Other

ID sylw: 106979

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We understand that the Warwickshire Local Nature Recovery Strategy (‘LNRS’) is in the early stages of consultation, and it is not yet clear what the draft LNRS will include. This work will need to be completed in order to inform the draft policy. If not, the feasibility and viability of ‘maintaining and enhancing local ecological networks through habitat creation, protection, enhancement, restoration and/or management’ as currently stated in the draft Policy Direction, should be considered to ensure that allocations coming forward in the plan are positively prepared and that allocated sites can deliver housing to meet South Warwickshire’s need. The policy should be worded with additional flexibility, such as adding ‘where possible and practicable’.

No

ID sylw: 106980

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the consideration in draft Policy Direction 38 to seek a higher percentage of biodiversity net gain (‘BNG’) than the mandatory 10%. If a higher percentage is sought, then the policy should be supported by evidence base to ensure that the policy is justified in line with NPPF paragraph 36. Consideration should also be given to the implications that a higher BNG would have on the viability of sites and their ability to be delivered efficiently. The provision of on-site BNG above 10% will have implications on site yields and is likely to lead to more sites requiring allocation to meet the significant development needs of South Warwickshire.

No

ID sylw: 106981

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works in practice. To our knowledge, there are no other examples of adopted
Local Plan policies requiring ENG or any well-developed metric for measuring ENG to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 106982

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 106983

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The policy seeks to protect and enhance carbon sinks. Reference is made to a supporting plan but these plans are unclear. More detail needs to be provided to demonstrate how much of the district is considered to be a ‘carbon sink’ and the Council’s justification for this identification.

No

ID sylw: 106984

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The policy seeks to protect trees of ‘value’. It is unclear what the LPA consider is a tree of ‘value’. National policy only seeks to protect irreplaceable habitats which include veteran trees and ancient woodland (NPPF paragraph 193). The SWLP should not seek to protect every tree which is not ‘dead’ or ‘dangerous’. The policy should seek for trees to be protected ‘where possible’.
The policy also states that development will be expected to increase tree canopy cover. We object to this requirement. The feasibility of this requirement as well as its impact on the viability and a site’s ability to be delivered efficiently has not been evidenced and justified. Trees with a large canopy cover need to be properly located on development sites away from proposed built development (e.g. to avoid shading / shadowing and root damage to
hard standing). Therefore, the more trees proposed, the greater the likelihood that the developable areas of a development site will be impacted.

No

ID sylw: 106985

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the proposed requirement for developments that result in the loss of open space to only be permitted where they provide significant public benefits. This does not align with national policy (NPPF paragraph 104) and should be properly justified.
Where off-site open space provision is required, the policy seeks to ensure this is delivered within 400m. The policy will need to state that this is required ‘where possible and practicable’. Enhancements within 400m of the site may not always be achievable and should be determined on a site by site basis.

No

ID sylw: 106986

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The policy proposes that Multi Use Games Areas (MUGA) will be requested as part of Major development sites and the aspiration is that every resident will have a MUGA available to them within 15 minutes’ walk. The threshold to delivering MUGAs should only be required in line with national guidance such as the Fields for Trust guidance which sets a requirement of 0.3ha per 1,000 people. The threshold for ‘major’ development is significant. A site of just 11
dwellings could be counted as ‘major’ but it would not be appropriate for a scheme of this scale to deliver a MUGA. The provision of MUGAs should be agreed on a site by site basis.

No

ID sylw: 106987

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

This policy proposes that development provides space for growth through allotments, orchards and gardens however the policy does not set a threshold for what type and size of development should seek to provide this space, it is also not clear how much space will be required. We consider that the policy should be amended to provided more flexibility as not all development will be able to provide onsite allotments, orchards and/or community gardens and consideration on the impact on site capacity and viability is necessary.

No

ID sylw: 106988

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to draft Policy Direction 45 as it is not supported by sufficient evidence to designate Areas of Restraint. We also note that further evidence is being produced to inform the landscape character of sites and is expected to be published with the Regulation 19. It is unclear whether new areas of restraint are being proposed in Warwick District and where these will be located. Therefore, the draft policy is not considered to be justified, as required in NPPF paragraph 36.