Other

ID sylw: 107662

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala agrees with the general approach laid out in Draft Policy Direction 5 to seek new or improved site-specific infrastructure, provision of such infrastructure or contributions, from developers to make development
acceptable in planning terms but recommends that further work is undertaken to clarify the items and amounts required across the districts. Clear justification on the type and quantity of obligations sought in respect of the new proposed settlements is also required.

The Infrastructure Delivery Plan (IDP) provides a consideration of the future infrastructure needs across South Warwickshire, providing a transport hierarchy at Fig Whilst Cala generally supports this hierarchy and fully
acknowledges that an emphasis on active travel and public transport is desirable, there will still need to be significant investment in improving the road network to accommodate future housing capacity and to ensure well-
connected communities across the district. It is important that the IDP clearly sets out any requirements and expectations of the level of contributions expected for specific forthcoming development to provide a transparent
process, avoiding any later, unexpected items which could have potential to render a development unviable.
The IDP recognises that Stratford on Avon frequently suffers from traffic congestion, particularly during peak hours, and specifically notes the A3400 Clopton Bridge (Stratford) as being an area of high traffic with the River Avon having limited crossing points.
Cala therefore welcomes the commitment to carry forward existing safeguarding measures identified in the adopted Local Plans that have not yet been implemented or completed.

No

ID sylw: 107681

Derbyniwyd: 26/02/2025

Ymatebydd: Shakespeare Line Rail User Group

The 2024 Stratford-Honeybourne SOBC Refresh rail study needs to be incorporated into the Infrastructure Delivery Plan. This integration is essential for securing developer contributions towards the rail link, which is a critical component of the emerging Worcester-Parkway-Evesham-LMAGV-Stratford-Hatton-Warwick-Leamington (A46 corridor) development arc, as outlined in the final report.

By including this study in the plan, the South Worcestershire Local Plan (SWLP) can effectively mobilise the necessary funding and resources to improve transportation infrastructure. This is vital to accommodate the current and future growth in the region, which is critical to achieving sustainability and fulfilling the vision and strategic objectives of the SWLP.

Other

ID sylw: 107694

Derbyniwyd: 04/03/2025

Ymatebydd: Pete Frteeman

Areas around Warwick are notoriously bad. Whoever dreamt up the Warwick Gates, Whitnash, and Hatton infrastructure plan, must been [redacted] ! How can the same people be trusted going forward?

Other

ID sylw: 107737

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We generally support draft Policy Direction 5, however contributions requested need to be acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development in accordance with paragraph 58 of the NPPF. We note from the SWLP that a Viability Appraisal will be produced to support the Regulation 19 plan. This should ensure the policy requirements being proposed will not impact on the delivery of development sites. The Viability Appraisal should be informed by a full and detailed review of all financial contributions which may be sought for development at the application stage.

Other

ID sylw: 107813

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle. The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.

Yes

ID sylw: 107844

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

3.56 Overall, Taylor Wimpey support development being consistent with and contributing to the implementation of transport strategies, reflecting the ‘sustainable travel and economy’ approach, the true ‘modal shift’ described at p46, and the improvement of public transport. This is considered to broadly align with Section 9 of the NPPF. Sites which benefit from existing access to public transport should be prioritised for future growth, particularly in the instance that additional sites need to be identified to meet the additional needs calculated for South Warwickshire.
3.57 The site promoted by Taylor Wimpey on land to the north east of Hampton Magna benefits from easy access to Warwick Parkway train station, located to the north of the site. The Illustrative Masterplan for the site sets out opportunities to provide pedestrian/cycle connectivity through the site to the existing pedestrian connections, adjoining the railway station.
3.58 Taylor Wimpey welcomes the reference to site specific infrastructure and other requirements in any forthcoming allocation policies given this will provide better certainty going forward. However, this needs to be proportionate to the scale of development proposed, based on up-to-date evidence of need and subject to viability (which should be explicitly referenced in the policy wording). These requirements will also need to be justified through the evolving IDP.

Yes

ID sylw: 107901

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

In general, Terra agrees with the SWA’s proposed approach of requiring developments to
make contributions towards the delivery of infrastructure. It is entirely appropriate for
development to mitigate their impacts and where possible and necessary make contributions towards associated infrastructure. However, as the SWAs will be aware, these
contributions must:
a necessary to make the development acceptable in planning terms;
b directly related to the development; and
c fairly and reasonably related in scale and kind to the development (Para 58,
NPPF).
2.74 As such, as the SWAs progress the SWLP, it will be critical that an Infrastructure Delivery
Plan [IDP] is prepared, which identifies the infrastructure necessary to mitigate proposed
development allocations – this will be particularly critical for any SGLs or New Settlements.
2.75 However, the NPPF is clear that planning policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals” (Para 16d). In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.”
2.76 Therefore, it will be critical that the SWLP is clear through site-specific allocations what
infrastructure improvements are required for each development allocation. The need for
the delivery of supporting new community and social infrastructure has formed the basis
for Terra ’s vision of the land at SG14- East of Gaydon and is illustrated within the Vision
Document at Appendix 1 to include a new 3FE primary school, new access routes,
pedestrian and cycle infrastructure, a Linear Park and significant landscape buffer to
Bishops Itchington, along with SUDS feature and drainage infrastructure.

Other

ID sylw: 107910

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Overall, Taylor Wimpey support development being consistent with and contributing to the implementation of transport strategies, reflecting the ‘sustainable travel and economy’ approach, the true ‘modal shift’ described at p46, and the improvement of public transport. This is considered to broadly align with Section 9 of the NPPF. Sites which benefit from existing access to public transport should be prioritised for future growth, particularly in the instance that additional sites need to be identified to meet the additional needs calculated for South Warwickshire.
Taylor Wimpey welcomes the reference to site specific infrastructure and other requirements in any forthcoming allocation policies given this will provide better certainty going forward. However, this needs to be proportionate to the scale of development proposed, based on up-to-date evidence of need and subject to viability (which should be explicitly referenced in the policy wording). These requirements will also need to be justified through the evolving IDP.

Other

ID sylw: 107927

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle; Paragraph 20 of the NPPF is clear that strategic policies should make sufficient provision for infrastructure, and this is also key for the delivery of sustainable development. The Site at Thickthorn is within the built-up urban area and as part of the existing permission for the Site infrastructure has been delivered in this sustainable location. It can therefore support development early in the Plan period, to assist in the early delivery of housing for Kenilworth.

Other

ID sylw: 107938

Derbyniwyd: 04/03/2025

Ymatebydd: Stratford Residents Action Group (SRAG)

SRAG - was formed in 2017 and has maintained and still maintains a position of publicly opposing the currently planned alignment of the South West Relief Road (SWRR).

Recent media comment on the SWLP Preferred Options Consultation claims that £250,000 has already been allocated by SDC for a study of an alternative to the SWRR made necessary, it is understood, by failure to secure funding, the largely negative response to the SWRR and uncertainty on the location of the preferred major new settlements (LMA and Bearley).

There is no publicly available evidence of the brief from SDC around which a "SWRR alternative" study would be studied - or by whom - although the description "Relief Road" continues to be used.

SRAG will also expect the existing SWRR proposal to be permanently removed as an infrastructure option, and the justification for its routing also removed to avoid it ever being regarded as a revisitable option.

Other

ID sylw: 107942

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.

Other

ID sylw: 107964

Derbyniwyd: 26/02/2025

Ymatebydd: Earlswood & Forshaw Heath Residents’ Association

The majority of the residents in Earlswood Ward of Tanworth-in-Arden Parish require east-west communications to be improved i.e. Solihull / Redditch / Solihull, rather than north-south communications as at the moment. You did not absorb this comment during the previous Core Strategy Review and we point it out again in order to remind you. Having said that, with the increased traffic flow from Solihull, the A435 running north as a dual carriageway is fine until it becomes a single carriageway road at The Maypole, at which point it bottlenecks, even during off-peak times. This poses the question of infrastructure improvements again. There doesn’t seem to be much in the way of their consideration in the first draft. Our view is that you need to set out plans to upgrade the infrastructure first before anything else is considered.

Other

ID sylw: 108063

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.

Other

ID sylw: 108164

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We recognise that all development proposals should provide appropriate on and off site infrastructure requirements.
This is subject to those requirements meeting the CIL tests.
Where infrastructure goes beyond that necessary to mitigate the impacts arising from development, this should be offset against other development management requirements, and/or put in the planning balance as a matter of significant weighting.
We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations. This is not a matter to be deferred to the Publication Consultation (this being the final consultation prior to the SWLP being submitted for examination).
We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options. The process should be workshop based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each subsequent workshop – to get to an agreed position by way of an iterative process. In so doing, the SWLP can be progressed and put to examination with a suite of completed SoCG’s underpinning each chosen site within the spatial growth locations, such that the Councils can be confident about the deliverability of each site and thus the soundness of the SWLP as a whole.

Yes

ID sylw: 108190

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy
Direction 5- Infrastructure Requirements and Delivery?
2.55 In general, St Philips agrees with the SWA’s proposed approach of requiring developments
to make contributions towards the delivery of infrastructure. It is entirely appropriate for
development to mitigate their impacts, and where possible and necessary make
contributions towards associated infrastructure. However, as the SWAs will be aware, these
contributions must:
a necessary to make the development acceptable in planning terms;
b directly related to the development; and
c fairly and reasonably related in scale and kind to the development (Para 58,
NPPF).
2.56 As such, as the SWAs progress the SWLP, it will be critical that an Infrastructure Delivery
Plan [IDP] is prepared, which identifies the infrastructure necessary to mitigate proposed
development allocations – this will be particularly critical for any SGLs or New Settlements.
2.57 However, the NPPF is clear that planning policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals” (Para 16d). In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.” (Emphasis Added)
2.58 Therefore, it will be critical that the SWLP is clear through site-specific allocations what
infrastructure improvements are required for each development allocation.
2.59 In addition, and as stated throughout St Philips’ response, the NPPF is also clear that
planning policies should have regard to the economic viability of sites (Para 68) and should
not undermine the deliverability of the Local Plan (Para 34). To this end, the SWLP will
need to be supported by a Viability Assessment that cumulatively tests the impact of policy
and infrastructure requirements on the viability of sites allocated in the SWLP. This should
include any site-specific infrastructure required to support the delivery of some sites, as
well as any Community Infrastructure Levy.

Yes

ID sylw: 108207

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle. In Stratford and Warwick, developer contributions can be secured via the Community Infrastructure Levy and Section 106 Agreements. The SWLP Part 1 should clearly define and distinguish between the two; developers should not be required to contribute towards the same items through each. In addition, the SWLP Part 1 should make it explicitly clear, including in relation to education contributions, that only proportionate infrastructure can be sought in line with the needs generated by a development – contributions must not extend beyond this to remedy any existing deficiencies which may exist in South Warwickshire. Indeed,

The emerging Policy Direction makes no reference to viability considerations. It suggests that “all development must provide appropriate on- and off-site infrastructure” (emphasis added), despite the fact that this may render a scheme unviable. The SA has not recognised the adverse impacts this omission could have on SA Objectives 9 (Housing) and 11 (Economy). Paragraph 35 of the NPPF is clear that whilst plans should set out the contributions and infrastructure expected from development, such policies should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure that contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may demonstrate whether particular circumstances justify the need for a viability assessment at the application stage.

Other

ID sylw: 108272

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we generally support the approach identified in Draft Policy Direction 5, we have a number of comments on the policy’s supporting text.
We welcome the acknowledgement that the site specific policies included in subsequent versions of the SWLP will specify the infrastructure delivery requirements associated with each allocation. However, we are concerned that the first opportunity to comment on these policies will be the Pre-submission of the SWLP. The Councils may receive comments at the Pre Submission stage that require a change to a Policy, or potentially require allocations to be reconsidered. This may result in the need for further target consultation following the preparation of the Pre-Submission SWLP prior to submission. This would slow down the Plan making process. In order to avoid this, the Councils should actively engage with site promotors to understand potential infrastructure opportunities and constraints in order to assist in establishing the most appropriate development sites and their policy requirements ahead of the publication of the Pre-Submission SWLP.
The policy’s supporting text advises that in planning for new development the Councils will have regard to where existing infrastructure deficiencies exist, and the extent to which new development will impact on these deficiencies. New development has the potential to address existing infrastructure deficiencies. Whereas this is the case this should support the case for an allocation.
For example, Spitfire control Stratford Agricultural Park, located to the east of Long Marston Airfield. The development of Long Marston Airfield has stalled due to offsite highways infrastructure funding issues. Directing additional development to Long Marston Airfield will help address these constraints by providing additional appropriate and proportionate S.106 funding and making Long Marston Airfield more self-contained.
We support recognition that an Infrastructure Delivery Plan needs to be prepared, and note that an Infrastructure Delivery Plan (Part One) has been published which is a key evidence based document to inform the plan making process and the infrastructure required with specification allocations. In order for the Infrastructure Delivery Plan to be robust it should be prepared in collaboration with site promotors.

Other

ID sylw: 108314

Derbyniwyd: 07/03/2025

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

Asiant : Nexus Planning

CEG and Mixed Farms agree that new development should contribute, where necessary, to the implementation
of transport strategies and acknowledges the role that development can play in delivering significant
infrastructure projects.
The Stratford-upon-Avon Transport Strategy sets out the difficulties the town experiences with regard to traffic
congestion, outlining that low average speeds are recorded throughout Stratford-upon-Avon on roads
approaching the town centre. The Transport Strategy attributes much of the traffic involved in this congestion to
through traffic to/from Shipston Road to/from Warwick Road; Birmingham Road to/from Shipston Road and
Banbury Road to/from Warwick Road, with traffic concentrated on two river crossings.
The Transport Strategy refers to historic work carried out to identify schemes to address existing transport
problems and accommodate future demands arising from new development. A series of Strategic Transport
Assessments were undertaken which identified where route improvements could be made, including growth to
the south east of Stratford-upon-Avon where a relief road on the eastern side of the town would be required.
Page 17 of the Transport Strategy outlines that an Eastern Relief Road connecting Warwick Road to Banbury Road
alongside a significant housing allocation in Southeast Stratford would ‘not only accommodate this scale of
development but would also improve overall network conditions and present opportunities to make further
advantageous changes to the transport infrastructure in central areas.’
Further investigations into this solution found that delivery of relief roads to both the east and west of Stratfordupon-
Avon would present the most effective reduction in journey times and alleviate pressure on junctions.
Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider
the substantial benefits that can be delivered through large scale growth south east of Stratford-upon-Avon, in
particular supporting the delivery of an eastern relief road, a strategic piece of infrastructure, noting that
paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs
of the area. More specifically, the opportunity to connect Banbury Road to Wellesbourne Road, providing
enhanced connectivity between the two routes should be explored. As set out within the Transport Note and
referenced elsewhere in these representations, this proposed ‘Movement Corridor’ will simplify journeys of all
modes towards Wellesbourne, where major economic growth is planned, without adding significant pressure on
routes in Stratford-upon-Avon town centre.
CEG and Mixed Farms therefore consider that development at SG19 would create significant improvements to
local infrastructure by delivering a phase of the Eastern Relief Road within the development site in accordance
with Draft Policy Direction 5.

Other

ID sylw: 108367

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

7.1 In general, Mackenzie Miller Homes agrees with the Council’s proposed approach to
require developments to provide appropriate on- and off-site infrastructure and to make
contributions towards the delivery of infrastructure.
7.2 It is an appropriate approach for developments to alleviate their impacts and where
possible and necessary make contributions towards associated infrastructure. It will be
essential for the Council to prepare an Infrastructure Delivery Plan [IDP], which sets out
the necessary infrastructure to mitigate the proposed development allocations (especially
for any strategic developments and New Settlements) as the SWCs progress the SWLP.
7.3 The NPPF is clear that planning policies should be “clearly written and unambiguous, so it
is evident how a decision maker should react to development proposals” (Para 16d). In
addition, Paragraph 35 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.” (Emphasis Added)
7.4 As such, it is critical that the emerging plan is clear through site-specific allocations the
level and type of infrastructure improvements that are necessary for each development
allocation.
7.5 Furthermore, the NPPF is also clear that planning policies should have regard to the
economic viability of sites (Para 68) and should not undermine the deliverability of the
Local Plan (Para 35). Planning policies should be underpinned by proportionate evidence
including a viability assessment that cumulatively tests the impact of infrastructure
requirements on the viability of any allocated sites. This should include any site-specific
infrastructure required to support the delivery of some sites, as well as any Community
Infrastructure Levy.

Other

ID sylw: 108385

Derbyniwyd: 01/03/2025

Ymatebydd: Morgan Powell

It is essential that the infrastructure associated with the increase in housing and consequent population is in place before the houses are sold. I'm talking about schools, health facilities, public transport, roads and utilities. Warks CC has a poor record of getting commitments from developers and an even poorer record of delivering these in a timely manner, if at all - look, for example at the Stoneleigh junction improvements (two years late and £16 million over budget, and counting), Shottery Relief Road (still waiting) and footpath improvements on Knights Lane (delivered 3 years after the houses were occupied). Warks CC or its successor needs to improve massively in this aspect. It should be mandated that important development impacts are mitigated before houses are sold.

Developments must be of a significant scale to attract the necessary investment from developers and Government to build this infrastructure.

I live near area SG19 and I would not be opposed to a large-scale development there provided the necessary infrastructure is delivered with it. Following the failure to deliver a relief road from Long Marston through Shottery, it is essential that Stratford gets a relief road from the Shipston Road through to the Tiddington Road and beyond towards the Longbridge Island.

Other

ID sylw: 108404

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations.

We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options. The process should be workshop based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each subsequent workshop – to get to an agreed position by way of an iterative process.

Other

ID sylw: 108435

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

Asiant : Cerda Planning Ltd

We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations.

We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options. The process should be workshop based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each subsequent workshop – to get to an agreed position by way of an iterative process.

Other

ID sylw: 108482

Derbyniwyd: 06/03/2025

Ymatebydd: Emma Guest

The infrastructure will be inadequate and the additional traffic will have a huge impact on the roads and environment.

Other

ID sylw: 108487

Derbyniwyd: 03/03/2025

Ymatebydd: Lesley O'Connor

Before any development is granted permission, it is essential that the necessary infrastructure is put into place. The recent developments that have been completed, or, are currently being constructed do not have enough GP surgeries, dental practices, shops, community centres, open spaces or schools. Why add to this with more houses?

Living in Kenilworth I am well aware of the traffic problems around the newly built Kenilworth school, the pupils are put at risk by insufficient footpaths & crossing places. This was due to opening the school before the correct road management was put in place, this must not be allowed to happen with other developments.

Our roads in this area are not adequate to cope with the increased traffic that will be generated by more houses; most households will probably have 1 or 2 vehicles. They will need places to park, especially if the house do no have big enough drives or garages. County highways, in my opinion, do not always consider the impact more traffic will have on the area. No one in planning appears to be worried about the damage to our environment by increased traffic.

The drainage, water supplies, supply of power should also be considered before a development takes place

The district council must ensure that developers adhere to the planning conditions mentioned when their developments are given permission, the 106 agreements must be put in place by developers (unfortunately, this has not always been the case so WDC should make sure that agreements are met)

Other

ID sylw: 108494

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Lack of Infrastructure Planning (Chapter 7)
• There is no clear plan for roads, schools, hospitals, or public transport to support such large-scale development.
• NPPF Paragraph 20 mandates that local plans must include infrastructure planning to support growth—this Plan fails to meet that requirement.
• The reliance on developer-led infrastructure contributions (CIL & Section 106 agreements) does not guarantee that essential services will be in place before occupation of new housing.
Conclusion: The Plan must include a comprehensive infrastructure strategy before development approvals are granted.

No

ID sylw: 108565

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle. In Stratford and Warwick, developer contributions can be secured via the Community Infrastructure Levy and Section 106 Agreements. The SWLP Part 1 should clearly define and distinguish between the two; developers should not be required to contribute towards the same items through each. In addition, the SWLP Part 1 should make it explicitly clear, including in relation to education contributions, that only proportionate infrastructure can be sought in line with the needs generated by a development – contributions must not extend beyond this to remedy any existing deficiencies which may exist in South Warwickshire. Indeed,

The emerging Policy Direction makes no reference to viability considerations. It suggests that “all development must provide appropriate on- and off-site infrastructure” (emphasis added), despite the fact that this may render a scheme unviable. The SA has not recognised the adverse impacts this omission could have on SA Objectives 9 (Housing) and 11 (Economy). Paragraph 35 of the NPPF is clear that whilst plans should set out the contributions and infrastructure expected from development, such policies should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure that contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may demonstrate whether particular circumstances justify the need for a viability assessment at the application stage.

Notwithstanding, sites such as that of land north of Harbury Depot have the ability, alongside the delivery of much needed new homes, to deliver enhanced infrastructure provision for the benefit of existing communities.

Yes

ID sylw: 108614

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 5 – Infrastructure Requirements and Delivery
4.36.
The provision of appropriate infrastructure is supported in principle; NPPF §20 is clear that strategic policies should make sufficient provision for infrastructure, and this is also key for the delivery of sustainable development. The Councils can seek developer contributions where it is not possible to address unacceptable impacts through conditions, in line with NPPF §56. In Stratford and Warwick, developer contributions can be secured via the Community Infrastructure Levy and Section 106 Agreements. The SWLP Part 1 should clearly define and distinguish between the two; developers should not be required to contribute towards the same items through each. In addition, the SWLP Part 1 should make it explicitly clear, including in relation to education contributions, that only proportionate infrastructure can be sought in line with the needs generated by a development – contributions must not extend beyond this to remedy any existing deficiencies which may exist in South Warwickshire. Indeed, The Council are reminded that planning obligations must meet the three tests established by CIL Regulation 122, and as referenced at NPPF §58, which require contributions to be:
a)
necessary to make the development acceptable in planning terms;
b)
directly related to the development; and
c)
fairly and reasonably related in scale and kind to the development.
4.37.
The emerging Policy Direction makes no reference to viability considerations. It suggests that “all development must provide appropriate on- and off-site infrastructure” (emphasis added), despite the fact that this may render a scheme unviable. The SA has not recognised the adverse impacts this omission could have on SA Objectives 9 (Housing) and 11 (Economy). NPPF §25 notes that whilst plans should set out the contributions and infrastructure expected from development, such policies should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the Planning Practice Guidance (PPG), to ensure that contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may demonstrate whether particular circumstances justify the need for a viability assessment at the application stage
(NPPF§59). Such references to viability would ensure the policy is fully consistent with national policies, and an effective and deliverable plan which allows viable schemes to be brought forward on a variety of sites across South Warwickshire.