108014

Derbyniwyd: 27/02/2025

Ymatebydd: Jennifer Watson

Yesterday , I attended a local housing consultation in Ashorne village where I learned of plans for 12 large-scale housing developments. This ludicrous idea seems to be firmly underpinned by financial gains of a few rather than the current community that currently exists.

I completely disagree with these proposals. It’s clear that big developers and their consultants are driving this plan, presenting biased analysis that prioritizes profit over sustainability, quality of life, and local interests. We need a better, more considered approach—one that distributes housing more evenly across the county, prevents infrastructure overload, and ensures that development works for us, not just for developers.

Surely a dispersed housing scheme makes more sense. This approach ensures a more balanced distribution of housing, infrastructure, and economic benefits while protecting the character and sustainability of towns and villages.

The traffic in our local area is already extremely heavy and the infrastructure needed for such projects is simply not in place. Our local GP surgery is already under pressure and as a local primary school teacher, I know without question that the resources we have are inadequate for the families we already serve, without any additional stress.

I find the current state of events truly worrying and unjustifiable.

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.

Other

ID sylw: 108422

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

Morgan Elliot Planning on behalf of Alscot Estate are promoting Land North of Shipston Road, Alderminster for residential development. This site does not fall within the categories of the targeted Call for Sites but is provided as a new option in the light of the recent changes to the Standard Method and the associated increase in the housing requirement.

The site is within Priority Area 3 and therefore aligns with the Councils’ preferred Growth Strategy. The entirety of the 14-hectare site is proposed for residential use. The number of dwellings is subject to further technical work. Alderminster provides a number of services accessible within walking distance of the site. The site’s proximity to Shipston Road provides a direct and safe route to Stratford-on-Avon. The Town Centre and its amenities are within cyclable distance and 20 minutes by public transport. This is a key driver for sustainable development at this location, providing access to an extensive range of services and facilities as well as employment opportunities.

There is national planning policy support to deliver housing in rural areas. Paragraph 83 of the NPPF supports the location of housing where it will enhance or maintain the vitality of rural communities. This is echoed in the PPG for rural housing. Application 14/02372/OUT for 25 dwellings, demonstrates that in the previous plan period Alderminster was judged capable of accommodating residential growth. Development of the site offers opportunities for affordable housing delivery which will retain and attract a younger population, sustaining and enhancing services within Alderminster and surrounding areas. It would also provide opportunity for rural farmers and those involved in rural businesses to reside in the local area, contributing towards a more balanced community and enhancing community cohesion, meeting the social objective of sustainable development.

The site benefits from an existing vehicular access connected to Shipston Road. As part of a future planning application, an appropriate Transport Assessment will be completed to establish that this access is safe and suitable, aligning with Paragraph 115 b) of the NPPF. The site is not within a designated landscape or conservation area. The topography is flat. Residential development is located immediately to the south and, more broadly, to the southeast. Development would be seen as a natural extension to the existing settlement within the surrounding landscape. The developer also intends to deliver a scheme that will conserve and enhance the surrounding landscape through careful and high-quality design. A Heritage Impact Assessment will be completed to inform the design and mitigate any potential impacts to the listed buildings 80m southeast of the site.

The developable area comprises agricultural land actively promoted by a single landowner. There are no known legal arrangements, complex land ownerships, or significant constraints that would prevent or delay development. As mentioned above, it is suitably and sustainably located for residential development and suitable in landscape terms. This development could be delivered quickly and is achievable within five years.

Other

ID sylw: 108423

Derbyniwyd: 27/02/2025

Ymatebydd: Edward Hargreaves

I attended a consultation event in Ashorne and was astonished by proposals for 12 large-scale housing developments. I disagree with this approach, which will have long-term impacts on communities, infrastructure and countryside. Big developers and consultants are driving the Plan. I support a dispersed housing strategy as an alternative to this approach.

This would better protect the character of rural areas, reduce infrastructure overload, result in fairer distribution of economic benefits, enhance community integration, and make growth more sustainable and flexible. This would be achieved by identifying suitable small and medium sized sites across the county, utilising brownfield and infill sites first. Developers would be required to contribute directly to infrastructure through CIL and S106 agreements. Planning policies would encourage developments of 10-50 homes rather than concentrated 500+ home estates, and support self-build and community-led housing. Grants or planning incentives could be offered for local builders and developers. This would be accompanied by eco-friendly building standards. Natural landscapes would be protected by spreading development and integrating green corridors and wildlife protection measures.

Conversely, large scale developments in one area cause infrastructure overloads due to delays in providing upgrades and developers arguing viability to try to avoid providing funding. Large estates destroy large swathes of countryside and wildlife habitats. They often lack character and a community feel, becoming isolated commuter zones that do not integrate with existing towns and villages. They are developer-led and this means they prioritise profit and maximising housing numbers over sustainability and community needs and concerns. Transport networks are often overwhelmed without properly-phased development. This increases traffic and travel times and reduces air quality.

Other

ID sylw: 108490

Derbyniwyd: 03/03/2025

Ymatebydd: Lesley O'Connor

As I stated above, we do need new houses, but I query the number that has been recommended by our government. As I understand it, that they have said that South Warwickshire requires over 54,000 new homes, this is contrary to the number needed, which is, I believe, 28,000.
We have already lost too much land to HS2, so I urge Warwick & Stratford district councils to think very seriously about the effect too many houses in our area may have for the present residents & future generations.

Other

ID sylw: 108492

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Excessive and Unjustified Housing & Employment Land Allocation (Chapter 4 & Chapter 6)
• The plan proposes up to 54,700 new dwellings by 2050, which significantly exceeds actual housing demand based on the latest census data.
• The Local Plan does not provide sufficient evidence to justify these excessive housing numbers, particularly when considering reduced population growth trends.
• Over-allocation of land leads to unnecessary urban sprawl, particularly when existing sites within towns and urban centers remain underutilized.
Conclusion: The housing targets must be reassessed using realistic population projections and demand-based evidence.

No

ID sylw: 108500

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Final Recommendation: The Plan Must Be Revised
The South Warwickshire Local Plan is unsound and requires the following modifications:
1. Recalculate housing need based on realistic population trends and census data.
2. Reduce land allocations to prevent unnecessary loss of countryside.
3. Implement a brownfield-first strategy in line with national policy.
4. Develop a comprehensive infrastructure plan before approving large-scale development.
5. Enforce affordable housing requirements to meet local needs.
6. Adopt a dispersed housing strategy to integrate new developments into existing communities.
7. Strengthen environmental policies to ensure compliance with biodiversity and sustainability targets.
8. Ensure transparency in housing targets and adherence to the Duty to Cooperate.