No

ID sylw: 107505

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

a) Housing Numbers

It is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire, and opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

b) Housing Land Supply

The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase). The latest analysis from Landstack indicates that using the new Standard Method results in a housing supply of just 2.96 years.

In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.62-year housing land supply at the present time.

c) Spatial Growth Strategy

There is insufficient previously developed land within South Warwickshire to accommodate the level of housing required.

The Councils clearly have an opportunity to allocate additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher- growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.

It is contended that the SA undervalues the positive contribution that residential development in South Warwickshire can make towards biodiversity, particularly if sites are currently in arable use, as such land generally has a low ecological value.

The Site forms part of the ‘South of Wellesbourne Group’ Strategic Growth Location (SG16) and is split across Priority Areas 1 and 2. Its inclusion and Priority Area designation is strongly supported. This highlights that the Site is a sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. Development would also assist with sustaining facilities and services in Wellesbourne, which is a smaller settlement. SG16 has been assessed against the SA Framework and generally performs favourably.

No

ID sylw: 107507

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

The policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the NPPF, and associated update to the Standard Method, were in draft form only and subject to change. However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to the Standard Method requirement and make no reference to the HEDNA.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62, whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF paragraph 69.

Other

ID sylw: 107532

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

Warwickshire Wildlife Trust is extremely concerned by the scale of the proposed housing, which seems grossly exaggerated. The Plan reports a need for 1,679 dwellings per annum, but suggests allocating 600 surplus houses to allow sufficient flexibility. This will have a significant negative impact on the important habitats and protected species across the area. The Local Plan must deliver houses in suitable numbers for residents but in suitable locations and help deliver the Environment Act 2021s target of 30% of land allocated to nature and in recovery by 2030.
The Plan also allocates many housing sites in the Green Belt, which is an important land designation intended to protect the edges of wildlife sites and provide a transitional and safe area for important protected and declining species. The SA and plan strategy hasn’t considered a ‘no Green Belt option’ even at the early stages.
WWT is not satisfied that the Councils have carried out a detailed Green Belt Review to include this land, particularly the Stage 2 work as well landscape impact assessments. They also have not done individual Flood Assessment work yet (SFRA part 2s), which should be carried out in order to help chose sites and the strategy.

No

ID sylw: 107542

Derbyniwyd: 05/03/2025

Ymatebydd: Ellis Machinery Ltd

Asiant : Frampton Town Planning

This 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 HEDNA figure is significantly lower than the minimum number of homes set out in the Standard Method and should therefore not be taken into account when assessing local housing need.
The draft South Warwickshire Local Plan should also reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing.
The policy should seek to meet the standard method for housing as a starting point, consistent with National Planning Policy Framework paragraph 62. Table 3 identifies, taking account of the standard method, a need for 28,150 dwellings in Stratford and 26,550 in Warwick across the plan period.
The SWLP should therefore look to the non-Green Belt, Strategic Growth Areas before looking to Green Belt areas, to ensure consistency with the Framework.
We agree that Gaydon should be considered as a Strategic Growth Area and consider that, in this context, land should be allocated or new strategic development on the edge of Gaydon.

No

ID sylw: 107550

Derbyniwyd: 04/03/2025

Ymatebydd: James Bushell

Asiant : Frampton Town Planning

This policy 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 HEDNA figure is significantly lower than the minimum number of homes set out in the Standard Method and should therefore not be taken into account when assessing local housing need.
The draft South Warwickshire Local Plan should also reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing.
In terms of Sustainability, the area ranks 3rd out of the 12 for being the most sustainable. However, the paper also concedes that there is “Strong concern re. lack of promoter given 0% land put forward in ‘Call for Sites’ thus deliverability is questionable” regarding New Settlement C1. Given none of the land has been put forward for development, this raises concern over the availability of the land for a new settlement at Kingswood. Other, sustainable, sites in this area should be considered for allocation, such as Land north of Old Warwick Road, Kingswood.

Other

ID sylw: 107563

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Draft Policy Direction 1 provides a range of dwelling numbers over the plan period, with the
lower figure being that of the HEDNA and the higher figure being that of the new version of
the Standard Method which was introduced in December 2025.
Whilst the HEDNA is a robust joint evidence base between the Housing Market Area
authorities, its application in terms of calculating housing need for the purpose of plan
making is determined by the transitional arrangements for implementing the new NPPF.
Given the timetable for the production of the SWLP it would appear that this will not meet
the deadlines for the transitional arrangements and that therefore the new Standard Method
calculations will apply.
In terms of employment need, Coventry City Council welcomes the use of the findings of
the HEDNA in producing more up to date evidence i.e. the WMSESS / HEDNA alignment
study, and the South Warwickshire Employment Land Study. This is consistent with
Coventry’s own approach.
Coventry City Council works closely with partners across the Housing Market Area (HMA)
and the Functional Economic Market Area (FEMA), and this includes regular meetings and
discussions under the Duty to Co-operate. Coventry has reached the Regulation 19 stage
of plan making and as partners are aware intends to accommodate its own identified
housing need but has a shortfall of 45 hectares for local employment need and is seeking
help from partners across the FEMA in addressing this, along with addressing the wider
issue of strategic employment. Discussions are ongoing across the FEMA and Coventry
welcomes acknowledgement of this through the SWLP Preferred Options.

Other

ID sylw: 107588

Derbyniwyd: 06/03/2025

Ymatebydd: Birmingham City Council

Housing need – Birmingham City Council published a Preferred Options consultation in July 2024. At that time, there was an identified shortfall of 46,000 homes. The new NPPF sets out a revised standard methodology which reduces Birmingham’s housing need and as such, the shortfall is expected to reduce significantly, However, further work needs to be undertaken to establish the new position. The City Council will publish a revised Preferred Options consultation in November 2025, and this will set out any shortfall.

Other

ID sylw: 107592

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

National Highways acknowledges that an evidence-led approach has been adopted
for identifying housing and employment growth across South Warwickshire, in line with
both the Housing and Employment Development Needs Assessment (HEDNA) and
the 2024 NPPF Standard Method. Based on the HEDNA (and taking account of
existing commitments and an assumed windfall allowance) a “to find” figure of 15,532
dwellings is identified, whilst a “to find” figure of 28,257 dwellings is identified based
on the 2024 Standard Method. A residual need for 75-125 ha of employment land is
also identified for the period to 2045.
We note that 24 areas have been identified as locations for potential strategic growth
and that full use of suitable urban brownfield land will be made before development is
considered elsewhere which is welcomed.

No

ID sylw: 107621

Derbyniwyd: 03/03/2025

Ymatebydd: Stratford-upon-Avon Town Transport Group

By contrast, Strategic Growth Areas which circle historic towns provide a collar affecting
both the effectiveness of new development and the pre-existing town. Where they are
separated from the town by major roads, communities become isolated. Major growth
options spread towards existing villages, potentially overwhelming them, and also detract
from investment in new settlements.

Stratford-upon-Avon infrastructure is constrained by the historic layout of the town, in
transport terms, it suffers major congestion. The transport assessment supporting these
sites around the town, generally suggests that increased bus services could be used to
provide connectivity, however in a congested road system, these provide unreliable
journeys and are unlikely to be acceptable by many. Therefore the TTG does not support
these Strategic Growth areas, particularly SG19, which would be remote from any significant
employment options and therefore require trips through the town to access employment
and sustainable transport commuting.

Other

ID sylw: 107628

Derbyniwyd: 06/03/2025

Ymatebydd: Napton Parish Council

On balance, the approach set out in the draft plan seems reasonable, noting it is to respond to the required numbers dictated to the Council by the standard method imposed by central government. It should be ensured that growth happens in a sustainable and sensible way, with any new housing and commercial development accompanied by necessary infrastructure.

Although sites F1, F2, and F3 are near a railway, we do not believe that new railway stations between Banbury and Leamington are likely viable, economic, practical or realistic and no evidence has been provided to suggest otherwise. The effect of these sites would be to generate unacceptable road traffic towards the M40 junction.

The Southam area has already experienced excessive housing growth, and the road network is poor. The Gaydon M40 Junction has pulled far too much traffic from local roads towards a junction never intended to serve those areas calling into question SG13, SG14 and G1. Any commercial development should be true employment land and not large warehousing for imported goods.

Other

ID sylw: 107651

Derbyniwyd: 26/02/2025

Ymatebydd: Laura Newberry

We support developments that:

1. Are close to major towns and cities, as we believe clustering around centres that already have established institutions (e.g. universities, R&D centres, cultural activities) offer better growth opportunities.
2. Can sustain additional development proportionate to the likely growth prospects for the area.
3. Have access to a range of transportation options, not just road.
4. Do not fundamentally change the character of the surrounding area.


We support development in locations best positioned for good transport links being well served by road and especially rail networks. By good transport links, as an absolute minimum ‘A’ roads should be directly accessible.

We support developments with easy access to larger settlements such as Birmingham and Coventry where they are easily accessible for work and leisure.

We support developments which utilise HS2 – settlements and industry could access and help to justify this rail link.

We encourage selection of sites not to be too heavily weighted towards major roads, especially the M40. This is very short-sighted given the preferred plan is designed to satisfy demand for homes until 2050. Such a narrow focus restricts the number of sites
available for expansion whereas consideration now of investments in rail and tram
networks would give the councils far greater scope.

The statement in the plan wants to reduce reliance on cars. We believe that sites selected should support this goal and use existing rail links, improve rail links and build tram etc links to those rail links. Easy and sustainable connections to the larger settlements/cities is likely to offer significant growth opportunities and employment prospects for Warwickshire residents.

No

ID sylw: 107733

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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.
The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
In order to accord with national policy, the SWLP should be planning for a minimum of 2,188 dwellings per annum across Warwick and Stratford Districts. The HEDNA (2022) should be updated to reflect this updated starting point and assess the need for the SWLP to plan for higher growth.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.

No

ID sylw: 107785

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

No as the NPPF says that the Standard Method represents the minimum local housing need that should be planned for. The SWLP should plan for 2,298dpa or 57,435 over the plan period as a minimum. Catesby Estates strongly submits that the Councils should plan for a greater level of growth than this in order to meet affordable housing need and maintain previous levels of economic growth. The 'to find' figure ought to be a minimum of 28,257 dwellings with a 5% buffer applied (29,670 dwellings). This assumes that the windfall estimates of 375dpa is accurate and robust.

No

ID sylw: 107786

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.
The HEDNA (2022) sets out a housing need of 41,975 dwellings for the 25-year plan period. This document was prepared over 2 years ago and does not reflect the recent changes to the Standard Method (December 2024). The Standard Method identifies a minimum housing need of 54,700 dwellings over the plan period. The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.

No

ID sylw: 107796

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.
The HEDNA (2022) sets out a housing need of 41,975 dwellings for the 25-year plan period. This document was prepared over 2 years ago and does not reflect the recent changes to the Standard Method (December 2024). The Standard Method identifies a minimum housing need of 54,700 dwellings over the plan period. The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.
Table 5 sets out a list of proposed Strategic Growth Locations (‘SGL’). Bellway’s land is included as part of the proposed SGL SG19 ‘East of Stratford-on-Avon’. Bellway strongly supports the proposed allocation of SGL SG19 and their land interests. Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon). This land is not constrained by Green Belt and is in a highly accessible location adjacent to a Growth Settlement and in close proximity to the most sustainable settlement in Stratford district.

No

ID sylw: 107807

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction seems to suggest this is the maximum number of homes. Additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall allowances should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. The latest analysis from Landstack indicates that using the new Standard Method results in a supply of just 2.96 years. Following a recent appeal decision it has been confirmed Warwick District does not have a five year land supply. Specific deliverable sites must be allocated for housing in South Warwickshire to ensure supply of housing over the plan period and particularly the five years following adoption or the Councils risk speculative applications outside of the preferred spatial strategy.

We support identification of Priority 2 and 3 areas given the limits to capacity for brownfield development. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all of the strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Land South of Main Street, Tiddington is part of SG19 and Priority Area 2 and we support its inclusion.

No

ID sylw: 107834

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey have concerns with regards to the approach set out within Draft Policy Direction 1. Whilst it is appreciated that the Draft Plan has been prepared against the backdrop of changing national policy the approach as set out is not justified based on the new National Planning Policy Framework (‘NPPF 2024’), which along with the accompanying Planning Practice Guidance (PPG)2 [2 Ministry of Housing, Communities and Local Government (2024) Planning Practice Guidance]– sets out the Government’s planning policies for England.
The emerging Plan as drafted, whilst acknowledging the outcome of the standard method, introduces uncertainty by also referencing housing need figures calculated prior to the publication of the NPPF 2024 within the 2022 Coventry and Warwickshire Housing and Economic Development Needs Assessment (HEDNA).
Draft Policy Direction 1 should therefore be redrafted to include
‘The South Warwickshire Local Plan will make provision for the delivery of at least 2,188 dwellings per annum, this being the minimum need calculated using the standard method. This equates to at least 54,700 dwellings over a 25-year plan period from 2025 – 2050’

Other

ID sylw: 107893

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Terra welcomes that the PO acknowledges the SWA’s housing needs under the revised
Standard Method [SM] – see Table 4, whilst the PO refers to the housing needs established
in the ‘Coventry & Warwickshire Housing & Economic Development Needs Assessment
(HEDNA) (November 2022)’ (“the HEDNA”),
2.7 As the SWAs will be aware, the Government recently revised NPPF and SM for the
calculation of housing needs in December 2024. The proposed new SM significantly
increases the housing needs for the SWAs when compared to the HEDNA – as identified in
the PO, with the SWLP having to identify a further c.12,725 dwellings to meet these needs
when compared to the HEDNA’s objectively assessed housing needs [OAHN].
2.8 Notably, paragraphs 234 to 236 of the NPPF are clear that Local Plans that do not reach
Regulation 19 by the 12th of March 2025 and are planning to meet at least 80% of the local
housing need [LHN] figure generated by the revised SM, would be required to take full
account of the revised NPPF policies, in addition to the updated LHN figures generated by
the revised SM.
2.9 When taken together, and given the SWA’s working timetable for the SWLP, it is clear that
the SWAs will need to plan for the revised SM figure through the SWLP.
2.10 This is because the NPPF is clear that the overall aim of Local Plans should be to meet an
area’s identified housing need in full (Para 61) generated by the revised SM (Para 62), as the
SWLP will not have reached Regulation 19 by the 12th of March 2025. To this end, Terra
considers that the SWAs should seek to address the c.2,188 dwellings per annum [dpa]
LHN generated by the revised SM – or c.54,700 dwellings over the 2025 to 2050 plan
period within the SWLP for the period to 2050.
2.11 However, Terra would also highlight to the SWAs that it is expected that Local Plans should
be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a housing
trajectory has sufficient land supply across the plan period so that it can adjust and
accommodate any unforeseen circumstances, such as a degree of flexibility in delivery rates
and densities. This means that to achieve a housing requirement a Local Plan must release
sufficient land or allow ‘headroom’ so that there is an appropriate buffer within the overall
planned supply.
2.12 As such, in due course, it will be necessary for the SWAs to identify suitable land supply in
excess of the SWLP’s LHN-based housing requirement to ensure that there is the flexibility
to respond to failures to deliver the required dwellings in the allotted time frames and
across the whole plan period.
2.13 This ‘buffer’ should also be in excess of any commitments to addressing unmet housing
needs from neighbouring authorities – discussed further below in Terra ’ response to Draft
Policy Direction 4. This is because if any single component of supply does not come forward
or falls behind the timescales implied by the SWAs, this would result in the unmet housing needs not being delivered. Therefore, Terra would recommend that a minimum of c.20%
headroom should be incorporated into the SWLP proposed housing supply.

Strategic Growth Locations
Given the scale of the SWA’s emerging housing needs under the new SM and the need to
make a contribution towards the unmet housing needs of the GBBCHMA, Terra strongly
supports the proposed ‘Sustainable Travel and Economy’ Spatial Growth Strategy. This is
because it will best promote sustainable patterns of development across the area and align
with the sustainability aspirations that are set out in the NPPF and SWLP Vision and
Objectives.
2.15 Ultimately, whilst greater levels of development may need to be focussed around the Main
Urban Areas, due to the level of infrastructure and services already present, it will also be
necessary to direct growth to other settlements to ensure that the benefits of housing
growth can be delivered in other parts of South Warwickshire to meet the need for new
housing.
2.16 Terra consider that there are several benefits to a mixed approach, to the distribution of
development:
1 It would support the well-being of those settlements that have the capacity to
accommodate growth;
2 By concentrating development around existing and proposed new employment
development and infrastructure, it would also ensure that it benefits from a sustainable
location with good access, such as at SG14 Gaydon/ Lighthorne Heath. Draft Policy
Direction 14 identifies this location as a Major Investment Site which follows the
findings of the South Warwickshire Employment Land Study (2024). The delivery of
additional jobs in this location will further enhance the important role of Gaydon as a
focus for economic growth within this part of South Warwickshire. This will create a
parallel demand for new homes and which Terra consider should be located in close
proximity, in order to ensure that sustainable patterns of growth are created and to
avoid unnecessary inward commuting from other part of South Warwickshire.
3 It can ensure that a sufficient supply of homes, within close proximity to existing and
future employment opportunities, such as those at Gaydon, contributes to an efficiently
functioning economy. This can also aid in minimising housing market pressures and
unsustainable levels of commuting (and therefore congestion and carbon emissions);
and
4 It would enable growth to meet the needs of neighbouring authorities to be located in
an area in close proximity to where these needs arise. Similar to the above, this also has
the added benefit of minimising housing market pressures and unsustainable levels of
commuting (and therefore congestion and carbon emissions).
2.17 Indeed, the NPPF is clear that planning policies should identify opportunities for
communities to grow and thrive, especially where this will support local services (Para 83).
Directing growth to existing settlements supports local services and also ensures
development is located sustainably in line with the NPPF (Para 11a). Existing settlements
often have access to education, healthcare, retail, jobs, and public transport, and should
therefore be considered as ideal locations for growth. Further growth can also broaden the
scope for these settlements to seek improvements to services and infrastructure, helping to address imbalances between the rural and urban areas in terms of provision and access to
facilities.
2.18 To this end, the NPPF is clear that planning policies and decisions should be responsive to
local circumstances and support housing developments that reflect local needs (Para 82).
Terra considers that the development on the edge of SG14- East of Gaydon and particularly
the Terra Site at Spring Farm) lends itself well to achieving these objectives, particularly
given the fact that the site is well-located in order for residents to access a range of key local
amenities and facilities. As such, Terra strongly considers that the SWLP should direct
growth to SG14- East of Gaydon in the SWLP.

No

ID sylw: 107926

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction seems to suggest this is the maximum number of homes. The NPPF is clear that the Standard Method establishes the minimum number. Treating this as a minimum would pose no issues for deliverability of the plan as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years.

Land at Thickthorn, Kenilworth is within Priority Area 1. We support prioritising brownfield land. However, we note the findings of the Urban Capacity Study which suggest brownfield can meet only 11% of the minimum housing need over the plan period. The acceptable uses of brownfield land should be more flexible to ensure it is brought forward for development. The site can be delivered early in the Plan period which would assist Warwick DC in providing much-needed housing given its current lack of 5 year land supply.

No

ID sylw: 107937

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. Therefore the presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to brownfield capacity identified in the Urban Capacity Study. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Darlingscote Road, Shipston-on-Stour is within SG17 and it is a priority 1 Area to which growth should be directed. It is sustainably located, available, achievable, and deliverable, It performs better than other parcels in the SGL as it close to services and has low flood risk.

Other

ID sylw: 107960

Derbyniwyd: 26/02/2025

Ymatebydd: Earlswood & Forshaw Heath Residents’ Association

The first question that we would then be asking is – “Do we actually need 35k new houses during the period of this plan?”. It’s not obvious that the answer to this question is “yes”, based on previous reviews, including that for the current SDC Core Strategy Plan, which indicate that the answer is probably “no”. Previous evidence indicates that housing is preferred to be built in the major cities and conurbations, rather than the countryside.

Other

ID sylw: 107975

Derbyniwyd: 02/03/2025

Ymatebydd: Abigail Young

The Local Plan's own Sustainability Appraisal shows that:
• Strategic Growth Locations which are NOT in the green belt have capacity for 48,500 dwellings (Table 5.1).
• New Settlements which are NOT in the green belt have capacity for a further 6,000 dwellings (Table 6.1).

This means that it is possible to meet housing need without building on green belt land. Sufficient capacity exists at Strategic Growth Locations outside the Green Belt to meet the Local Plan dwelling requirements to 2050. Therefore, exceptional circumstances cannot be met to release green belt sites to meet the housing requirements of Warwick District and Stratford on Avon District.

No

ID sylw: 107999

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG 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.
Draft Policy Direction 1 looks to the Coventry and Warwickshire Alignment Paper (2024) which brings together the HEDNA (2022) and WMSESS (2024) to identify employment land residual needs. For up to 2050, the policy identifies a residual need of 217 ha. For strategic industrial, the policy identifies a residual need between 75-125 ha up to 2045 to include 1-2 mixed/ B8 sites and 0-1 B2 sites within Road Opportunity Area 8 along the M40/A46. Given the need for strategic employment identified within the WMSESS only covers the period up to 2045, CEG request that the need figure is uplifted to cover the SWLP plan period to 2050. The strategic site period spans 23 years therefore in lieu of commissioning additional evidence, CEG advise that the 125ha need figure identified by the Alignment Paper be subject to a 25% uplift which would take the total need for the plan period to approximately 156ha.
Junction 12 is excellently placed to accommodate the above employment need within Road Opportunity 8 Area as set out within these representations.

No

ID sylw: 108005

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. Therefore the presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to brownfield capacity identified in the Urban Capacity Study. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

No

ID sylw: 108032

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from 30 to 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. The presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to brownfield capacity identified in the Urban Capacity Study. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all SGLs areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Growth should also be directed towards other villages capable of accommodating development such as Ettington. Land South of Banbury Road is within Priority Area 3, demonstrating the site is sustainable and suitable. It performs well when individually assessed against the SA framework.

No

ID sylw: 108037

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

With regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire, and opting for this higher figure would not undermine the effectiveness of the plan.

The Site at Birmingham Road is located in a Strategic Growth Location, identified as ‘West of Stratford upon Avon’ reference SG18. The Site is sustainably located and is suitable, available, achievable and deliverable, with it being capable of accommodating a high-quality residential development on land that is immediately adjacent to the settlement edge to the south and would effectively ‘round-off’ the settlement up to the A46 on the Site’s northern boundary.

No

ID sylw: 108040

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction seems to suggest this is the maximum number of homes. Additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall allowances should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. Therefore the presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to capacity for brownfield development. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all of the strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Growth should also be directed towards other villages capable of accommodating development such as Long Itchington.

No

ID sylw: 108049

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. The presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to brownfield capacity identified in the Urban Capacity Study. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Land at Walton Road, Wellesbourne forms part of SG16 Priority Areas 1. We support inclusion and Priority Area designation, which highlights the Site is sustainably and suitably located for growth in alignment with the spatial strategy. Development would assist with sustaining facilities and services in Wellesbourne, a smaller settlement. SG16 has been assessed against the SA Framework and generally performs favourably.

No

ID sylw: 108058

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

With regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire. Therefore, opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

. The policy direction suggests that there are 17,068 existing commitments which will form part of the supply over the plan period.
In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.40-year housing land supply at the present time.
Stratford District Council claim to have a 24.65-year housing land supply as of 1st April 2024, as set out in their Information Sheet dated 16th October 2024. We strongly dispute the assertion that the Council can demonstrate this level of supply at the present time.
If the Core Strategy is out of date, the five-year housing land supply for Stratford needs to be measured against the housing need calculated using the Standard Method, in accordance with the PPG. The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase).
4.14. Regardless of the current land supply Stratford have published, for the emerging SWLP, there is a minimum local housing need of 1,126 dpa, which equates to a need for at least 5,630 homes over the period 2024-29. The latest assessment by Stratford suggests that 3,505 homes will be delivered from 2024-2029, meaning there is a demonstrable substantial need for 2,125 homes irrespective of the housing land supply position. It also equates to a five year supply of just 3.11 years if the published land supply figures are taken as read.
. It is also important to emphasise that both Stratford and Warwick’s calculations are based on a number of assumptions regarding deliverability. The housing land supply figures may reduce further if sites do not deliver as expected, permissions expire without being implemented, or fewer windfall sites come forward than expected.
When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply (3.11 years and 4.40-years respectively), and as such the presumption in favour of sustainable development will apply, which may lead to a substantial number of speculative planning applications in locations which the Councils do not consider favourable for growth under the selected spatial strategy. Any under-delivery which may occur would result in an even lower supply. Specific and deliverable sites must be allocated for housing across South Warwickshire to ensure that there can be a steady supply of housing in Stratford and Warwick over the plan period, and certainly for five years following adoption, in line with Paragraphs 72 and 78 of the NPPF.
The Councils express a preference to concentrate growth on brownfield sites, Priority 1 areas, prior to considering development elsewhere. However, it is important to emphasise that there is insufficient previously developed land within South Warwickshire to accommodate the level of housing required. Indeed, the Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – just 11% of the minimum housing need required over the plan period (54,700 dwellings). As such, the study concludes (on page 37) that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (emphasis added).
The identification of a myriad of Priority 2 and 3 areas, where development can occur in accordance with the spatial growth strategy, is supported, to ensure that needs can be fully met. Proportionate growth directed away from brownfield sites to settlements which are comparatively smaller than Stratford, Warwick, and Leamington Spa will also support their viability and vitality, whilst providing opportunities to enhance sustainable travel options at these locations, resulting in positive impacts on transport and accessibility (SA Objective 11), as acknowledged in Appendix E of the SA, paragraph 3.1.6.
Twenty-four Strategic Growth Locations are identified, twenty-one of which would accommodate housing. It is stated that these locations could accommodate development which exceeds South Warwickshire’s housing need; The Councils suggest that allocations will not be made in all areas given that this exceeds their housing requirement. It is agreed that allocating land for 74,521 dwellings would be excessive, since the evidence is unlikely to justify this, and the plan must be deliverable. Notwithstanding, the Councils clearly have an opportunity to allocate some additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher-growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.

No

ID sylw: 108059

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. The presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given limits to brownfield capacity identified in the Urban Capacity Study. This will help support viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Land at Russells Garden Centre, Mill Lane, Baginton is within Spatial Growth Priority Area 2 and whilst not in an SGL it is to the northeast of SG03 Coventry Airport Group for employment. A highly sustainable location combined with excellent access to existing employment opportunities and future employment growth in the immediate locality means it is an excellent Site for allocation. Whilst the Site is within Green Belt it aligns with the proposed Spatial Growth Strategy, which seeks to prioritise development of brownfield land. The Site is partly previously developed land. The remainder meets the definition of grey belt land. Baginton was identified as a Growth Village in the 2017 Warwick Local Plan and is already established as a sustainable location for housing growth. Housing site H19 (a greenfield site) was identified to deliver approximately 80 dwellings and now has outline consents (W/22/1038 and W/20/0808) totalling 119no. dwellings. This highlights Baginton's suitability for housing growth and strong deliverability of allocations in Baginton.