No

ID sylw: 107057

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Strategic Objective 4 references innovative industries and technologies but should also specifically recognise the important contribution logistics will play in developing job opportunities.

Other

ID sylw: 107058

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

South Warwickshire’s Housing Requirement

NBBC would be in favour of the preferred approach being explored further, as South Warwickshire progress with developing the SWLP, taking into consideration the implications of Green Belt locations, the Sustainability Appraisal outcomes and the new 2024 NPPF Standard Method housing figures. As the SWLP is only at the Regulation 18 stage of plan-making, the new 2024 NPPF Standard Method figures are applicable after 12th March 2025 and therefore, must be accommodated in future iterations of this Plan.

Other

ID sylw: 107059

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Employment requirements are set out as residual amounts in the SWLP, removing completions and commitments. NBBC are supportive of including these components in the supply and the Alignment Paper and Employment Land Review (ELR) which inform the Policy Direction. The Policy Direction is not clear and unambiguous on what components of supply are included and why one evidence document is preferred over another.

Table 4 identifies a residual strategic industrial site need (2021-2045) of 75-125ha. This derives from the West Midlands Strategic Employment Sites Study (WMSESS) and associated Alignment Paper. NBBC is supportive of using the upper band figure as recommended in the Study.

Strategic need is calculated until 2045, whilst other need figures are calculated to 2050. While it could be argued the need should be extended to 2050, NBBC is supportive of using the figure to 2045 as the WMSESS is the primary evidence document regarding strategic need. The Alignment paper does not recalibrate strategic site needs but aligns the evidence of the need for wider employment sites to this. NBBC are supportive of the approach adopted in the SWLP.

The WMSESS identifies a residual need for 75-125 ha of strategic sites up to 2045, to include 1-2 mixed B8 sites and 0-1 B2 sites, within Road Opportunity Area (ROA) 8 along the M40/A46. Opportunity Areas 7 and 9 are discounted as they do not feature junction opportunities and access to the strategic highways network is prime consideration in identifying suitable land. NBBC is supportive of discontinuing areas which do not provide junction opportunities and agrees Opportunity Area 8 is the primary Opportunity Area for South Warwickshire. The location is consistent with the recommendations of the Study.

Other

ID sylw: 107060

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

The Preferred Options states that three ‘priority areas’ have been delineated which determine areas of land which fall within the 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. However, the SWLP outlines that there is insufficient urban brownfield land to accommodate South Warwickshire’s housing and employment land needs and so the majority of SWLP’s strategic growth needs will be met within priority areas 1-3.

Draft Policy Direction 12 – Locations for Employment Growth, identifies specific sites for allocation in the Regulation 19 version of the SWLP. To note, Wedgnock Park Farm is also proposed as a potential Strategic Growth Location (SG07) in the SWLP. NBBC considers the three strategic sites under consideration are consistent with the requirements set out in the WMSESS and is supportive of utilising previously developed land, which the Coventry and Warwickshire HEDNA identified by using gross completions. NBBC also considers that an amount of supply could be accounted from recycling existing employment sites.

Other

ID sylw: 107061

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Non-Strategic Employment Need

24 Strategic Growth Locations have been identified, outlined in Table 5 of the SWLP. These strategic locations could accommodate more than South Warwickshire’s non-strategic employment need (alongside assisting in accommodating South Warwickshire’s housing need). We understand that not all these locations will be allocated, and that the locations situated in the Green Belt will require exceptional circumstances for their release. To note, SG07 (Strategic Growth Location) is also proposed as a potential strategic employment site in Draft Policy Direction 12.

NBBC would be in favour of this preferred approach being explored further as South Warwickshire progress with developing the SWLP, taking into consideration the implications of Green Belt locations, the Sustainability Appraisal outcomes and the new 2024 NPPF Standard Method housing figures.

Furthermore, Coventry City Council's Regulation 19 consultation on their Local Plan declares a shortfall in employment land need. NBBC believes that Coventry should undertake further work to identify supply within its administrative boundary. In the event South Warwickshire accept there is a shortfall deriving from Coventry’s local need, NBBC supports the findings of the ELR regarding accommodating Coventry’s unmet need. The ELR identifies sites to the south of Coventry and the west of the A46 such as Land South of Dalehouse Lane, Kenilworth (16ha) (CFS95) and Land South of Coventry (East) (49ha) (CFS94) which could contribute to Coventry’s unmet need, subject to assessment. Therefore, should it be established that Coventry has unmet employment land need, SG01 and SG03 would be suitable.

Yes

ID sylw: 107062

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Duty to Cooperate

Warwick District Council and Stratford District Council have worked collaboratively with NBBC regarding cross-boundary strategic issues, alongside adjoining and nearby local authorities within the Coventry and Warwickshire Housing Market Area. Effective and on-going joint working has and will continue to be undertaken as the Council’s respective Local Plans are progressed through the plan-making system.

NBBC agrees that it is yet to be established to what extent there will be any unmet need, or of what type (e.g. housing and/or employment), from elsewhere within the Coventry and Warwickshire HMA. The Borough Plan Review (2021-2039) is progressing towards Main Modifications consultation following the conclusion of the Examination in Public hearing sessions. NBBC can confirm that there is no unmet housing or employment need from Nuneaton and Bedworth Borough. NBBC would welcome the opportunity to discuss a Statement of Common Ground with the South Warwickshire authorities.

Other

ID sylw: 107063

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

Green Belt

It is acknowledged that parts of South Warwickshire fall within the West Midlands Green Belt. The 24 Strategic Growth Locations and 12 new settlement locations, put forward in the SWLP Preferred Options document, include a mixture of Green Belt and non-Green Belt locations. The outcomes of the Stage 2 Green Belt Review, for the SWLP, will be important in deciding the most appropriate/suitable sites to allocate at Regulation 19, as it will assess the performance of these specific sites and also villages which are currently ‘washed over’ by the Green Belt designation. Furthermore, commissioning a Grey Belt Review may also be an avenue to explore, in relation to the introduction of the Grey Belt in the December 2024 NPPF, to ensure a robust evidence base is prepared to support future South Warwickshire planning decisions and in this plan-making process.

No

ID sylw: 107064

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

This policy outlines where small-scale development on unallocated sites will be supported in Green Belt and non-Green Belt locations. I would suggest the wording is aligned more closely with the December 2024 NPPF. For example, the Draft Policy Direction 3 states “limited infilling within Built Up Area Boundaries” which is reflective of the draft policy direction overall; whereas the NPPF states development in the Green Belt is inappropriate unless one of the following exceptions applies: limited infilling in villages. There is potential for the policy to be misconstrued and open to scrutiny.