Other

ID sylw: 108211

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

In encouraging the use of previously developed land, this Policy Direction aligns with national policy, with Paragraph 124 emphasing that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the Urban Capacity Study is still clear that “significant greenfield development” (including Green Belt) will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.

Other

ID sylw: 108304

Derbyniwyd: 07/03/2025

Ymatebydd: Indurent Propco A3 Ltd

Asiant : Turley

Draft Policy Direction 9 aims to make “full use” of suitable urban brownfield land before development is considered in other
locations. Indurent Propco A3 Ltd (‘Indurent’) strongly supports this policy direction in principle.
The draft policy wording states that “where available brownfield land is located outside of urban areas, decisions on its use
will have reference to the sustainability of the location, with regard to the Spatial Growth Strategy priority areas 1-3; and/or
whether its use would increase the sustainability of the area as part of a large-scale development such as a new settlement”.
Any future redevelopment of the Business Park would fully align with this policy direction.
The draft policy direction also aligns with paragraph 89 of the NPPF which states that the “use of previously developed land,
and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist”.
A similar policy is contained with the Stratford Core Strategy, adopted in 2016. Policy CS.15(e) states that development will
be permitted on certain large rural brownfield sites “to encourage the effective use of previously developed land”. The policy
directed the decision-taker to Policy AS.11 which provided greater detail on proposals for the re-use and redevelopment of
previously developed sites. It included a specific part (2) which confirmed which planning uses would be appropriate as part
of a wider redevelopment of Meon Vale (referred to as the ‘former Engineer Resources Depot, Long Marston’), subject to
specific requirements. These uses included: “leisure-related activities and accommodation; employment uses within Classes
B1, B2 and B8; other forms of employment that make use of the rail connection to the site; and residential development that
is consistent with the approach set out in Policies CS.15”. Indurent recommends that the new local plan includes a similar
policy to deal with specific previously developed sites within the plan area.
Moreover, the policies within the future Regulation 19 consultation must be drafted to include a caveat that any other
restrictive policies within the plan (such as those which aim to resist the loss of existing employment uses to nonemployment uses) should not apply to the Meon Vale Business Park or other similar sites listed in the policy.

Other

ID sylw: 108342

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Draft Policy Direction 9 confirms that the SWLP will make “full use” of urban brownfield land before development is considered in other locations.

Whilst this approach is common practice and enshrined in national policy, the Councils should ensure that any consideration of brownfield sites is robustly tested for viability to ensure deliverability. It is commonly accepted that brownfield sites often have development constraints
that render the viability of such schemes marginal, often to the detriment of affordable housing delivery.

It is submitted that the Councils should look to provide a balanced approach between using brownfield land and green field sites in sustainable locations, such as Land North and South of Hill Wootton Road, Leek Wootton.

Other

ID sylw: 108355

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

In light of the extent of the substantial unmet needs for housing as shown in the above section, and the lack of sufficient capacity for development as confirmed by the Council’s Brownfield Land Registers, we consider that the Council should not be reliant upon the supply of brownfield land in addressing the need for growth.

It is significant that developments on brownfield land or previously developed land often experience financial viability issues due to high abnormal costs often associated with remediation activities, which would result in a reduction in the provision of affordable housing relative to the policy level set out in the Plan’s Vision and Objectives.

As such, and for the Plan to be robust and effective, we urge the Council to prioritise the allocation of potential strategic growth locations, in particular those on non-Green Belt areas, including this Site

Other

ID sylw: 108406

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.

However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.

Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities.

Other

ID sylw: 108437

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

Asiant : Cerda Planning Ltd

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.

However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.

Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities.

Other

ID sylw: 108495

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Failure to Prioritize Brownfield and Infill Development (Chapter 6)
• The Plan ignores urban brownfield sites in favour of easier, more profitable greenfield development.
• NPPF Paragraphs 119 & 120 require councils to prioritise brownfield regeneration before releasing countryside for development.
• The failure to maximize urban densities results in unnecessary urban sprawl and inefficient land use.
Conclusion: The Local Plan must focus on brownfield-first policies before permitting greenfield expansion.

Yes

ID sylw: 108539

Derbyniwyd: 07/03/2025

Ymatebydd: Warner Planning

We support the policy and the utilisation of brownfield land to assist in the housing delivery for the Local Plan.

Yes

ID sylw: 108541

Derbyniwyd: 07/03/2025

Ymatebydd: Chapel Ascote Farms

Asiant : Framptons

Chapel Ascote Farms Ltd are supportive of the Spatial Growth Strategy which first utilises available urban brownfield land and then where greenfield development is needed, concentrating this into fewer, larger areas of strategic growth.

Other

ID sylw: 108569

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

In encouraging the use of previously developed land, this Policy Direction aligns with national policy, with Paragraph 124 emphasing that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the Urban Capacity Study is still clear that “significant greenfield development” (including Green Belt) will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.

Other

ID sylw: 108617

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 9 – Using Brownfield Land for Development
4.40.
In encouraging the use of previously developed land, this Policy Direction aligns with NPPF, with §124 emphasising that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the
Urban Capacity Study is still clear that “significant greenfield development” will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.