No

ID sylw: 108109

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

As per the December 2024 NPPF, there is no validity in the SWLP responding to the HEDNA derived housing need figure. It must take as a baseline the new Standard Method derived figure of 2,188 units per annum (combining the figures for Stratford on Avon and Warwick DC). Accordingly, 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.
• Windfall Development
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.
Such an overreliance on windfall provision is simply unacceptable and would render the SWLP unsound. Leaving almost one fifth of housing land supply to chance is not plan-led. As such, additional allocations are required to respond to housing need. Furthermore, the identified quantum of windfall housing fails to incorporate a lapse rate and is taken from 2025 rather than from the anticipated Plan commencement date, effectively resulting in double counting. In our view, the inevitable consequence of these matters is to further compound the need for the identification of additional site allocations in the face of likely shortfall of provision.

No

ID sylw: 108116

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates 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policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum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.
It is critical to ensure that a sufficient amount of housing is planned for in the SWLP Part 1. When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply, 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.
Catesby land interests at Oaks Farm and Warwick Road form part of the ‘South of Kenilworth Group’ Strategic Growth Location (SG04). Its including is strongly support. The Site falls within Priority Area 2, which highlights that this is s sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. SG04 has been assessed against the SA framework and performs generally favourably against the objectives, and certainly more favourably than some of the other proposed Strategic Growth locations.

Yes

ID sylw: 108155

Derbyniwyd: 07/03/2025

Ymatebydd: IM Properties Development Ltd (IMP)

Asiant : Turley

The approach laid out in Draft Policy Direction 1 is supported.
This is based on the premise that the South Warwickshire Local Plan (SWLP) will plan for
“at least” the following employment land need in Stratford-on Avon, as documented in
Table 4 of the Preferred Option Paper:
• A residual (net) non-strategic industrial need of 139 hectares between 2021-50.
• A residual (net) office need of 3 hectares between 2021-50.
This in addition to the South Warwickshire wide residual (net) strategic industrial site
need of between 75 and 125 hectares over the period 2021-45. It is noted that the SWLP
will use the upper threshold of the 125 hectares, as recommended by the West Midlands
Strategic Employment Site Study (WMSESS) (2024). This is welcomed.
Figure 8 of the Preferred Options Paper helpfully outlines the evidence used to support
the definition of the employment land need in South Warwickshire. IM Properties
Development Ltd (IMP) consider the scope of evidence relied upon is right with
particular support for the conclusions of the WMSESS and Coventry & Warwickshire
Alignment Paper (2024), which apportions need from the strategic level to the local level.
This approach has been missing in plan-making in Warwickshire for more than a decade,
and its return via the alignment paper is welcomed.
Furthermore, the explanatory text to Table 4 rightly sets out:
“Strategic sites in this context refer to large scale employment sites typically over 25
ha and largely dedicated to units of over 9,300sqm (100,000sqft). Non-strategic (or
local) need refers to industrial (B2/B8 class) uses to meet a local need, generally for
units under 9,300sqm (100,000sqft) but also for units over 9,300sqm (100,000sqft)
where these are located on non-strategic sites (<25 ha)..”
IMP take this opportunity to confirm Stratford 46 - which is subject to a hybrid planning
permission (Ref: 19/01402/OUT) and is allocated under the reference Proposal SUA.2 in
the Stratford-on-Avon Core Strategy, and it is a draft policy in the emerging Stratford-onAvon Site Allocations Plan (SAP) - has the capacity to address both the strategic and local
industrial need.
The above is based on the site area measuring 25 hectares and its spatial layout affording
the ability to deliver a range of unit sizes either below or above 9,300m². This flexibility
should be viewed favourably by Stratford-on-Avon District Council, especially in the
context of the Core Opportunity Area and selection of Major Investment Sites (the Draft
Policy Directions for these are responded to separately).
IMP welcome a discussion with Stratford-on-Avon District Council to explore how
Stratford 46 can better respond to the latest evidence on employment land need,
including that relating to industrial and logistics need.

No

ID sylw: 108159

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We object to Draft Policy Direction 1.
As drafted, 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.
As such, the SWLP should be taken forward having regard to Table 3 (Housing calculation 2024 NPPF Standard Method), which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.
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.
In terms of the Strategic Growth Location (SGL) options, the Emerging Spatial Growth Strategy Paper November 2024 proposes 24 locations identified for potential strategic growth. At this stage, to be able to consider reasonable alternatives, the identified strategic growth locations could accommodate significantly more land for employment and housing need, and it is not anticipated that all areas will be allocations within the SWLP. It is expected that the SWLP evidence base will continue to grow while the plan is being drawn up, and there are a number of key pieces of evidence expected after the Preferred Options consultation which will further inform the eventual selection of sites for allocation -this will include the Sustainability Appraisal, Estimation of Emissions, Green Belt review and Infrastructure Delivery Plan.
A Sustainability appraisal for this Reg 18 consultation has been undertaken, and the SGL’s have been assessed for likely impacts on the 13 SA objectives (all currently desktop) as follows:
SA Objective 1: Climate Change- no single SGL can be identified as the best or worst option for climate change due to limitations of current information.
SA Objective 2: Flood Risk – the majority of SGLS are predominantly located on greenfield land and likely to lead to loss in vegetation coverage and permeable soils which contribute to capturing rainwater and slow run-off rates. SG18 is not currently identified within the best


performing option (Coventry Airport and East of Lillington) or the worst performing option, West of Warwick.
SA Objective 3: Biodiversity, Flora, Fauna and Geodiversity – all SGLs have potential to result in adverse impacts on biodiversity. 5 SGL’s including West of Stratford-upon-Avon (SG18) lie withinclose proximity to a SSSI (within the IRZ) which indicates that consultation with Natural England will be required prior to development. SG18 is also located within close proximity to a LNR which is likely to adversely impact upon them. All SGLs coincide with LWs and have the potential to result in the direct loss and/or degradation of these habitats. The worst performing option is South of Coventry SGL.
SA Objective 4: Landscape – the majority of SGLs have potential for adverse impacts on landscape. Coventry Airport is considered to be the best performing option and West of Studley is expected to be the worst performing.
SA Objective 5: Cultural Heritage – All SGLs will have potential to result in adverse effects on heritage features and settings of conservation areas. The best performing is East of Gaydon, and the worst Southeast of Whitnash.
SA Objective 6: Pollution - All SGLs are identified to result in adverse effects to some extent with the exception of East of Lillington. The East of Stratford-upon-Avon (SG18) and West of Stratford-upon-Avon slightly coincide with the Stratford-upon-Avon AQMA, whilst the Coventry Airport and South of Coventry SGL’s lie adjacent to the Coventry AQMA. 20 SGLS are located within 200m of a main road and the West of Stratford-upon-Avon, and 4 other SGLs are located within 200m of a railway line within may impact end users in terms of noise and air pollution. The best performing option is identified as East of Lillington, and the worst is West of Stratford. This SGL lies in proximity to the AQMA, and A roads leading to the town centre and could hence worsen poor air quality within the AQMA.
SA Objective 7: Natural Resources – all 24 SGLs are expected to result in adverse impacts. 23 of SGLs comprise of land of Grade 3 and above. 23 also coincide with Mineral Safeguarding Areas. Coventry Airport is identified as the best performing option, with Bidford-on-Avon identified as the worst performing option.
SA Objective 8: Waste – the large scale residential-led development across the Plan area is likely to result in an increase in waste. No single SGL can be identified as best or worst option at this time.
SA Objective 9:Housing – all 21 residential-led and mixed-use SGLS are likely to result in a significant net gain in housing. There is currently limited information available to form ranking against this objective.
SA Objective 10:Human Health – all 24 SGLs are likely to have adverse impacts on access to one or more health receptors. 17 SGLS are located beyond 5km to a hospital with A&E services. 20 SGLs are located beyond the 800m sustainable distance to an existing GP surgery. 18 are located outside of a 1.5km distance to leisure facilities. The West of Studley SGL is identified as the best performing option with East of Gaydon the worst performing option.
SA Objective 11: Accessibility – Mixed effects have been identified against this option. East of Lillington has been identified as the best performing option for accessibility and the North of Wellesbourne and Alcester SGLS being joint worst options.
SA Objective 12: Education – all 21 SGLs with residential capacity are identified to result in negative impacts on sustainable access to education based on existing school provision. The best performing option is West of Studley and North of Leamington, the worst is East of Gaydon.
SA Objective 13: Economy: - positive effects are expected on the economy from the majority of SGLs. All except North of Henley-in Arden are located within 5km of an existing key employment location.

Other

ID sylw: 108185

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

The SWLP’s Housing Needs
2.7 Whilst the PO refers to the housing needs established in the ‘Coventry & Warwickshire
Housing & Economic Development Needs Assessment (HEDNA) (November 2022)’ (“the
HEDNA”), St Philips welcomes the PO acknowledging the SWA’s housing needs under the
revised Standard Method [SM] – see Table 4.
2.8 As the SWAs will be aware, the Government recently revised NPPF and SM for the
calculation of housing needs. The proposed new SM would significantly increase 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].
2.9 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.
2.10 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. 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, St Philips 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.
2.11 However, St Philips 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. Critically, this means that to achieve a housing requirement a Local Plan
must release sufficient land or allow sufficient ‘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. Importantly, this ‘buffer’ should also be in excess of any
commitments to addressing unmet housing needs from neighbouring authorities –
discussed further below in St Philips’ 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,
rather than the SWLPs. Therefore, St Philips would recommend that a minimum of c.10-
20% headroom should be incorporated into the SWLP proposed housing supply.

Strategic Growth Locations
2.13 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, St Philips 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. 2.14 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. In particular, St Philips consider that there are several benefits to a mixed approach, which includes Green Belt release, 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 infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the SWAs to capitalise on opportunities presented by existing or planned infrastructure when considering options for large-scale new residential developments, in accordance with paragraph 77a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent with paragraph 148 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well served by public transport (Paragraph 147); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, 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 5 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).

Approach to achieving net zero
2.33 As noted above, St Philips’ Vision for the Site ensures that the development could deliver on
the SWLP’s Vision and Strategic Policy Objectives in relation to delivering sustainable
growth and combating climate change. Further information on how St Philips proposes to
achieve this is set out in detail in the supporting Vision Document (Appendix 1).
2.34 However, in short, the Site could deliver a suite of ecological and green infrastructure
improvements throughout the proposed development, ensuring a 10% Biodiversity Net
Gain [BNG] alongside blue-infrastructure enhancements and a c.9 ha Country Park. When coupled with a fabric-first approach to the build specification that will ensure that new
homes will reduce heat waste and incorporate low-carbon energy generation technologies,
and electric vehicle charging points, the Site is well placed to assist the SWAs in achieving
Net Zero.

Mitigation of issues identified through the SA
2.35 Based on the SA conclusions, SG24 broadly ranks in the middle out of twenty-four SGLs in terms of best and worst-performing SGLs against the Sustainability Appraisal [SA] objectives, set out in the ‘Interim Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Preferred Options Stage’. However, it is considered that these matters are resolvable through appropriate mitigation – indeed, as stated within the SA: “Mitigation has not been considered when ranking the SGLs, given the options requiring less intervention are likely to be more sustainable choices.” However, St Philips have set out below how the Site could mitigate against any of the impacts identified within the SA: [See attachment]
Further technical work can be provided to the SWAs to demonstrate that the Site could mitigate any negative impacts arising from development.

No

ID sylw: 108260

Derbyniwyd: 07/03/2025

Ymatebydd: Sovereign Man Simon of the family Thomas

Policy 1 - Housing
Iam 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 must not disregard the Environment Act 2021 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.
Iam 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 have not done individual Flood Assessment work (SFRA part 2s), which should be carried out in order to help choose sites.

No

ID sylw: 108268

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. Both the policy and its supporting text require amending.

Other

ID sylw: 108277

Derbyniwyd: 05/03/2025

Ymatebydd: David Kinnesley

Asiant : Fisher German

2.1 The Council’s proposed approach is to meet the provisions of the 2024 NPPF through a flexibility allowance (2,188 dwellings per annum), but the Plan seems to adopt a lower housing requirement of only 1,679 dwellings per annum, which is derived from the HEDNA (November 2022) (which is already out of date having regard for the PPG which allows a 2 year period). For the avoidance of doubt, given the Plan has almost certainly missed the transitional arrangements, the housing requirement must at the very minimum be the Local Housing Need figure of 2,188 dwellings per annum. It is not appropriate or in compliance with the NPPF to cover off Local Housing Need through supply but not the adopted housing requirement, unless the Council is advancing an exceptional circumstances argument.

2.2 Paragraph 11 of the NPPF (2024) affirms “strategic policies should, as a minimum, provide for objectively assessed needs for housing”. Paragraph 69 states 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 that cannot be met within neighbouring areas) can be met over the plan period. The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment” [our emphasis].

2.3 It is not sound to identify a housing requirement below Local Housing Need (without an exceptional circumstances argument), justified through having sufficient supply to meet Local Housing Need. If there is sufficient supply to meet the housing requirement, it is considered highly unlikely exceptional circumstances could exist which would justify an alternative approach, particularly having regard to historic delivery rates (discussed below) and the impetus on uplifting housing delivery endorsed by the most recent framework.

2.4 The housing requirement must therefore be clear it is a minimum of 2,188 dwellings per annum, or 54,700 dwellings over the Plan period derived from the Standard Method, not the now out of date requirements derived from the HEDNA. This is required as a matter of soundness, not least ‘Positively prepared’, which the NPPF prescribes as “providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs”; but also consistent with national policy having regard for paragraphs 11 and 69 as provided above.

2.5 However, in accordance with the NPPF and PPG, it is necessary to consider whether the housing requirement should be Local Housing Need, or a figure in excess of Local Housing Need. This uplift can be derived for numerous factors, including seeking to increase economic growth, affordable housing delivery, or relating to opportunities arising through the delivery of strategic infrastructure. The Iceni Paper ‘Advice on Housing & Employment Land Needs’ (February 2024) affirms that that 2,808 dpa may be required in South Warwickshire utilising a 5-year migration scenario, and Table 6.10 indicates that at least 2,772 dpa is needed to meet the total affordable housing need. The Council’s own evidence is clear that if there is to be movement from Local Housing Need, it is likely to be higher, not lower as currently proposed.

2.6 The PPG also advised logically that evidence of higher levels of delivery in previous years can be a strong sign of market need and this should be considered as part of setting the housing requirement. It is noted having regard for the Council’s monitoring papers that the Plan area has exceeded the Local Housing Need figure of 2,188 dwellings per annum 6 out of 8 years, including 2016/17, 2017/18, 2018/19, 2019/20, 2021/22 and 2022/23. It is noted the only year since 2015/16 where housing delivered was below 2,188 dwellings per annum was 2020/21, peak covid years and thus clearly could have been impacted by Covid restrictions. In two years the Council delivered in excess of 2,600 dwellings per annum. These figures strongly suggest that the housing requirement should be increased, particularly given the evidence provided above.

2.7 Another crucially important factor to review is a consideration of unmet need, but this is subject of its own question provided below.

2.8 It is noted that the plan assumes windfall delivery of 9,375 dwellings over the Plan period .This equates to circa 20% of the supply proposed. For such high amount of windfall to be assumed, the Council needs strong evidence both on historic delivery, but also in respect of supply. In respect of historic delivery, regard would need to be had for fluctuating delivery rates. It is noted that the AMR (2022/23) indicates windfall delivery varies significantly from almost a thousand dwellings to below 50 in a single year.

2.9 Windfall redevelopment opportunities are ultimately a finite resource and those sites which are easiest and most appropriate for development will likely have been developed, leaving a pool of more difficult sites less likely to be delivered. Whilst there will be a churn in the supply as sites become available, recent years delivery cannot be guaranteed to be sustainable over a long period. The Council’s need to meet the windfall allowance could result in land which may be suitable to stay in employment or community use for example, being forced for redevelopment as residential, thus permanent loss of existing uses. Whilst windfall allowance rates by definition cannot be wholly predicted, clearly the higher the reliance on the windfall delivery, the higher the risk of plan failure is if sites do not to come forward.

2.10 It is noted that the approach adopted by the Council is that that LHN will be met through essentially additional supply or buffer. Notwithstanding our comments above in relation to the soundness of this approach, it is further worthy to note that when the Council adopts LHN or higher as its housing requirement, it will be necessary still for the Plan to contain a buffer to ensure delivery. In accordance with the NPPF, this should be in excess of 5%, but for contingency should be closer to 20%.

2.11 In terms of spatial strategy, the Council confirmed that it intends to proceed with a ‘Sustainable Travel and Economy’ spatial growth strategy, with three ‘priority areas’ for growth identified. Priority 1 is brownfield land. We do not disagree that brownfield land should be used in the first instance. It is noted that the most recent Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – circa 10% of the minimum housing need required over the plan period (54,700 dwellings), lower when a more sensible housing requirement and buffer is applied. Regardless, even with a lower level of requirement the study concludes that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (Page 37). However, this assumes that all such brownfield sites will actually be deliverable and thus it remains this figure may be lower still. Regardless, even if so there remains significant land to be allocated.

2.12 The Council’s approach is that this land should be allocated predominantly on a selection of the 24-strategic growth locations identified in the Draft Plan and utilising a new settlement. We disagree with this approach. This approach results in a significant overreliance on similar typologies of land, does not provide an adequate housing mix, including the NPPF requirement for sites under a hectare to form 10% of the overall requirement. The Council should ensure it has enabled for reasonable growth throughout the spatial hierarchy to ensure the continued vitality of rural communities, and also ensured it has delivered the requisite supply of land on small sites as per paragraph 73 of the NPPF.

2.13 we do not support any strategy which renders sustainable settlements as unsustainable. Failure to enable sufficient rural growth can result in significant harm to the vitality and viability of key services in the rural area, the impact of rural house pricing and the inability for young people to stay in the communities where they have grown up. Growth of a commensurate scale down the spatial hierarchy is considered to have significant social and economic utility, supporting local services to ensure sustainability is retained

2.14 This conclusion has been reached by a number of a different organisations, including the Country Land and Business Association (CLA) whose publications Strong Foundations (July 2017) and Sustainable Communities: the role of housing in strengthening the rural economy (February 2022) outlines the significant issues for rural communities when described as unsustainable by development plan documents, unduly restricting their growth. The lack of affordable or entry level housing means younger people are often unable to find local accommodation, forcing them to move away from their homes to find suitable accommodation. Moreover, the lack of new development including bungalows or other dwellings suitable for downsizing means many older such will instead remain over occupying larger family homes. The loss of younger people and resulting imbalance of the local population can have issues for service and facility viability, including schools, leading to self-fulfilling cycles of decline, as services, facilities, public transport routes are lost due to lack of development, reducing the sustainability of the settlement, thus resulting in further restricted growth.

2.15 To resist such issues, the CLA advocate strongly for planning policy regimes which do not seek to wholly prevent growth in the rural areas, and that commensurate growth is allowed throughout the spatial strategy. This will not be achieved through this spatial option.

2.16 We also consider there to be issues with market absorption which would be compounded by limiting growth to such restricted geographies, as would be the case through the selection of a limited number of growth options only instead of commensurate growth throughout the spatial hierarchy. Through this approach, the Council can also meet the requirement of Paragraph 73 of the Framework. The Council are advised that the NPPF is clear that ‘strong reasons’ are required in terms of justification when not providing sufficient small sites which given the supply of land in South Warwickshire are not likely to be demonstrable.

Other

ID sylw: 108293

Derbyniwyd: 05/03/2025

Ymatebydd: Bostrom Property LLP

Asiant : Fisher German

The Council’s proposed approach is to meet the provisions of the 2024 NPPF through a flexibility
allowance (2,188 dwellings per annum), but the Plan seems to adopt a lower housing requirement
of only 1,679 dwellings per annum, which is derived from the HEDNA (November 2022) (which is
already out of date having regard for the PPG which allows a 2-year period). For the avoidance of
doubt, given the Plan has almost certainly missed the transitional arrangements which would
allow the above approach to be advanced, the housing requirement must at the very minimum be
the Local Housing Need figure of 2,188 dwellings per annum. It is not appropriate or in compliance
with the NPPF 2024 to cover off Local Housing Need through supply but not the adopted housing
requirement, unless the Council is advancing an exceptional circumstances argument.
2.2 Paragraph 11 of the NPPF (2024) affirms “strategic policies should, as a minimum, provide for
objectively assessed needs for housing”. Paragraph 69 states 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 that cannot be met within neighbouring areas) can be met over
the plan period. The requirement may be higher than the identified housing need if, for example, it
includes provision for neighbouring areas, or reflects growth ambitions linked to economic development
or infrastructure investment”.
2.3 It is not sound to identify a housing requirement below Local Housing Need (without an
exceptional circumstances argument), justified through having sufficient supply to meet Local
Housing Need. If there is sufficient supply to meet the housing requirement, it is considered highly
unlikely exceptional circumstances could exist which would justify an alternative approach,
particularly having regard to historic delivery rates (discussed below) and the impetus on uplifting
housing delivery endorsed by the most recent framework.
2.4 The housing requirement must therefore be clear it is a minimum of 2,188 dwellings per annum,
or 54,700 dwellings over the Plan period derived from the Standard Method, not the now out of
date requirements derived from the HEDNA. This is required as a matter of soundness, not least
5
‘Positively prepared’, which the NPPF prescribes as “providing a strategy which, as a minimum, seeks
to meet the area’s objectively assessed needs”; but also consistent with national policy having regard
for paragraphs 11 and 69 as provided above.
2.5 However, in accordance with the NPPF and PPG, it is necessary to consider whether the housing
requirement should be Local Housing Need, or a figure in excess of Local Housing Need. This uplift
can be derived for numerous factors, including seeking to increase economic growth, affordable
housing delivery, or relating to opportunities arising through the delivery of strategic infrastructure.
The Iceni Paper ‘Advice on Housing & Employment Land Needs’ (February 2024) affirms that that
2,808 dpa may be required in South Warwickshire utilising a 5-year migration scenario, and Table
6.10 indicates that at least 2,772 dpa is needed to meet the total affordable housing need. The
Council’s own evidence is clear that if there is to be movement from Local Housing Need, it is likely
to be higher, not lower as currently proposed.
2.6 The PPG also advised logically that evidence of higher levels of delivery in previous years can be a
strong sign of market need and this should be considered as part of setting the housing
requirement. It is noted having regard for the Council’s monitoring papers that the Plan area has
exceeded the Local Housing Need figure of 2,188 dwellings per annum 6 out of 8 years, including
2016/17, 2017/18, 2018/19, 2019/20, 2021/22 and 2022/23. It is noted the only year since
2015/16 where housing delivered was below 2,188 dwellings per annum was 2020/21, peak covid
years and thus clearly could have been impacted by Covid restrictions. In two years the Council
delivered in excess of 2,600 dwellings per annum. These figures strongly suggest that the housing
requirement should be increased, not decreased, from Local Housing Need and the Council’s
approach is likely to stifle what is a healthy and successful housing market. This squeezing of new
supply could expedite house price growth, disproportionate to wage growth, and could thus result
in lower spending in the local economy and less opportunity for younger people, or those without
existing equity, to stay in the area.
2.7 Another crucially important factor to review is a consideration of unmet need, but this is subject
of its own question answered below.
2.8 It is noted that the plan assumes windfall delivery of 9,375 dwellings over the Plan period. This
equates to circa 20% of the supply proposed. For such high amount of windfall to be assumed, the
Council needs strong evidence both on historic delivery, but also in respect of ongoing supply. In
6
respect of historic delivery, regard would need to be had for fluctuating delivery rates. It is noted
that the AMR (2022/23) indicates windfall delivery varies significantly from almost a thousand
dwellings achieved in some years, to below 50 dwellings in others.
2.9 Windfall redevelopment opportunities are ultimately a finite resource and those sites which are
easiest and most appropriate for development will likely have been developed, leaving a pool of
more difficult sites less likely to be delivered. Whilst there will be a churn in the supply as sites
become available, recent years delivery cannot be guaranteed to be sustainable over a long period..
Whilst windfall allowance rates by definition cannot be wholly predicted, clearly the higher the
reliance on the windfall delivery, the higher the risk of plan failure is if sites do not to come forward.
The windfall rate should be reduced to reflect this historic uncertainty in respect of delivery.
2.10 It is noted that the approach adopted by the Council is that that LHN will be met through essentially
additional supply or buffer. Notwithstanding our comments above in relation to the soundness of
this approach, it is further worthy to note that when the Council adopts LHN or higher as its
housing requirement, it will be necessary still for the Plan to contain a buffer to ensure delivery. In
accordance with the NPPF, this should be in excess of 5%, but for contingency should be closer to
20%.
2.11 In terms of spatial strategy, the Council confirmed that it intends to proceed with a ‘Sustainable
Travel and Economy’ spatial growth strategy, with three ‘priority areas’ for growth identified.
Priority 1 is brownfield land. Whilst the Council concede brownfield land cannot meet all of its
development requirements, the strategy shows a clear preference for brownfield land and as such
the Council should receive positively additional brownfield opportunities such as those associated
with the Arrow Works site.
2.12 It is noted that the Arrow Works site is not a designated employment site and is located in the
highly sustainable settlement of Studley (currently designated as a Main Rural Centre in the
adopted Core Strategy), close to neighbouring Redditch. The site is in close proximity to existing
bus stops on Redditch Road, with further higher frequency services available a short walk away
on Alcester Road. The Alcester Road forms the settlements main street with various services and
facilities in close proximity of the site including doctors, schools, shops, etc. The site is highly
sustainable and suitable for residential development and should be considered positively as part
7
of ongoing site appraisal and allocation work ahead of the next phase of consultation.
2.13 The site’s tenants have not requested a further extension in lease and thus the current use is
anticipated to cease in 2026. We understand the current tenant have been receiving abatement
notices from the council regarding opposition to the noise levels associated with the current
commercial use. As such, the landowners do not see a sustainable future commercial use of the
site, hence their confidence in residential. The Council should thus recognise this opportunity to
end a noise generating use which is causing amenity issues whilst allocating a site which is
predominantly brownfield.
2.14 A call for sites form has been provided. It is noted that this site falls outside of the scope of the
current Call for Sites consultation, but given the site’s context and opportunity, we hope the Council
will take a flexible approach with regards to this submission.

Yes

ID sylw: 108302

Derbyniwyd: 07/03/2025

Ymatebydd: Indurent Propco A3 Ltd

Asiant : Turley

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. No comments are made specifically to the housing requirements set out in this draft
policy direction.
Indurent Propco A3 Ltd (‘Indurent’) supports the councils’ decision to plan to 2050. The NPPF (2024) is clear at paragraph 22
that “strategic policies should look ahead over a minimum 15-year period from adoption to anticipate and respond to longterm requirements and opportunities”.
Meon Vale Business Park falls within ‘Priority Area 1’ on the interactive policies map. The supporting text to draft Policy
Direction 1 states that “three ‘priority areas’ have been delineated which determine areas of land which fall within this
Spatial Growth Strategy, based on proximity to the various elements that form part of the strategy. South Warwickshire's
existing urban areas fall within Priority 1, and full use will be made of suitable urban brownfield land before development is
considered elsewhere” (our emphasis). Indurent supports this intention to focus development towardS suitable brownfield
land (such as the Business Park) before considering development elsewhere.

No

ID sylw: 108311

Derbyniwyd: 07/03/2025

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

Asiant : Nexus Planning

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

No

ID sylw: 108334

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

As part of the SA process, a SA at Preferred Options stage should identify and assess ‘reasonable alternatives’ to the ‘preferred option’ in order to ‘sense check’ and justify the pursuing of the preferred strategy.

There are two issues with this approach used. The first is that the Councils have determined the reasonable alternatives themselves based upon their preferred strategy, rather than the reasonable alternatives being driven by the iterative process of the SA.

The second is that the above ‘reasonable alternatives’ are in fact the preferred development plan options that the Councils are consulting on within the SWLP; there are no alternative to the above strategies. The SA itself is clear that the SA should assess ‘development plan options
and reasonable alternatives’ [emphasis added].

For example, whilst there is no prescribed formula or procedure about which aspects of a local plan require reasonable alternatives, the Councils have not evidenced or justified how they came to the decision to pursue a two-part plan. A reasonable alternative would have been to
consider the sustainability implications of an all-encompassing local plan, inclusive of identifying
non-strategic development allocations, which has simply not been considered or assessed.

The SA suggests that ‘small settlement locations’ inclusive of developments between 50-500 dwellings were considered in the Issues and Options SA, but no explanation is provided within this SA as to why this approach was discounted.

Similarly, in respect of growth options, the Councils have only tested the prevailing standard method at the time of writing (2,188 dwellings or 54,700 dwellings across the Plan period) versus the HEDNA originally produced in 2022. The purpose of both of these methods is to determine the local housing need (LHN) for the Plan area. The SA has not tested the implications of providing growth in excess of this figure, either to boost economic growth or the delivery of affordable housing. This is despite the SA including a sequencing flowchart from the Royal Town
Planning Institute at Figure 3.1, which includes an illustration of alternative amounts of housing to be provided, such as LHN plus a 5% or 10% uplift.

This is a fundamental failing of the SA arising from the pre-determined nature of the Councils’ preferred development strategy.

No

ID sylw: 108336

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

No it is evident that that ‘to find’ figure ought to be a minimum of 28,257 dwellings with a 5% buffer applied (29,670 dwellings). This figure also assumes that the Councils’ windfall estimate of 375dpa across the plan area is accurate and has been robustly evidenced and justified. No evidence has been provided to support this figure
to date.

No

ID sylw: 108347

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

The HEDNA housing requirement does not capture the latest changes to the planning system and the Government’s aspiration to boost housebuilding through recent changes to the Standard Method. This would also not meet need for affordable homes, as highlighted in the Further Advice on Housing & Employment Land Needs study (February 2024) which confirms need cannot be met without provision upwards of 2,000 homes a year.

Both Councils are experiencing a housing affordability crisis. Stratford-on-Avon is the most unaffordable area in the West Midlands.

There is a substantial 81% uplift in the local housing need for Stratford-on-Avon and Warwick (in combination) to deliver a minimum of 2,188 dwellings a year. This will approximately double the amount of the unmet housing need from 15,532 dwellings to 28,257 dwellings. This should be planned for to futureproof the plan and ensure compliance with the NPPF’s sustainability principle.

Other

ID sylw: 108362

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

The SWCs will be aware, that the Government recently revised NPPF and Standard Method
[SM] for the calculation of housing needs. Whilst the PO document refers to the housing
needs established within the ‘Coventry & Warwickshire Housing & Economic Development
Needs Assessment (HEDNA) (November 2022)’ (“the HEDNA”), Mackenzie Miller Homes
welcomes that the PO recognises the SWC’s housing needs under the recently revised SM.
3.2 As identified in the PO, when compared to HEDNA, the new proposed SM would
significantly increase the housing needs for the SWCs, 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].
3.3 It is important to note that paragraphs 234 to 236 of the revised 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.
3.4 Considering the SWC’s timetable for the SWLP, it is evident that the SWCs must
incorporate the revised SM figure into the SWLP. The NPPF mandates that Local Plans
should fully meet the identified housing needs of an area (Para 61) as determined by the
revised SM (Para 62).
3.5 Since the SWLP will not reach Regulation 19 by 12th of March 2025, Mackenzie Miller
Homes believes that the SWCs should aim to accommodate c.2,188 dwellings per annum
(dpa) LHN as per the revised SM, equating to around 54,700 dwellings for the 2025 to
2050 plan period.
3.6 Nevertheless, Mackenzie Miller Homes would like to emphasise to the SWC’s that it is
expected that Local Plans should be sufficiently flexible to adapt to rapid change. In
practice, this involves ensuring that the housing trajectory includes enough land supply
throughout the plan period to adapt to unforeseen circumstances, such as flexibility in
delivery rates and densities. Essentially, to meet housing requirements, a Local Plan must
allocate enough land or provide sufficient 'headroom' to create an appropriate buffer within
the overall planned supply.
3.7 Therefore, in due course, it will be necessary for the SWCs 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.
3.8 Importantly, this ‘buffer’ should also be in addition of any commitments to addressing
unmet housing needs from neighbouring authorities as discussed further below in Mackenzie Miller Homes’ 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
SWCs, which buffers are intended to address this would result in the unmet housing needs
not being delivered, rather than the SWLPs. Therefore, Mackenzie Miller Homes would
recommend that a minimum of c. 20% headroom should be incorporated into the SWLP
proposed housing supply.
3.9 Mackenzie Miller Homes strongly considers that the SWC’s must provide robust evidence to
justify the proposed windfall rate of 375 dwellings per annum. This evidence should include
historical data on windfall site delivery and an analysis of future trends to ensure the rate is
realistic and achievable.
3.10 Furthermore, Mackenzie Miller Homes urges the SWC’s to consider increasing specific
allocations now. This approach would provide greater certainty in meeting housing targets
and reduce reliance on windfall sites, which may not consistently deliver the anticipated
numbers. By allocating more specific sites, the SWC’s can ensure a more reliable and
deliverable housing supply, supporting the overall objectives of the Local Plan.

No

ID sylw: 108374

Derbyniwyd: 05/03/2025

Ymatebydd: Simon Tagg-Wilkinson

The current proposed sites appear at odds with current NPPF as it focuses on green field sites rather than brown field, with some sites clearly inappropriately identified due to there being national monuments at the same location e.g. Roman Fort on the Foss Way. The document whist stating numbers investigations and references to planning policies and national designations and targets such as increasing nature reserves and bio diversity, then identify sites for construction which are identified are nature improvement areas with ongoing investment and improvement programmes. Previous consultations have placed a high value bot for nature and amenity but this has been ignored by placing potential growth sites throughout the South Warwickshire Country Side.

No

ID sylw: 108382

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We object to Draft Policy Direction 1 insofar as reference to the HEDNA, whilst supporting other aspects of the Policy Direction.

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. As such, the SWLP should be taken forward having regard to Table 3, which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.

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: 108388

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate welcomes the Council’s acknowledgement that the revised NPPF issued in December 2024 includes a new method for calculating local housing need and that the draft policy direction takes this into account.

From 12 March 2025 the SWLP must be assessed against the policies relating to plan-making in the revised NPPF. Paragraph 62 is clear that Local Plan policies relating to housing needs should, as a minimum, be based on the revised standard method calculation. This calculation should therefore be used rather than the HEDNA.

The Estate broadly supports the approach of identifying three Priority Areas as shown in Figure 5. We have a land interest within potential new settlement E1 and recognise a hybrid approach to the development strategy is required to ensure needs are met.

However, we wish to add that proportionate and sustainable growth can be delivered at rural settlements within priority areas, particularly Priority Area Three. The Estate own land within Alderminster and Clifford Chase that sit within the Priority Area Three. NPPF Paragraph 73 acknowledges the important contribution small-to-medium sites can make to meeting housing requirements, Paragraph 83 emphasises that policies should ‘identify opportunities for villages to grow and thrive, especially where this will support local services’. Consideration should be given to how sustainable growth of rural communities can help to achieve the forecasted housing need.

It should be made clearer in the next iteration of this draft policy direction that small-to-medium sites can be allocated within Priority Area Three. These could be built out relatively quickly and help the Council achieve a healthy land supply in the first five years of the local plan period.

Other

ID sylw: 108420

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

Morgan Elliot Planning on behalf of Alscot Estate are promoting Land North West of New Road’ Alderminster (ref.ID 648) as suitable for residential development. We note that the site scored 43.40 in HELAA Part B, which is within the most common scoring range of 40-55.

The constraint score for the site was 1.00 for a well-connected South Warwickshire. This should be lower. The site aligns with the chosen Spatial Growth Strategy as it is in Priority Area 3. Alderminster contains services accessible within walking distance of the site. The site’s proximity to Shipston Road provides a direct and safe route to Stratford-on-Avon. The Town Centre and its amenities are within a cyclable distance and 20 minutes by public transport. This is considered a key driver for sustainable development at this location, providing access to an extensive range of services and facilities as well as employment opportunities.

There is national planning policy support to deliver housing in rural areas. Paragraph 83 of the NPPF supports the location of housing where it will enhance or maintain the vitality of rural communities. This is echoed in the PPG for rural housing. Application 14/02372/OUT for 25 dwellings, demonstrates that in the previous plan period Alderminster was judged capable of accommodating residential growth. Development of the site offers the opportunity for affordable housing to be delivered which will retain and attract a younger population, sustaining and enhancing services within Alderminster and surrounding areas.

The site scored 0.50 for ‘Viability and deliverability’ due to site constraints that may cause additional development costs. A viability assessment will accompany a future application to ensure flooding and heritage constraints can be cost-effectively mitigated. The viability and deliverability score should reflect this and be reduced to 0.00.

The site’s greenfield status increased the overall score by 9.0. Development would be carbon neutral and include affordable housing to balance the potential impacts.

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

No

ID sylw: 108431

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

Asiant : Cerda Planning Ltd

We object to Draft Policy Direction 1.

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. As such, the SWLP should be taken forward having regard to Table 3, which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.

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: 108452

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

It is clear that this Plan will be examined against the 2024 NPPF, as confirmed by the transitional arrangement at Paragraph 234 of that document. Therefore, 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. Magdalen College, Oxford’s view is that the Plan must proceed on the basis of the higher NPPF figure to ensure a sound Spatial Strategy.
The publication of the 2024 NPPF was part of the Government’s aims to deliver a universal, ambitious local plan coverage, which is seen as being vital to deliver the Government’s commitments to achieve economic growth and build 1.5 million new homes. It is paramount that the Local Plan sets an ambitious agenda for growth in the district that seeks to allocate sufficient land to accommodate the 54,700 dwellings required by the 2024 NPPF.
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.
It is not clear from the Draft Policy Direction to what extent this Plan will seek to allocate sufficient land to meet the housing target and what
proportion will be left to Part 2 of the Local Plan and Neighbourhood Development Plans (NDPs). Given the scale of the housing need identified by the 2024 NPPF, the approach is lacking in detail and certainty.

The College considers that its site at Goose Lane, Lower Quinton should be considered favourably for allocation in this Plan, as explored further within our representations. Magdalen College, Oxford considers that its site Adjacent to former Long Marston Depot, west of Campden Road (HELAA Refs 273 and 832) should be considered favourably for allocation in this Plan as explored further below.

No

ID sylw: 108457

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

This submission is made on behalf of the Bird Group, in relation to their interests at Land East of Birmingham Road (Site Ref. 482 and part of 408) (hereafter referred to as ‘the Site’).
The Site is located in potential Strategic Growth Locations (SGL) in the emerging plan (ref. SGL 18).
It is considered that the site is deliverable, available and suitable (as previously recognised by Stratford-on-Avon District Council in its emerging Site Allocations Plan) to deliver a high-development that will significantly assist in meeting South Warwickshire’s identified housing and employment need as well as any unmet needs arising from Coventry and from Greater Birmingham and the Black Country.
Draft Policy Direction 1 sets out that 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 is not consistent with the Framework which states at Paragraph 62.
The HEDNA is over two years old (November 2022) and therefore provides outdated evidence, with a housing need figure that is significantly lower than the minimum number of homes set out in the Standard Method. Indeed, the Sustainability Appraisal (December 2024) states at paragraph 4.2.5 that:
‘It is recommended that the HEDNA calculation is updated to reflect the latest population information and trends to determine whether this figure remains fit for purpose.’
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method. The Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (April 2023) identifies a shortfall of some 106,654 dwellings. Whilst this Position Statement is out of date on account of the Local Plan preparation and revisions to calculating housing need through the new Standard Method, it is anticipated that the updated position (which is currently being prepared) will conclude that there is a significant shortfall.
Given the pressing need for additional housing within the Stratford-on-Avon District, the site is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a mixed-use site within the South Warwickshire Local Plan as part of SG18.

Other

ID sylw: 108486

Derbyniwyd: 03/03/2025

Ymatebydd: Lesley O'Connor

Only 36 sites have been mentioned so far for this consultation, presumably other sites, also in the green belt will be earmarked in the next few years. Over development in south Warwickshire can only be to the detriment of existing residents

No

ID sylw: 108497

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Failure to Consider a Dispersed Growth Strategy (Chapter 4)
The Plan relies on large-scale developments, which create isolated estates, overwhelm infrastructure, and reduce community integration. A dispersed housing strategy would:
• Protect rural character by maintaining smaller, sustainable developments within existing towns and villages.
• Reduce infrastructure overload by evenly distributing housing and supporting incremental growth.
• Encourage local developers rather than favouring large national firms.
Conclusion: The Plan should adopt a dispersed housing model, ensuring growth benefits are shared across communities

No

ID sylw: 108502

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

No, by reason of the revisions to the National Planning Policy Framework in December 2024(NPPF) and to the Standard Method - in an attempt to boost housing delivery.
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.
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method.
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 considered that the Site is in a sustainable location and should be included as part of the Spatial Growth Strategy within the Plan.

Other

ID sylw: 108507

Derbyniwyd: 03/03/2025

Ymatebydd: Mrs. Elizabeth Rochford

The South Warwickshire Local Plan, provided by the planning department, clearly shows that there are sufficient non greenfield sites available to accommodate the developments required.
The government has stated that Greenbelt should only be considered where there are exceptional circumstances, as this is not the case, all greenbelt sites should be withdrawn from the SWLP. (see below)
“ The 2018 revisions to the National Planning Policy Framework (NPPF) added the requirement, unchanged in the 2019 update, that exceptional circumstances should be "fully evidenced and justified, through the preparation or updating of plans". It states that, before green belt boundaries are redrawn, an authority must demonstrate that it has "examined all other reasonable options for meeting its identified need for development", including making use of brownfield land, increasing the density of existing settlements and exploring whether neighbouring authorities can help meet its needs.”
Coventry Council only allowed non-Greenbelt land to be put forward in their call for sites. They want to protect the land for future generations, I would like Warwick to do the same.

Warwick Corporate Strategy
To make Warwick District a great place to live, work and visit by improving lives and our environment."
Do you honestly believe building unnecessary on Greenbelt land supports this strategy?

Other

ID sylw: 108515

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

This submission is made on behalf of the Bird Group, in relation to their interests at Wildmoor Fields land (Site Ref. 486 and part of 545) (hereafter referred to as ‘the Site’).
The Site is located in potential Strategic Growth Locations (SGL) in the emerging plan (ref. SGL 18).
It is considered that the site is deliverable, available and suitable (as previously recognised by Stratford-on-Avon District Council in its emerging Site Allocations Plan) to deliver a high-development that will significantly assist in meeting South Warwickshire’s identified housing and employment need as well as any unmet needs arising from Coventry and from Greater Birmingham and the Black Country.
Draft Policy Direction 1 sets out that 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 is not consistent with the Framework which states at Paragraph 62.
The HEDNA is over two years old (November 2022) and therefore provides outdated evidence, with a housing need figure that is significantly lower than the minimum number of homes set out in the Standard Method. Indeed, the Sustainability Appraisal (December 2024) states at paragraph 4.2.5 that:
‘It is recommended that the HEDNA calculation is updated to reflect the latest population information and trends to determine whether this figure remains fit for purpose.’
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method. The Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (April 2023) identifies a shortfall of some 106,654 dwellings. Whilst this Position Statement is out of date on account of the Local Plan preparation and revisions to calculating housing need through the new Standard Method, it is anticipated that the updated position (which is currently being prepared) will conclude that there is a significant shortfall.
Given the pressing need for additional housing within the Stratford-on-Avon District, the site is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a mixed-use site within the South Warwickshire Local Plan as part of SG18.

No

ID sylw: 108521

Derbyniwyd: 07/03/2025

Ymatebydd: Bevan Family

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: 108530

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

The revisions to the National Planning Policy Framework and the Standard Method for calculating local housing need necessitate a minimum of 2,188 dwellings per annum in South Warwickshire. The outdated Housing and Economic Development Needs Assessment (HEDNA) should be updated to reflect current demographic trends, and the true housing need must be thoroughly assessed. Southam is identified as a sustainable location for additional housing growth, with necessary services available. Therefore, the site east of Banbury Road should be allocated for residential development in the South Warwickshire Local Plan.

No

ID sylw: 108535

Derbyniwyd: 07/03/2025

Ymatebydd: Warner Planning

Whilst there is acknowledgement of the ability to deliver dwellings as per the uplift in housing numbers following the revisions to the NPPF, we feel that this should be the minimum figure used within the policy wording.