No

ID sylw: 106989

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to draft Policy Direction 47 as it is not supported by sufficient evidence to designate Special Landscape Areas (SLAs). 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 SLAs are being proposed and where these will be located. Therefore, the draft policy is not considered to be justified, as required in NPPF paragraph 36.

No

ID sylw: 106990

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We note that further evidence is being produced to inform the landscape character of sites and is expected to be published with the Regulation 19 SWLP. We withhold comment until this evidence has been made available.
The overriding need for housing is recognised in the draft policy direction 48, Warwick District currently only has 4.01 years supply. The policy should be clear that it is not just ‘local need’ but District wide need which would outweigh landscape harm.

Yes

ID sylw: 106991

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We support the Spatial Growth Strategy set out in Chapter 4.1 of the Preferred Options document. The site is located within Strategic Growth Location SG10, Bishop’s Tachbrook Group and has been assessed as growth option rather than in isolation.
SG10 is well-located adjacent to the western edge of Bishop’s Tachbrook, south of the largest settlement in Warwick District, and is therefore located in an accessible location in close proximity to existing transport links and facilities / services.

We do not support the major negative score applied for cultural heritage (objective 5). We are aware that there is a Conservation Area and a number of listed buildings within and adjacent to Bishop’s Tachbrook but the SWLP Heritage Settlement Sensitivity Assessment has score the south west of the settlement (including our client’s land which falls within SG10, Site ID 106/150) as ‘green’ in the RAG score. The north west of the settlement scored ‘amber’. We therefore do not consider that the development of SG10 would lead to significant impacts on heritage assets.
Site SG10 also scored ‘major negative’ for natural resources (objective 7) and climate change (objective 1) but most SGLs have been scored the same.
On the SA score for SG10 against education, we do not consider that it has taken into account he recently constructed Oakley School to the north east of Bishops Tachbrook. The IDP (2025) also states that SG10 is one of only 2 SGLs to have a primary school within 800m. Similarly, the SA paragraph 5.13.2 states ‘Out of the 21 residential-led SGLs, 19 lie outside of the recommended 800m sustainable distance to an existing primary school. However, the majority of the Bishop’s Tachbrook SGL and Hockley Heath SGL areas lie within 800m of a primary school, where positive impacts have been identified for these two SGLs on access to primary schools’.
We are supportive of Objective 3 (Biodiversity) which states that SG10 is the best performing SGL for biodiversity.
SG10 is one of the best scoring SGLs for the range of existing employment opportunities within 5km and being within a sustainable distance of a GP surgery and hospital.
In light of the above, proposed SGL SG10 ‘Bishops Tachbrook Group’ is one of the higher performing SGL and it should be allocated wholly or in-part within the SWLP. Bellway’s land (Site ID 106/150) is located within SGL SG10. If the SWLP only allocates part of SG10 then detailed technical work has been undertaken for Bellway’s land to demonstrate that it is deliverable and can be delivered in the short term to meet immediate housing needs as well
as provide wider social, environmental and economic benefits.

Other

ID sylw: 106992

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway is promoting Site ID 106 and 150 which were both assessed in Part B of the HELAA.
Site ID 150 (is located within the proposed SGL SG10. Bellway strongly support the proposed allocation of their land.
Site ID 106/150 scored 33.70 overall. Across all sites assessed in Part B, the median score was 45. We note a lower score is considered better and therefore the Site’s score reflects a positive assessment and means the site is much better performing than the majority of sites assessed in the HELAA.
The site is located on the edge of an existing growth settlement which offers a range of services and facilities and is served by public transport which connects the site to other settlements such as Whitnash, Leamington Spa and Warwick. Bishop’s Tachbrook is also one of very few settlements within Warwick District that is not located within the Green Belt or restricted in terms of landscape or ecological designations.
Site ID 106/150 offers the opportunity for much needed housing delivery in the immediate term. From current SWLP evidence that is available, the HELAA has positively assessed the site.
In light of the above, Site ID 106/150 should remain as a proposed residential allocation within the SWLP.

No

ID sylw: 107786

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to Policy Direction 1 as the policy sets out both the Coventry and Warwickshire Housing and Economic Development Needs Assessment (2022 HEDNA) and Standard Method figures for the number of dwellings required for Warwick and Stratford across the plan period.
The HEDNA (2022) sets out a housing need of 41,975 dwellings for the 25-year plan period. This document was prepared over 2 years ago and does not reflect the recent changes to the Standard Method (December 2024). The Standard Method identifies a minimum housing need of 54,700 dwellings over the plan period. The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.

Other

ID sylw: 107787

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We note that a New Settlement is proposed to be allocated for strategic growth in a sustainable location. Although we do not object to a proposed new settlement, new settlements take a significant amount of time to deliver and it will therefore be important to allocate a sufficient number of sites which can be delivered in the short term, such as Site ID 334-336.
The NPPF is clear that where new settlements are proposed in plans, the policies should be set within a vision that looks further ahead, at least 30 years, to take account delivery timescales (paragraph 22). The SWLP will only cover the period of 25 years up to 2050 and should therefore be extended.

No

ID sylw: 107788

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We consider that settlement boundaries should not be revised in the SWLP as the SWLP is only seeking to allocate strategic sites, smaller scaled allocations will be required in the Part 2 plans and the location of those Sites should not be dictated by the BUAB.
The Policy also states that the SWLP will support Neighbourhood Plans allocating sites. We acknowledge that there may be a role for some growth to be identified in Neighbourhood Plans, however, the SWLP has no control on when NPs will be produced or reviewed to accommodate growth and therefore, there should not be an over reliance on NPs delivering growth. Major and small scale sites should be allocated as part of any future Part 2 plans. Any growth directed to NPs will need to set a specific requirement and the LPAs should be satisfied that the NPs will progress and deliver much needed housing within the plan period.
The Policy lists a number of criteria where small-scale development on unallocated sites will be supported. The Policy needs to be updated to accord with changes in national policy relating to Green Belt development (NPPF paragraphs 154 – 159). In relation to non-Green Belt locations should include definition of small scale and a ‘threshold site size’ for growth adjacent to sustainable settlements. The policy as worded is not clear or justified (NPP paragraph 36). Long Itchington is a sustainable settlement but it does not fall within the SWLP Priority Area. We object to Priority Areas being used to direct small scale development. These areas are appropriate when considering strategic development but not small scale development.

No

ID sylw: 107789

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to draft Policy Direction 10 that providing the right tenure and type of homes will only have regard to the latest evidence. This should be one of a few factors. The latest evidence is the Coventry and Warwickshire HEDNA 2022, which, as already stated above, is based on the old standard method figures. Existing evidence will become out of date during the lifetime of the plan. Housing mix and tenures should be left to be agreed on a site-by-site basis and informed by market demand at the time of the application as that is the best indicator of need.

No

ID sylw: 107790

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the proposed requirement development sites of over 100 dwellings to deliver 5% self-build and custom-build plots. There is no evidence to justify the requirements for allocating a percentage of plots on sites to provide custom-self build and whether there is a projected need to identify this level of provision. There is also no specific requirement in the PPG (reference 57-025-20210508) to require allocated sites to deliver self and custom build plots.
We are aware that Stratford on Avon District Council produce an annual position statement (December 2024) which sets out the demand for Self-build and Custom Housebuilding. The demand in Warwick District differs to the demand in Stratford District, therefore we object to the blanket approach of 5% for all developments of more than 100 dwellings. We consider that the LPAs should continue with the approach which provides overall support for self-custom build development but leaves it to the housing market to deliver plots when demands arises or allocate specific sites to deliver self and custom built plots to meet identified need where evidenced.

Other

ID sylw: 107791

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway are generally supportive of draft Policy Direction 28 which states that ‘Development that supports the regeneration of canals and would improve access and sense of place will be supported’. However, contributions sought to deliver restoration of canals/waterways as part of a development must be fair, directly related and acceptable in planning terms, paragraph 58 NPPF.