No

ID sylw: 108161

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We do not support this policy direction and made extensive comments in the last consultation response. Our views have not changed in that new settlements can take years to come forward before housing can be delivered. This can seriously jeopardise the ability of the local plan to deliver both open market and affordable homes across the district for which there is a critical need.

Yes

ID sylw: 108188

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements? 2.37 Yes, St Philips considers that it is clear that the step-change in delivery required to meet the SWA’s SM LHN figures, and any unmet housing needs from the GBBCHMA, will require a suite of new sites to be allocated throughout the SWLP area – including New Settlements. Indeed, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 74), such as New Settlements. 2.38 Importantly, however, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b) and should set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). As such, the SWAs also need to robustly test reasonable alternatives for the spatial distribution of South Warwickshire’s housing needs through the SA process at an early stage. In addition to the above, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 67). 2.39 The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large-scale developments can come forward. In particular, this should include a realistic assessment of the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales.1 2.40 In this context, St Philips would not object to the option of exploring meeting some of the SWA’s needs through a New Settlement but wishes to highlight to the SWAs that sufficient evidence will need to be prepared in support of any future allocation. However, St Philips would note that such forms of development should not be viewed as the panacea for meeting all of the SWLP’s needs. These types of development can take some years to come onstream and begin delivering, and the SWAs will need a spatial strategy that allocates a supporting package of ‘suitable, available, and achievable’ sites at different scales throughout the SWLP area in sustainable locations to ensure that supply can come forward in the earlier parts of the plan period to meet housing needs in the interim.

No

ID sylw: 108262

Derbyniwyd: 07/03/2025

Ymatebydd: Sovereign Man Simon of the family Thomas

No. Warwickshire Wildlife Trust (WKWT) is extremely concerned regarding the allocation of a new settlement and the potential environmental impacts. Local Wildlife Sites, Potential Wildlife Sites, Sites of Special Scientific Interest, designated Nature Reserves and other important sites are incredibly important for wildlife within our natural landscape. It doesn’t appear that the Councils have considered these in the selection of their new settlement locations.
Several proposed settlements in the Local Plan are within existing Green Belt, which if built on would have a negative impact on designated sites and wildlife including protected and declining species at these locations, which act as transitional buffers for nature and would reduce access to nature for people living in urban areas.
Impacted Local Wildlife Sites are listed below:
A1 /2- River Alne LWS, Round Wood and Long Wood LWS, Grove Wood PLWS and Grotton Hill Wood LWS
C1 - Gilbert’s and Claypits coppices, Linnear Woodland LWS
E1 Allocation – This site is very concerningly directly adjoining and Area of Outstanding Natural Beauty, Meon Vale LWS, River Avon LWS and the greenway, dismantled railway, Welford Hill Farm Meadows PLWS, Rumerhill Coppice PLWS and Coxmere Coppice PLWS
BW Allocation - Newfoundland Wood LWS, Stratford Canal PLWS, River Avon LWS and Wood by Churchill
G1 Allocation - Itchington Holt PLWS
Allocation F1 - Long Itchington and Ufton woods SSSI
Allocation F2 - Deppers Bridge Meadow PLWS
Allocation F3 - South Southam LWS and Disused railway LWS.

Yes

ID sylw: 108269

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support recognition that new settlements and expanding settlements are required to meet the housing and employment growth requirements in the most sustainable way. However, these large-scale proposals should be complemented by smaller scale allocations in sustainable locations that are deliverable in the short term.

Other

ID sylw: 108278

Derbyniwyd: 05/03/2025

Ymatebydd: David Kinnesley

Asiant : Fisher German

2.17 Whilst we do not object to the principal of the identification of a new settlement through this Plan, we would urge caution be applied if the Council rely on a new settlements delivery to meet the overall quantum of housing growth necessary over the Plan period. Large scale, freestanding communities are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered.

2.18 Our preferred approach in this scenario is to positively allocate such sites above and beyond the sites needed to meet housing needs, or at worst with highly cautious assumptions in terms of lead in times and annual build out rates. If work is underway and delivery has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which should provide the confidence needed to the market to commit to the works and evidence necessary to obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn’t come forward at all.

2.19 This approach also means the Council retain an element of control, meaning they can ensure the new settlement comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery. If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence and appropriate planning consents, then the Council can begin to rely on delivery as part of its housing figures.

2.20 Given the likely lead in times, assumed in excess of 7 years supported by evidence documents such as Lichfield Start to Finish Volume 3, Saville’s Housing Saville’s Planning and Housing Delivery and the Letwin Review, it is considered unlikely any development will be forthcoming on such sites until the latter end of the Plan period. This approach however could provide supply and certainty in the long term and an important avenue for future delivery, whilst ensuring a healthy housing land supply to ensure continued choice and competition in the market and not ‘putting all eggs into a single basket’.

2.21 Your attention is also drawn to correspondence of the ongoing Bedford Local Plan Examination where Inspectors concluded recently that build out rates assumed by the Council on the two proposed strategic sites were wholly unrealistic and that there was very little flexibility in the remainder of the Plan. The result being the Council now need to find additional sites to give the Inspector’s assurances that the housing requirements can reasonably be met.

2.22 The Inspector’s letter of the 27 November 2023 sets out these fundamental concerns. Paragraph 53 states “the delivery rate for larger sites is also naturally constrained by traditional factors that would exist regardless, such as master planning and arriving at an acceptable scheme, opening up, providing infrastructure, and resource availability. As such, attaching a high level of premium to delivery rates due to Corridor growth is not a justified approach. It is instead more logical to take a cautious attitude to this issue”. Paragraph 54 continues “Overall, I am not satisfied that the assumed build out rates for either Little Barford or Kempston Hardwick are based on justified assumptions that are soundly based. This is the case before factoring in the uncertainty around infrastructure delivery timings discussed above and is a view that only hardens once the two issues are considered alongside each other”.

2.23 With regards for implications, paragraph 55 states “as discussed above, the soundness of the spatial strategy (and therefore the Plan) is fundamentally linked to the deliverability of strategic infrastructure and the reasonableness of the assumptions on alignment with anticipated growth”. It continues “in addition, the assumed build out rates for the two new settlements on which so much of the Plan’s growth relies upon are not based on justified assumptions”.

2.24 Paragraph 56 states “by the Council’s own acceptance, the Plan has very little flexibility built in that may assist with managing either of these issues”, concluding that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)”.

2.25 Taking all relevant factors into consideration, the Inspector’s letter concludes at paragraph 57 and 58 that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)… Taking the three issues of assumptions around infrastructure delivery, build out rates, and the reliance on a stepped trajectory together, I am unable to conclude that the Plan meets the tests of soundness at paragraph 35 of the NPPF”.

2.26 It is apparent any strategy which places overreliance on such delivery risks falling foul of the same issues at EiP. A cautious approach is therefore entirely sensible if there is to be the identification of any new settlements as part of the emergent spatial strategy.

Other

ID sylw: 108294

Derbyniwyd: 05/03/2025

Ymatebydd: Bostrom Property LLP

Asiant : Fisher German

Do you agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements?
2.15 Whilst we do not object to the principal of the identification of a new settlement through this Plan, we would urge caution be applied if the Council rely on a new settlements delivery to meet the overall quantum of housing growth necessary over the Plan period. Large scale, freestanding communities are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. 2.16 Our preferred approach in this scenario is to positively allocate such sites above and beyond the sites needed to meet housing needs, or at worst with highly cautious assumptions in terms of lead in times and annual build out rates. If work is underway and delivery has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which should provide the confidence needed to the market to commit to the works and evidence necessary to obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn’t come forward at all. 2.17 This approach also means the Council retain an element of control, meaning they can ensure the new settlement comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery. If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence and 8 appropriate planning consents, then the Council can begin to rely on delivery as part of its housing figures. 2.18 Given the likely lead in times, assumed in excess of 7 years supported by evidence documents such as Lichfield Start to Finish Volume 3, Saville’s Housing Saville’s Planning and Housing Delivery and the Letwin Review, it is considered unlikely any development will be forthcoming on such sites until the latter end of the Plan period. This approach however could provide supply and certainty in the long term and an important avenue for future delivery, whilst ensuring a healthy housing land supply to ensure continued choice and competition in the market and not ‘putting all eggs into a single basket’. 2.19 Your attention is also drawn to correspondence of the ongoing Bedford Local Plan Examination where Inspectors concluded recently that build out rates assumed by the Council on the two proposed strategic sites were wholly unrealistic and that there was very little flexibility in the remainder of the Plan. The result being the Council now need to find additional sites to give the Inspector’s assurances that the housing requirements can reasonably be met. 2.20 The Inspector’s letter of the 27 November 2023 sets out these fundamental concerns. Paragraph 53 states “the delivery rate for larger sites is also naturally constrained by traditional factors that would exist regardless, such as master planning and arriving at an acceptable scheme, opening up, providing infrastructure, and resource availability. As such, attaching a high level of premium to delivery rates due to Corridor growth is not a justified approach. It is instead more logical to take a cautious attitude to this issue”. Paragraph 54 continues “Overall, I am not satisfied that the assumed build out rates for either Little Barford or Kempston Hardwick are based on justified assumptions that are soundly based. This is the case before factoring in the uncertainty around infrastructure delivery timings discussed above and is a view that only hardens once the two issues are considered alongside each other”. 2.21 With regards for implications, paragraph 55 states “as discussed above, the soundness of the spatial strategy (and therefore the Plan) is fundamentally linked to the deliverability of strategic infrastructure and the reasonableness of the assumptions on alignment with anticipated growth”. It continues “in addition, the assumed build out rates for the two new settlements on which so much of the Plan’s growth relies upon are not based on justified assumptions”. 9 2.22 Paragraph 56 states “by the Council’s own acceptance, the Plan has very little flexibility built in that may assist with managing either of these issues”, concluding that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)”. 2.23 Taking all relevant factors into consideration, the Inspector’s letter concludes at paragraph 57 and 58 that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)… Taking the three issues of assumptions around infrastructure delivery, build out rates, and the reliance on a stepped trajectory together, I am unable to conclude that the Plan meets the tests of soundness at paragraph 35 of the NPPF”. 2.24 It is apparent any strategy which places overreliance on such delivery risks falling foul of the same issues at EiP. A cautious approach is therefore entirely sensible if there is to be the identification of any new settlements as part of the emergent spatial strategy.

Other

ID sylw: 108303

Derbyniwyd: 07/03/2025

Ymatebydd: Indurent Propco A3 Ltd

Asiant : Turley

Indurent Propco A3 Ltd (‘Indurent’) raises no concerns with the approach to identify new settlement locations to address the
housing requirement. The NPPF is clear at paragraph 77 that the “supply of large number 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”.
However, the plan must not place an overreliance on strategic sites delivering the required housing during the plan period.
Stratford District Council’s Core Strategy (adopted 2016) allocated two new settlements in Long Marston Airfield (LMA) and
Gaydon / Lighthorne Heath (GLH) to deliver around 4,400 new homes over the plan period to 2031 (2,100 and 2,300
respectively).
The most recent annual monitoring report for Stratford-on-Avon district was released in December 2023 and covered the
period 2022/23. For the LMA, the report advised that 251 homes had been built by 2022/23. The housing trajectory in the
Core Strategy anticipated the new settlement would have delivered 550 dwellings at this point. Moreover, the LMA only has
detailed planning permission for 400 new homes. Although it is understood that applications for another 500 homes will be
permitted shortly, the outline application for the wider 3,100 dwellings was submitted in 2018 and remains undetermined
(18/01892/OUT). It is understood that the delay to the South Western Relief Road is preventing the majority of the site
coming forward, so it is highly unlikely that the LMA will deliver 2,100 new homes by the end of the plan period. The same
monitoring report confirmed that only 454 new homes were built up to 2022/23 (against the assumed number of 725
dwellings at the same stage in the housing trajectory). The report advises that the whole GLH new settlement is expected to
deliver only 1,651 new homes by 2031 (against the target of 2,300 new homes for the plan period).
The redevelopment of the Business Park for residential uses would not be dependent upon the South Western Relief Road
coming forward. There remains sufficient trip capacity within the wider Meon Vale site to accommodate further, and
significant, residential development. Moreover, the potential future closure of the Business Park would open up more
capacity on the network which would be absorbed by further housing development. Evidence can be provided to the
councils to demonstrate this in more detail.
Moreover, the redevelopment of the Business Park for residential uses would benefit from the existing services and facilities
on Meon Vale (primary school, village hall, convenience store, cafes, leisure centre, sports pitches, open spaces). The key
infrastructure already exists at Meon Vale which gives certainty of delivery if Indurent decided to promote the Business Park
for redevelopment to residential use during the plan period. It would also benefit the local planning authorities as the site
could be delivered early in the plan period.

Other

ID sylw: 108312

Derbyniwyd: 07/03/2025

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

Asiant : Nexus Planning

Whilst CEG and Mixed Farms does not oppose planning to deliver new settlements, per se, the SWLP is urged to
proceed with caution in terms of relying upon the delivery of new settlements to meet housing requirements
within the plan period.
It is well evidenced that large strategic sites such as new settlements are costly and complex in terms of land
assembly and therefore take much longer to deliver housing than allocations in locations which are already
sustainable.
The Lichfields document ‘From Start to Finish’ (March 2024) is an industry-wide accepted document which
considers housing delivery, lead-in times for planning application of different scales and average build-out rates
for development sites. The SWLP confirms that any new settlement will be a minimum of 6,000 dwellings, and
whilst Start to Finish considers developments of 2,000 + within one category, it outlines that:
 Planning approval for these sites averages at 5.1 years from validation;
 First delivery for these sites averages 6.7 years from validation;
 Build out rates average between 100 and 188 dpa.
The above data, which suggests that the first dwelling is not occupied over 10 years after submission of a
planning application, should be treated as an absolute minimum for a new settlement. In reality, given the
significantly uplifted number of dwellings in a South Warwickshire new settlement, it can be expected that
planning permissions, delivery and build out rates for a site of 6,000 dwellings will be substantially increased
above the evidence set out within Start to Finish.
The SWLP will therefore need to ensure that market and affordable housing and associated necessary
infrastructure is also delivered early in the plan period and should therefore allocate sites at a variety of scales to
ensure the spread of housing delivery across the trajectory. Whilst the infrastructure to be delivered alongside a
new settlement can be selected to meet the needs of future residents, urban extensions, such as at East of
Stratford-upon-Avon can rely initially on existing infrastructure to deliver development earlier within the plan
period whilst also unlocking additional land to be developed later in the plan period. This approach is critical to
the Council demonstrating a five year housing land supply upon adoption of the plan and maintaining sufficient
supply and meeting delivery rates throughout the plan period.
CEG and Mixed Farms’ land at East of South East Stratford-upon-Avon can deliver approximately 1,200 dwellings
across the plan-period, however CEG and Mixed Farms expect that a first phase of 300 - 450 dwellings can deliver
housing within the first five years of the plan period.
In terms of the specific new settlement options put forward within the SWLP, CEG and Mixed Farms note that
‘Land at Hatton (B1)’, ‘Long Marston Airfield (E1)’, ‘Land south of Leamington Spa/Whitnash and west of B4455
Fosse Way (X2)’ and ‘Land at Bearley and Wilmcote (BW)’ are all considered to be ‘More Suitable’ of the New
Settlement options. Two of these options (‘Land at Hatton’ and ‘Land at Bearley and Wilmcote’) are located
entirely within the Green Belt and therefore, again, are sequentially less preferable than SG19 in terms of the
NPPF’s direction to allocate non-Green Belt land first, before considering review and allocation of Green Belt
land. SG19 is a sustainable non-Green Belt option which can accommodate significant levels of growth and unlock
land required to deliver vital infrastructure for Stratford-upon-Avon and Wellesbourne in the form of the Eastern
Relief Road.
In summary, whilst new settlements might be appropriate as part of a strategy to accommodate the longer term
housing needs of the Local Plan area, CEG and Mixed Farms consider non-Green Belt urban extensions such as
East of Stratford-upon-Avon, which can deliver market and affordable housing earlier in the plan period, should
be allocated for development.

No

ID sylw: 108337

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Draft Policy Direction 2 describes how one or more new settlements will be identified and considered for strategic site allocation where they can be developed to a suitable minimum size to provide the required infrastructure. 12 potential new settlement locations have been identified
which have been categorised as more or less suitable based on the work undertaken to date.

Whilst Caddick Land recognise that the provision of large scale development such as new settlements is supported through Paragraph 77 of the NPPF, part d) nonetheless requires Local Planning Authorities to make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Paragraph 22 similarly recognises that such developments take time to deliver and that relevant policies should accordingly be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.

Conversely, Paragraph 72 makes clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes, and are often built-out relatively quickly.

As referred to in this Representation, it is accordingly disappointing that the Councils are deferring the consideration of smaller sites to individual ‘part-two’ plans. As mentioned previously, the deferral of these issues to a part-two plan will result in three to five years delay whilst any subsequent plan is prepared, submitted for examination and subsequently implemented.

This approach is accordingly not in the spirit of national policy.

No

ID sylw: 108348

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are concerned about the lack of a robust delivery model for proposed new settlements or a robust trajectory for delivery of housing and infrastructure in the Infrastructure Delivery Plan and other supporting evidence. The PPG requires evidence there is a reasonable prospect that proposals can be delivered within the envisaged timescales. New settlements often require substantial lead-in times and have delays due to funding and infrastructure uncertainties. We urge the Councils to focus on developments that are sustainably located close to existing settlements with good accessibility, infrastructure, and employment opportunities. This is true for the promoted site, Land North and South of Welsh Road West, Southam.

Other

ID sylw: 108365

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

5.1 Mackenzie Miller Homes does not object to the SWCs exploring New Settlements to meet
some housing needs and acknowledges that the SWCs will require various sites to address
the LHN and contribute towards the unmet housing needs from the neighbouring areas.
Paragraph 77 of the NPPF 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, and supported by the
necessary infrastructure and facilities (including a genuine choice of transport modes)..”
5.2 It is important to highlight that the NPPF is also clear that plans should be prepared
positively, in a way that is aspirational but deliverable (Para 16b), and should identify
specific, developable sites or broad locations for growth, for years 6-10 and, where possible,
for years 11-15 of the plan (Para 72b).
5.3 However, Mackenzie Miller Homes would like to highlight large-scale developments such as
New Settlements often take years to fully deliver and may not meet all needs within the plan
period. Paragraph 22 of the NPPF states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to
anticipate and respond to long-term requirements and opportunities, such as those
arising from major improvements in infrastructure. Where larger scale developments
such as new settlements or significant extensions to existing villages and towns form part
of the strategy for the area, policies should be set within a vision that looks further ahead
(at least 30 years), to take into account the likely timescale for delivery.” (Emphasis
Added).
5.4 The Councils must consider reasonable alternatives and be based on proportionate
evidence (Para 36b). It is considered that the Councils must evaluate alternative housing
distributions through the SA early on. It must also ensure a sufficient mix of sites that are
viable, available, and suitable (Para 69).
5.5 Furthermore, the Planning Practice Guidance [PPG] requires LPAs to show a reasonable
prospect that large-scale developments will come forward, including a realistic assessment
of development timelines and engagement with infrastructure providers to ensure
feasibility within the planned timescales (PPG ID: 61-060).
5.6 Given the above, Mackenzie Miller Homes would not object to the option of exploring
meeting some of the SWC’s needs through a New Settlement but would like to highlight to
the SWCs that sufficient evidence will need to be prepared in support of any future
allocation.
5.7 Notwithstanding this, Mackenzie Miller Homes believes that New Settlements should not
be the only option for meeting all of the SWLPs needs, as these types of developments take
many years to commence. Therefore, Mackenzie Miller Homes considers that SWCs should
use a mix of sites and sizes, including larger sites at different scales, within the SWLP area in sustainable locations to ensure that supply can come forward at different parts of the
plan period to meet the housing needs over the 2050 plan period. As such, it is considered
that larger sites such as land at Fell Mill and Leasow Farm should be allocated to help
meeting the LHN.

Yes

ID sylw: 108389

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate supports the Councils’ approach of delivering one or more new settlements to help meet identified local housing need over the plan period. This aligns with NPPF Paragraph 77 and the Written Ministerial Statement ‘Building the homes we need’.

New settlements must meet the deliverability tests set out within the NPPF and the Councils must be comfortable that sites will be built out at a rate which ensures they maintain a healthy supply of housing each year.

The Lichfields ‘Start to Finish’ report is helpful in identifying average build-out rates. Its latest findings conclude:
• On average, it will take 6.6 years from validation of the first application to the first dwelling being completed on schemes of 2,000 or more dwellings.
• On average, the annual build-out rate range for schemes of 2,000+ dwellings is between 100-188 dpa.
• On average, the annual build-out rate range for schemes of 500-999 dwellings is between 44-83 dpa.
• It is 34% quicker to deliver greenfield sites of 500 or more units than some brownfield sites.

The Estate has prepared separate representations in support of E1 Long Marston Airfield, within which the Estate own land, which conclude that this is one of the more sustainable potential locations.

Yes

ID sylw: 108426

Derbyniwyd: 04/03/2025

Ymatebydd: Landowner Site A1

Asiant : Morgan Elliot Planning

We support Draft Policy Direction 2 – Potential New Settlements, in the identification of one or more new settlements for the Plan. We believe that a new settlement would significantly help boost and deliver housing and sustainable communities within the plan period.
For the reasons above we support the identification of Site A1, Land south of Tanworth-in-Arden as the most suitable new settlement location.
We agree that a new settlement is supported by national planning policy and has an essential role in the SWLPPO delivering new housing and sustainable communities.
We believe that site A1 should now be the preferred option (or one of the preferred options) for a new settlement within the Plan.

No

ID sylw: 108504

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

It has not been adequately demonstrated that the Potential New Settlements will be supported by the necessary infrastructure and facilities, including a genuine choice of transport modes. Opportunities for rail links to these Potential New Settlements may be challenging and therefore further information is required to demonstrate how such development can help to meet identified needs in a sustainable way.
The need for significant new infrastructure and facilities to support the Potential New Settlements will mean that these growth locations are unlikely to be delivered until towards the end of the Plan Period to 2050. Clearly, there is a requirement for smaller allocations to meet the identified housing needs in the shorter term, in accordance with Paragraph 72 of the Framework.
The site at Wilmcote 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 village and will enhance its vitality in line with national planning policy.
The site at Wilmcote, should be allocated as a housing site. 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.

Yes

ID sylw: 108543

Derbyniwyd: 07/03/2025

Ymatebydd: Chapel Ascote Farms

Asiant : Framptons

The approach is agreed, the new settlement sites can be developed to a suitable minimum size to provide the required infrastructure for substantial internalisation of trips. A new settlement has the potential to accommodate approximately 6,000-10,000 dwellings (minimum), as a significant proportion of South Warwickshire's growth needs.

No

ID sylw: 108562

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

It is recognised that new settlements can make an important contribution towards meeting South Warwickshire’s housing requirement and this approach would be consistent with national policy (with Paragraph 77 stating that the supply of large numbers of new homes can often be best achieved through planning for new settlements), this must be balanced alongside the delivery of a range of sites throughout the Plan period.

New settlements have long lead-in times, which means that their contribution towards South Warwickshire’s housing supply would likely be in the latter part of the plan period, and possibly into the next. If too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations, and these should form the majority of South Warwickshire’s housing supply, in addition to any new settlement(s).

To the east of this Site, beyond the railway line, the Council identifies Land south of Deppers Bridge as a potential new settlement (New Settlement F2), with a capacity of 4,840 new homes. Whilst not identified as one of the preferred Settlements, directing growth within this broader location was clearly considered to be a reasonable alternative when assessing suitable growth locations. This highlights further the inconsistent approach taken by the Council’s in relation to the Priority Areas, and in particular with regards to Bishops Itchington settlement and this Site. As with the BDW housing development to the south, this Site has the ability to be brought forward within the next 5 years with no constraints to development, contributing further to the sustainability credentials of the wider settlement.

Other

ID sylw: 108611

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 2 – Potential New Settlements
4.28.
In addition to the Strategic Growth Locations in Priority Areas 1, 2, and 3, the South Warwickshire Councils have identified twelve potential new settlements, and a policy direction is included which states that one or more will be considered for allocation. The New Settlements Assessment Topic Paper (November 2024) only identifies four of the potential new settlements as “more suitable”.
4.29.
New settlements can make an important contribution towards meeting South Warwickshire’s housing requirement. Indeed, NPPF §77 states that the supply of large numbers of new homes can often be best achieved through planning for new settlements, thus this approach would be consistent with national policy, and the provision of one or more new settlements is supported in principle. The Councils are reminded that where such large-scale residential development is proposed, NPPF §22 stipulates that strategic policies should be set within a vision that looks at least 30 years ahead (taking into account the timescales likely to deliver a new settlement). The vision in the SWLP Part 1 is currently restricted to its 25-year plan period, thus, if the Councils were to pursue a new settlement, this should be amended/addressed accordingly within the plan.
4.30.
New settlements have long lead-in times typically 6.6 years from first application to first home on site (source: Lichfield’s Start to Finish 3), which means that their contribution towards South Warwickshire’s housing supply would likely be in the latter part of the plan period, and possibly into the next. If too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations, and these should form the majority of South Warwickshire’s housing supply, in addition to any new settlement(s). This aligns with NPPF §61, which states that a variety of land should be brought forward for housing, i.e. sites of different scales, ranging from minor development through to new settlements. It will also better meet the needs of SME housebuilders, who are able to respond more flexibly to meet short term requirements and provide variety and choice in the marketplace NPPF §73.
4.31.
The SA assesses the potential new settlement locations. Whilst they would all make a major positive contribution to housing (SA Objective 9), all options will generally result in minor adverse to major adverse impacts across most of the other SA objectives. The Emerging Spatial Growth Strategy Topic Paper recognises that new settlements will have a harmful impact due to the amount of land they would occupy in existing countryside locations. The SA suggests that the Strategic Growth Locations are therefore generally more sustainable, in terms of having lesser adverse impacts on the SA Objectives. However, it is important to note that this is only a high-level exercise, which has not taken potential mitigation, which could include ecological and landscape enhancements which would give rise to major positive impacts, into account. As with the Strategic Growth Locations, the positive impacts on transport and accessibility (SA Objective 11) and, as a result, Climate Change (SA Objective 1) have also not been recognised.

Other

ID sylw: 108658

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

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

No

ID sylw: 108661

Derbyniwyd: 06/03/2025

Ymatebydd: Cora

Asiant : Woolf Bond Planning

Whilst it is recognised that new settlements could have a role in contributing towards housing delivery, it is important that this does not undermine the wider requirements to ensure existing communities can thrive and grow, consistent with the advice in the NPPF. It is on this basis that the plan should include other sources of supply, both in the short and longer term, especially given the extended timeframe and realistic delivery rates from new settlements. Nevertheless, for clarity, we have no comments on the potential sites for new settlements.
The Plan therefore as currently prepared is not sound for the following reason: 1) It is not effective as it does not demonstrate how new settlements will adequately ensure sufficient delivery to achieve the minimum housing requirements in the NPPF.
To address this matter of soundness; a) Any provision for new settlements should both acknowledge the extended lead in times for new settlements alongside recognising that the plan should not hinder the ability of existing communities to grow and thrive throughout the entire plan period.

Other

ID sylw: 108678

Derbyniwyd: 07/03/2025

Ymatebydd: Ventrix Limited

Asiant : Frampton Town Planning

Whilst this is not confirmed as an allocation at this stage, we note the identification of the potential of this area. The Platt Group stress that if Wellesbourne Airfield is to be allocated in this location for employment, any policy should ensure that land is safeguarded for Wellesbourne Market.