No

ID sylw: 106713

Derbyniwyd: 06/03/2025

Ymatebydd: Mrs Maureen Randerson

Asiant : Sworders

: In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method. The difference in provision between the old and the new standard method is significant. The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The current wording has not been positively prepared and is not considered to be sound in accordance with Para 36(a). We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which seems very excessive. We object to the overall strategy of solely relying on the Strategic Growth Areas and New Settlements to bring forward the districts housing requirements, as it takes more time for larger strategic sites like those proposed to come forward for development and as such will fail to meet the housing need in the short term. In order to have a five year housing land supply upon adoption of the new South Warwickshire Local Plan should allocate a greater number of small and medium sized sites. Avon Dassett can contribute to delivery of housing in the early years of the plan. Under the new method the shortfall in delivery will then be carried forward into the next five year period. Without the allocation of smaller sites on edges of existing settlements the housing and employment land provision will risk being in deficit for a significant part of the plan period.

No

ID sylw: 106751

Derbyniwyd: 04/03/2025

Ymatebydd: Robert Jay

Where are all these people coming from? Our death rate is higher than birth rate in our area.

Already congestion in this area at peak times.

Frequent power cuts so a lot of investment would be needed for new dwellings.

Water supply & sewage - where would all extra water come from & how will sewage be treated & taken away?

No

ID sylw: 106753

Derbyniwyd: 04/03/2025

Ymatebydd: P Beauchamp

Policy Direction 1 - No

No infrastructure for so many houses. Roads, doctors, schools to name a few.

No

ID sylw: 106786

Derbyniwyd: 04/03/2025

Ymatebydd: Shannon Moore

Oppose the proposed developments at Tanworth in Arden and at Woodend.

Yes

ID sylw: 106797

Derbyniwyd: 07/03/2025

Ymatebydd: H W Smith Ltd

Asiant : Bruton Knowles

We agree with Draft Policy Direction 2’s intention to identify and consider the allocation of one or more new settlements.
Site E1, in combination with the Site, provides the opportunity to deliver upwards of 10,000 dwellings, which would make a substantial contribution towards the local housing needs for South Warwickshire over the plan period. This is recognised at paragraph 77 of the NPPF, which states that new homes can often best be achieved through planning for larger scale development, provided they are well located and designed, and supported by the necessary infrastructure and facilities. Site E1, in combination with the Site, would be of a scale that could provide services, amenities, and local employment opportunities. They would also enable sustainable and active transport connectivity to Stratford-upon-Avon, as well as access to internal sustainable, low carbon transport options to meet the 20-minute neighbourhood concept and align with SWLP’s “Sustainable Travel and Economy” Spatial Growth Strategy.
Alongside the allocation of Site E1 as a New Settlement Location, the SWLP should also allocate a range of smaller and medium sized sites in order to ensure there is a sufficient supply of a range of site types and sizes to meet market needs and ensure a supply of housing can be provided in the earlier stages of the plan period. This aligns with Paragraph 61 of the NPPF, which states that a variety of land should be brought forward for housing, i.e. sites of different scales, ranging from minor development through to new settlements.

Yes

ID sylw: 106801

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Developments Ltd

Asiant : Morgan Elliot Planning

MMH is supportive of the approach set out in Draft Policy Direction 1 and advocates for developments in Priority Areas 2 and 3 to be endorsed.

No

ID sylw: 106806

Derbyniwyd: 07/03/2025

Ymatebydd: Bloor Homes

Asiant : Stantec

It is vital that the SWLP part one is in line with the NPPF which sets out that exceptional circumstances must be permitted in order to allow for an alternative method in assessing local housing needs such as the HEDNA. It is clear that Draft Policy 1 fails to comply adequately in this regard and therefore Bloor Homes object to the policy as currently set out.
It should plan for a minimum of 2,188 dwellings per annum (equating to 54,700 dwellings over the duration of the plan), with an additional buffer included for flexibility.
The buffer should, at a minimum, include an additional 5%, equating to 110 dwellings annually or a total of 2,735 dwellings throughout the duration of the plan. However, both Councils retain the authority to consider planning for further development beyond this minimum threshold to promote economic growth initiatives, as long as there is supporting evidence for such an approach.

No

ID sylw: 106838

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to Policy Direction 1 as the policy sets out both the Coventry and Warwickshire Housing and Economic Development Needs Assessment (2022 HEDNA) and Standard Method figures for the number of dwellings required for Warwick and Stratford across the plan period.

Yes

ID sylw: 106863

Derbyniwyd: 06/03/2025

Ymatebydd: Birmingham International Airport Ltd

We are pleased to see the Councils are looking to accommodate up to 54,700 dwellings across the 25-year plan period in line with the 2024 National Planning Policy Framework (NPPF) Standard Method. Additionally, we support the proposal to identify the upper threshold of 125 hectares of employment strategic sites. New housing and employment development of the capacities proposed in the SWLP will support Birmingham Airport’s growth aspirations by introducing additional potential customers to the region, with the Airport also functioning to boost physical connectivity to proposed strategic employment sites for those potentially outside the region.

Other

ID sylw: 106889

Derbyniwyd: 25/02/2025

Ymatebydd: Mr Geoffrey John Prince

I acknowledge the challenging new compulsory housing requirement for SW – set at 2,188 pa (ie 54,700 over the plan period 2025-2050). This will require a mix of:

- Amendments to Green Belt boundaries around all settlements
- Major, master-planned extensions (not piecemeal) to all large settlements/towns
- New settlements – these should be located along rail served public transport corridors Ie the Chiltern Line corridor) and include provision for anew Park and Ride station. The optimum locations would appear to be at Hatton and at Deppers Bridge/Bishops Itchington
- All other settlements in SW including at non Cat 1-4 settlements in SDC. These non cat villages should not be regarded as unsustainable locations – they are living places and part of a network closely linked to nearby larger settlements

No

ID sylw: 106994

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Wotherspoon

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method. The difference in provision between the old and the new standard method is significant.
The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The use of the HEDNA figures is not in accordance with Paras 36(a) and 62 of the NPPF.
We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which seems very excessive.
We object to the overall strategy of solely relying on the Strategic Growth Areas and New Settlements to bring forward the districts housing requirements, as it takes more time for larger strategic sites like those proposed to come forward for development and as such will fail to meet the housing need in the short term. Due to their scale and complexity larger sites will take time to plan and require significant upfront capital investment resulting in the housing need not being met within the next five year period. This will result in housing shortfall and the potential for an influx of speculative housing applications in areas that are less suitable for development.
In order to have a five year housing land supply upon adoption of the new South Warwickshire Local Plan should allocate a greater number of small and medium sized sites. Radford Semele can contribute to delivery of housing in the early years of the plan. Under the new method the shortfall in delivery will then be carried forward into the next five year period. Without the allocation of smaller sites on edges of existing settlements the housing and employment land provision will risk being in deficit for a significant part of the plan period.

No

ID sylw: 107001

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Davies

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method. The difference in provision between the old and the new standard method is significant.
The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The use of the HEDNA figures is not in accordance with Paras 36(a) and 62 of the NPPF.
We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which seems very excessive.
We object to the overall strategy of solely relying on the Strategic Growth Areas and New Settlements to bring forward the districts housing requirements, as it takes more time for larger strategic sites like those proposed to come forward for development and as such will fail to meet the housing need in the short term. Due to their scale and complexity larger sites will take time to plan and require significant upfront capital investment resulting in the housing need not being met within the next five year period. This will result in housing shortfall and the potential for an influx of speculative housing applications in areas that are less suitable for development.
In order to have a five year housing land supply upon adoption of the new South Warwickshire Local Plan should allocate a greater number of small and medium sized sites. Radford Semele can contribute to delivery of housing in the early years of the plan. Under the new method the shortfall in delivery will then be carried forward into the next five year period. Without the allocation of smaller sites on edges of existing settlements the housing and employment land provision will risk being in deficit for a significant part of the plan period.

Other

ID sylw: 107033

Derbyniwyd: 21/02/2025

Ymatebydd: Coventry and Warwickshire Chamber of Commerce

In terms of employment need to 2050 the CWCCC supports the basis of this key Policy. It notes that this draft policy direction sets out a large range of additional “industrial” provision between 75 and 125 ha up to 2050. The figure needs to be refined in subsequent iterations of this plan.

The CWCC welcomes the indication that the plan will accept the upper end of the range derived from
the WMSSS.

The final figures should not be derived only from the quantitative sources identified. It should also be informed from additional qualitative input from business organisations like the Chamber of Commerce, directly from industry and the spread of businesses across the C&W sub region.

The Chamber of Commerce has not commented on the
proposed new settlement locations but notes that a new settlement is likely to be allocated. CWCC
believes that if this option is selected it must include provision for an appropriate balance of
employment opportunities.

The CWCCC welcomes and supports the overall approach underpinning the Spatial Growth Strategy
this will provide a balance of new growth and an appropriate relationship between homes, jobs and
the provision of infrastructure and community facilities.

Other

ID sylw: 107058

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

South Warwickshire’s Housing Requirement

NBBC would be in favour of the 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. As the SWLP is only at the Regulation 18 stage of plan-making, the new 2024 NPPF Standard Method figures are applicable after 12th March 2025 and therefore, must be accommodated in future iterations of this Plan.

Other

ID sylw: 107059

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Employment requirements are set out as residual amounts in the SWLP, removing completions and commitments. NBBC are supportive of including these components in the supply and the Alignment Paper and Employment Land Review (ELR) which inform the Policy Direction. The Policy Direction is not clear and unambiguous on what components of supply are included and why one evidence document is preferred over another.

Table 4 identifies a residual strategic industrial site need (2021-2045) of 75-125ha. This derives from the West Midlands Strategic Employment Sites Study (WMSESS) and associated Alignment Paper. NBBC is supportive of using the upper band figure as recommended in the Study.

Strategic need is calculated until 2045, whilst other need figures are calculated to 2050. While it could be argued the need should be extended to 2050, NBBC is supportive of using the figure to 2045 as the WMSESS is the primary evidence document regarding strategic need. The Alignment paper does not recalibrate strategic site needs but aligns the evidence of the need for wider employment sites to this. NBBC are supportive of the approach adopted in the SWLP.

The WMSESS identifies a residual need for 75-125 ha of strategic sites up to 2045, to include 1-2 mixed B8 sites and 0-1 B2 sites, within Road Opportunity Area (ROA) 8 along the M40/A46. Opportunity Areas 7 and 9 are discounted as they do not feature junction opportunities and access to the strategic highways network is prime consideration in identifying suitable land. NBBC is supportive of discontinuing areas which do not provide junction opportunities and agrees Opportunity Area 8 is the primary Opportunity Area for South Warwickshire. The location is consistent with the recommendations of the Study.

No

ID sylw: 107067

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Over-riding concerns
The Board’s primary concern relates to Draft Policy Direction 1 (Meeting South Warwickshire’s Sustainable Development Needs).
Our concern is that there is not sufficient evidence or clarity to be able to identify whether the aspiration to meet the South Warwickshire’s objectively assessed needs (OAN) can be achieved without harming assets of particular importance, including the CNL. If meeting the area’s OAN cannot be achieved without causing harm to the natural beauty of the CNL, consideration should be given to setting a housing requirement figure that is lower than the housing need figure identified in the Government’s ‘standard method’.
This issue is complicated by three main factors, as outlined below.
Firstly, there is some ambiguity regarding exactly what OAN the SWLP is seeking to accommodate. For example, the SWLP states that provision will be made for at least the quantum of development identified in the Councils’ Housing and Economic Development Needs Assessment (HEDNA). However, it then goes on to say that that there will be ‘sufficient flexibility’ to accommodate the ‘standard method’ figure (which is significantly larger). As such, it sets two differing targets. If the intention is to accommodate the ‘standard method’ figure then this should be stated in a way that is unambiguously explicit and direct.
Secondly, there is considerable ambiguity regarding exactly which sites the South Warwickshire Councils intend to allocate for housing and other development. Some sites have been sifted out through the Housing and Economic Land Availability Assessment (HELAA) process. However, as we understand it, there are still far more sites currently in consideration than the Councils anticipate actually allocating.
Thirdly, through the HELAA process, the Councils have sifted out all sites that are located entirely within the CNL. This includes some sites that are allocated (or identified as reserve sites) in the relevant Neighbourhood Plan but have not yet been developed. We do not agree with the principle of sifting out potential allocations on the basis of being located 100% within the CNL. This is because, as outlined above, we recognise that a limited degree of development within the CNL may be appropriate in order to retain thriving and vibrant local communities. Therefore, we have reviewed and assessed nearly all of the sites within the CNL that have been sifted out through the HELAA process.
For some of these sites, we have recommended that they should remain in consideration, rather than being sifted out. As such, we are taking the unusual step of advocating a less restrictive approach to development in the CNL than the local authorities have proposed.
Conversely, there are a number of very large sites that overlap with the CNL boundary that have not been sifted out in the HELAA process. The Councils have indicated that such sites are unlikely to be allocated. However, given that they are still in consideration at this stage, it has still been necessary for the Board to review and assess them. We have recommended that all of these larger sites that overlap with the CNL boundary should not be taken forward (at least with regards to the CNL sections).

No

ID sylw: 107114

Derbyniwyd: 06/03/2025

Ymatebydd: Mr and Mrs Marvelly

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method. The difference in provision between the old and the new standard method is significant.
The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The use of the HEDNA figures is not in accordance with Paras 36(a) and 62 of the NPPF.
We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which seems very excessive.
We object to the overall strategy of solely relying on the Strategic Growth Areas and New Settlements to bring forward the districts housing requirements, as it takes more time for larger strategic sites like those proposed to come forward for development and as such will fail to meet the housing need in the short term. Due to their scale and complexity larger sites will take time to plan and require significant upfront capital investment resulting in the housing need not being met within the next five year period. This will result in housing shortfall and the potential for an influx of speculative housing applications in areas that are less suitable for development.
In order to have a five year housing land supply upon adoption of the new South Warwickshire Local Plan should allocate a greater number of small and medium sized sites. Radford Semele can contribute to delivery of housing in the early years of the plan. Under the new method the shortfall in delivery will then be carried forward into the next five year period. Without the allocation of smaller sites on edges of existing settlements the housing and employment land provision will risk being in deficit for a significant part of the plan period.

No

ID sylw: 107163

Derbyniwyd: 07/03/2025

Ymatebydd: Sharba Homes

Asiant : Stantec

It is vital that the SWLP part one is in line with the NPPF which sets out that exceptional circumstances must be permitted in order to allow for an alternative method in assessing local housing needs such as the HEDNA. It is clear that Draft Policy 1 fails to comply adequately in this regard and therefore Bloor Homes object to the policy as currently set out.
It should plan for a minimum of 2,188 dwellings per annum (equating to 54,700 dwellings over the duration of the plan), with an additional buffer included for flexibility.
The buffer should, at a minimum, include an additional 5%, equating to 110 dwellings annually or a total of 2,735 dwellings throughout the duration of the plan. However, both Councils retain the authority to consider planning for further development beyond this minimum threshold to promote economic growth initiatives, as long as there is supporting evidence for such an approach.

Yes

ID sylw: 107175

Derbyniwyd: 07/03/2025

Ymatebydd: Site Owner (Name Withheld)

Asiant : Nigel Gough Associates Ltd

We contend that the SWLP should plan to accommodate a minimum of 2,188 dwellings per annum, in line with the 2024 NPPF Standard Method. However, 2,188 dwellings per annum is the minimum and frankly South Warwickshire should plan for a higher level of provision than this because of failures in viability, failures in land ownership provision and failures to provide within the agreed time span for the Local Plan.

No

ID sylw: 107199

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

We do not support the inclusion of Table 2 within the draft SWLP, given that this sets out the housing calculation using the HEDNA method.
Table 3 (Housing calculation 2024 NPPF standard method) identifies a total housing need across the plan period of 54,700 for South Warwickshire, with assumed windfall allowance across the plan period contributing 9,375 to this figure, or 17.1% of the total need.
The reliance on windfall provision is even more marked when looking at Stratford-on-Avon in isolation, which has a housing need of 28,150 units over the plan period (as per the 2024 NPPF standard method) and an assumed windfall allowance of 6,850 or 24.3%.
Such an overreliance on windfall provision is simply unacceptable and would render the SWLP unsound.
Paragraph 15 of the NPPF requires the planning system to be ‘genuinely plan-led’. Leaving almost one quarter of housing land supply to future speculative development is not plan-led. As such, additional allocations are required to respond to housing need.

No

ID sylw: 107209

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

Emerging policy must treat 2,188 dpa as a minimum figure for housing in South Warwickshire to 2050.
There will undoubtedly be challenges for neighbouring authorities to meet their own needs and hence the South Warwickshire authorities may well need to increase their housing need figure by reason of the requirement to accommodate any unmet needs.
It is hence concluded that the draft South Warwickshire Local Plan should reflect that the combined Standard Method housing figure of 2,188 dwellings per annum is only the starting point and additional housing may be required to facilitate economic growth, the delivery of affordable housing and any unmet needs from neighbouring authorities. It is considered that the delivery of housing in excess of 2,188 dwellings per annum is achievable on the basis of the housing completions identified in the Authority Monitoring Reports for both authorities.

Other

ID sylw: 107231

Derbyniwyd: 06/03/2025

Ymatebydd: Malvern Hills District Council and Wychavon District Council

Paragraph 62 of the NPPF states that the standard method should be used to “determine the minimum number of homes needed”. On this basis it is queried as to whether any consideration has been given to revising the housing supply, development strategy and timetable etc. by the two South Warwickshire Councils to comply with a housing figure of 2,188 dwellings per annum as a minimum.

The development option of focusing new development on railway, and other transport corridors is supported as it is the most sustainable option and reflects the development strategy in the SWDPR. Encouragement is given though to considering how both housing, along with economic development can be woven into this approach from the options set in the consultation.

Other

ID sylw: 107234

Derbyniwyd: 26/02/2025

Ymatebydd: Oxfordshire County Council

The quantum of housing development to be provided for in this Joint Local Plan is substantial, particularly given the intention for this Local Plan to cover the period to 2050. Draft Policy Direction 1 says: 'The South Warwickshire Local Plan will make provision for the delivery of at least 1,679 dwellings per annum, in line with the HEDNA; with sufficient flexibility to accommodate up to 2,188 dwellings per annum, in line with the 2024 NPPF Standard Method. This equates to at least 41,975 dwellings over a 25-year plan period from 2025-2050, with sufficient flexibility to accommodate up to 54,700 dwellings. After accounting for existing commitments, and an assumed windfall allowance, there remains a "to find" figure of 15,532 dwellings (HEDNA) or 28,257 dwellings (2024 Standard Method). This to find figure represents the scale of development to be accommodated by the SWLP.'

The figure of 2,188 is made up of the NPPF Standard Method figures of 1, ,126 for Stratford-on-Avon and 1,062 for Warwick. We understand that this Local Plan will need to set a housing requirement in accordance with that Standard Method figure. Draft Policy Direction 4 indicates that there may, in addition, be a requirement to provide for unmet housing needs from Coventry and Birmingham, which should be further considered prior to the Local Plan progressing to Regulation 19.

At this stage we don’t have specific comments on the strategic growth options but are willing to engage in discussions if needed. We note that there are
no emerging spatial strategy growth options close to Oxfordshire’s boundary and therefore this Local Plan should not result in direct impacts and costs to Oxfordshire
County Council.

No

ID sylw: 107240

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The current Reg 18 Preferred Options consultation has been prepared on the basis of the lower HEDNA housing figures, relying upon the broad approach of growth options as providing flexibility to achieve the new Standard Method. As per the August 2024 Cabinet endorsed recommendation, we would encourage a period of reflection and that future drafts of the SWLP reflects on the outcome of the revised NPPF December 2024 and new Standard Method, update the approach to unmet need (see below) and revise the development strategy accordingly.

Other

ID sylw: 107242

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Meeting Housing Need
The housing need figure for South Warwickshire over the plan period is set out in Draft Policy Direction 1 and is presented as a range reflecting the findings of the Coventry and Warwickshire HEDNA as a minimum and the standard methodology as the top of the range. It proposes the delivery of at least 1,679 dwellings per annum across the area with flexibility to provide up to 2,188 per annum. This equates to 41,975 between 2025 and 2050 with flexibility to provide up to 54,700 dwellings.
A revised National Planning Policy Framework (NPPF) was published on the12th December 2024. This sets out the approach for determining local housing need which expects local authorities to follow the standard methodology for assessing local housing need. It identifies that the minimum annual housing need figure should be based on this approach (Paragraph 62). National Planning guidance sets out that where ‘Local housing need assessments may cover more than one area in particular where strategic policies are being produced jointly. In such cases the housing need for the defined area should at least be the sum of the local housing need for each local planning authority within the area (para 013 Housing and Economic Needs Assessment guidance).
Paragraph 69 of the NPPF sets out that strategic policy making authorities should establish a housing requirement figure for their whole area which shows the extent to which their identified housing need (and any needs which cannot be met within neighbouring areas) can be met over the plan period.
The plan sets out a sustainable spatial strategy for meeting the areas growth needs over the plan period with flexibility to meet the upper end of the identified housing need as evidenced through the standard methodology. This focuses development in priority areas 1 to 3 identifying potential new settlements and 24 potential strategic growth locations. It is clear from the range of potential locations for growth identified in the plan that there is capacity and sufficient flexibility to meet the overall higher need based on the standard methodology as set out in the NPPF. SMBC would support in principle a strategy which seeks to meet the identified housing need within the Local Plan boundary and does not seek to redistribute growth outside of the Local Plan area. Given the capacity to plan for the higher housing need figure it is unclear why the housing need is presented as a range and the higher figure derived from the standard methodology is not identified as the minimum housing need. This would reflect the latest government position for delivering national objectives for housing growth and would ensure the housing needs for South Warwickshire are met.
SMBC welcomes the commitment within the Preferred Options Plan to address the issue of unmet cross boundary housing needs. It is acknowledged within the Plan that there is a shortfall relating to the Greater Birmingham and Black Country HMA but the level beyond 2031 has yet to be established. It is considered that a study refresh is needed to take account of updated evidence and latest guidance. On this basis it is proposed that the Regulation 19 version of the plan will consider unmet housing need reviewing latest evidence and duty to cooperate discussions. SMBC would reiterate the importance of engaging in duty to cooperate discussions to ensure wider housing needs are met. The South Warwickshire Plan may need to address needs arising from both housing market areas. It is acknowledged that further evidence will be necessary to consider the wider housing market area through an update of the West Midlands Strategic Growth study which is currently underway.

Other

ID sylw: 107303

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon District Social Inclusion Partnership

Consideration should be made to whether the housing needs of more vulnerable, less mobile groups that rely most significantly on the provision or public and VCS services to maintain their health and wellbeing, access services and employment, should have housing in these more rural locations.

Comments in respect of rural exception sites:

In response to PD-1, would it be possible to promote the opportunity for using Rural Exception Sites as a way to deliver more affordable rural housing schemes? Our experience shows that there are two types of homes that are usually found to be missing within the rural context - small (2 bedroom) bungalows for older persons to downsize to, and small (2 bedroom) houses for young families. Both of these groups benefit from the housing advantages presented by Rural Exception Sites.

Rural communities need to be continually adjusted and transformed to make them attractive places to live and work, and to stabilise the population.

No

ID sylw: 107352

Derbyniwyd: 04/03/2025

Ymatebydd: Mr & Mrs - Blackhurst

Asiant : Frampton Town Planning

The policy approach is not consistent with the Framework which states at Paragraph 62: ‘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.’
The policy should seek to meet the standard method for housing as a starting point, consistent with National Planning Policy Framework paragraph 62.
It is imperative that consideration of the circumstances which may lead to an assessment of housing need which exceeds Standard Method are fully explored, and that the true unconstrained housing need for the area is established.

Other

ID sylw: 107397

Derbyniwyd: 24/02/2025

Ymatebydd: Moreton-in-Marsh Town Council

The Town Council notes the views expressed in paragraph 3.12 ‘If a new settlement is located too close to an existing settlement, this could limit its ability to grow into a truly self-sustaining settlement, with a risk it functions merely as a dormitory to its neighbour. There is also a risk that a successful new settlement could act as a drag on the existing settlement, jeopardising its retail and employment provision...’ of the Technical Document New Settlements Assessment (As at Preferred Options) South Warwickshire Local Plan November 2024, relating to New Settlement Locations within the existing context particularly in respect of the identified Priority 3 location between the A44 and Great Wolford on the Parish Boundary of Moreton in Marsh.

MTC notes the priority 3 area outlined on its Parish Boundary between the A44 and Great Wolford (Spatial Growth Strategy Priority Areas map: Fig 5) and is concerned. This priority 3 location lies within the Special Landscape Area, close the AONB (Cotswold National Landscape) and directly on the Parish Boundary. Whilst Moreton in Marsh railway station Identified in the Technical Topic Paper Emerging Spatial Growth Strategy (November 2024) at point 4.15 as a Group A station is a point of note, Bus frequency point 4.22, proximity to major towns point 4.23 and major employment sites described in point 4.27 would not suggest the location to be attractive from a growth perspective.

Other

ID sylw: 107491

Derbyniwyd: 07/03/2025

Ymatebydd: Suzanne Ross

Asiant : Savills

To accord with national requirements, this Plan must be written in a way to accommodate the full housing need of the area, as calculated by the 2024 NPPF Standard Method.
The Draft Policy Direction recognises this reality by mentioning both the HEDNA figure of 41,975 dwellings across the Plan period (at 1,679 dwellings per annum (dpa)) and the Standard Method figure of 54,700 dwellings at 2,188 dpa. Our client’s view is that the Plan must proceed on the basis of the higher NPPF figure to ensure a sound Spatial Strategy.
It is likely that to achieve this higher target, the Council will need to allocate a wide range of sites, from new settlements, strategic urban extensions to towns and smaller sites in sustainable villages. The Council should “leave no stone unturned” in its search for additional sites.
Consequently, our Client considers that its site at Alcester Road in Stratford-upon-Avon (HELAA Site References 492 and 827) should be considered favourably for allocation.

Yes

ID sylw: 107494

Derbyniwyd: 05/03/2025

Ymatebydd: Worcestershire County Council (WCC)

We support Strategic Objective 1: Providing sustainable levels of growth in the area.

The Preferred Options document identifies 24 potential Strategic Growth Locations, 12 potential New Settlement locations and 9 Major Investment Sites. The sites in closest proximity to the WCC highway and transport network are: - Strategic Growth Locations - SG20 Bidford-on-Avon, SG21 Alcester, SG22 West of Studley and SG23 North of Henley-in-Arden, and to a lesser extent SG17 Shipston-on-Stour. Potential New Settlements - A1 south of Tanworth-in-Arden, A2 east of Wood End, and E1 Long Marston Airfield. Major Investment Sites - MIS.2 LMA and MIS.3 Long Marston Rail Innovation Centre

We note that there are no requirements that need to be met by district Local Plans in Worcestershire.

WCC seeks further engagement with the SWLP team to understand:
• Forecast trip rates, trip generation and trip distribution associated with large new settlements (6,000 – 10,000 dwellings).
• Cumulative impacts of dispersed small-scale developments.
• Potential cross-boundary movements utilising WCC’s transport network.
• Development dependent on WCC’s infrastructure (e.g., to access services in Redditch and Evesham).
• Necessary highway capacity improvements to the WCC transport network.
• Mitigation measures to provide for/support cross-boundary movements.