Other

ID sylw: 107792

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We are generally supportive of draft Policy Direction 31.
The second part of the Policy proposes to require developments to demonstrate that they will incorporate or contribute towards the provision of cycle lanes, pedestrian paths and public transport and public transport links should be integrated into the development. The policy should specifically note that not all development will be of a scale to enable public transport links through the site. Additionally, only developments subject to a S106 Agreement would be able to contribute to off-site sustainable access improvements and any requests for upgrades will be required to demonstrate that they are complaint with Section 122 of the Community Infrastructure Levy Regulations 2010.

Other

ID sylw: 107793

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 policy should be clear that it is not just ‘local need’ but District wide need which would outweigh landscape harm.

Other

ID sylw: 107794

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The SWLP is seeking to allocate strategic sites. Bellway has no objection to this approach but considers that the SWLP needs to be clear that additional sites which are not in these strategic locations but adjacent to other sustainable settlements in the Districts will be supported and may be allocated in the Part 2 plan.
Long Itchington is identified as a Category 1 (most sustainable) village for sustainability in the adopted Stratford on Avon Core Strategy. Long Itchington is sustainable and, although it may not be an appropriate location for strategic scaled growth, it will be able to accommodate major housing development. Settlements which are not currently proposed to be the subject of ‘strategic’ growth in the SWLP should not be dismissed as unsuitable for any level of growth across the plan period. The SWLP should be planning for all scales of growth.
The Sustainability Appraisal (SA Preferred Options) only assesses the Strategic Growth Locations but we consider that all sustainable settlements, such as Long Itchington, should be assessed for their potential to accommodate growth.

Yes

ID sylw: 107795

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Site ID 334, 335, 336
Bellway’s land adjacent to Long Itchington (Site ID 334, 335 and 336) were all carried forward to be assessed in Part B of the HELAA.
Long Itchington is a sustainable settlement suitable for accommodating housing growth within the plan period. We consider that additional areas / sites outside of Strategic Growth Locations should be allocated for development that can come forward in the short to medium term.
In the submitted Vision Document, Bellway has set out different promotion options for Site ID 334, 335 and 336 depending on the scale of growth which is directed to Long Itchington. The sites are directly adjacent to Southam Road which connects the site via public transport to Leamington Spa, Rugby and Daventry. We consider that Long Itchington should be identified for growth given its location on a key transport route, the range of shops, services and facilities provided and that it is one of the few sustainable settlements that is not located within the Green Belt, AONB or Special Landscape Area. • Option 1 - Northern site only - Circa 45 – 55 dwellings (30 – 35dph).
• Option 2 – Northern and Central sites – Circa 80 – 100 dwellings (30 – 35dph)
• Option 3 – Northern, Central and Southern site 100+ dwellings as well as potential community uses and / or school if required.
The HELAA assesses the sites as follows:
• Site ID 334 Land to West of Southam Road, Long Itchington (North) scored 45.5 overall (1.71ha).
• Site ID 335 Land to West of Southam Road, Long Itchington (Central) scored 54.9 overall (2.28ha).
• Site ID 336 Land to West of Southam Road, Long Itchington (South) scored 62.9 overall (10.98ha).
Across all sites assessed in Part B, the median score was 45. We note a lower score is considered better and therefore the site ID 334 score reflects the most positive assessment of the three sites. In comparison to sites assessed in and around Long Itchington, Site 334 (north) is the joint lowest scoring parcel which we consider reflects that it is one of the most suitable locations for housing growth adjacent to Long Itchington.
In the ‘Settlement Design Analysis’ (January 2023), Site IDs 334 and 335 are category ‘B’ out of 9 categories and Site ID 336 is category C, ‘A’ being the best connectivity to a settlement. Therefore, the HELAA recognises the sites, particularly 224 and 335, are in a sustainable location.
The only potential concern raised in the HELAA relates to potential heritage impact. The Sites are within an area assessed as ‘Red’ in the HELAA and Heritage and Settlement Sensitivity Assessment (2022). CSA Heritage has produced a Heritage Note (February 2025) which is submitted with this response. CSA consider that the assessment is not consistent with the heritage sensitivity of the Site due to the incorrect assessment of the Site’s relationship with the Long Itchington Conservation Area. The ‘Red’ score does not take into account the presence of woodland between the Sites and the Conservation Area which differentiates it from land assessed further west. We therefore consider that the assessment of the Site, and subsequent score applied in the HELAA, should be amended.

No

ID sylw: 107796

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.
Table 5 sets out a list of proposed Strategic Growth Locations (‘SGL’). Bellway’s land is included as part of the proposed SGL SG19 ‘East of Stratford-on-Avon’. Bellway strongly supports the proposed allocation of SGL SG19 and their land interests. Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon). This land is not constrained by Green Belt and is in a highly accessible location adjacent to a Growth Settlement and in close proximity to the most sustainable settlement in Stratford district.

Other

ID sylw: 107797

Derbyniwyd: 15/06/2025

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-medium term, such as Site ID 471/466 within proposed Strategic Growth Location SG19. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).
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: 107798

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the part of the Policy which 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.

Other

ID sylw: 107799

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We are generally supportive of draft Policy Direction 31.Bellway’s land (Site reference 466/471) is part of proposed Strategic Growth Location SG19 which has been identified for growth and the settlement is also located in Priority Area 3, therefore is considered a sustainable and accessible location suitable for accommodating growth. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).

The second part of the Policy proposes to require developments to demonstrate that they will incorporate or contribute towards the provision of cycle lanes, pedestrian paths and public transport and public transport links should be integrated into the development. The policy should specifically note that not all development will be of a scale to enable public transport links through the site. Additionally, only developments subject to a S106 Agreement would be able to contribute to off-site sustainable access improvements and any requests for upgrades will be required to demonstrate that they are complaint with Section 122 of the Community Infrastructure Levy Regulations 2010.

Yes

ID sylw: 107800

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. Bellway’s Land (Site ID 471/466) is located within proposed Strategic Growth Location (SGL) SG19, East of Stratford Upon Avon, and has been assessed as wider growth option rather than in isolation. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).
The Sustainability Appraisal (SA) has assessed the 24 proposed SGLs against 13 objectives.
SG19 is extremely well-located and in close proximity to the eastern edge of Stratford-on-Avon, which is the largest settlement in the District. SG19 is therefore located in close proximity to existing transport links and facilities / services and employment opportunities. This accessibility is reflected in the SA with SG19 being the 4th best performing SGL against SA objective 11, for accessibility and performs well against Objective 13 (economy).
We note that SG19 scored ‘minor negative’ for landscape (objective 4). A Landscape Assessment has not yet been published to support the SWLP so it is unclear how this has been evidenced. The Landscape is not statutorily designated in this location so we assume this score is a result of the site being greenfield and on the edge of a settlement. Further evidence is required to justify the score in the SA. However, we note that compared to the other SGLs, SG19 scores well comparatively.
Furthermore, we do not support the ‘major negative’ score applied for cultural heritage (objective 5). We expect this assessment is likely been deduced as the SG19 site covers a wider land interest than Bellway’s land which is not constrained by any heritage assets. This is confirmed in the HELAA which concluded that Site ID 471/466 scores ‘Green’ for heritage, meaning ‘the location/site does not include any designated heritage assets, and it is unlikely to directly impact upon the setting of any heritage assets’ (HELAA methodology November 2024).
As the largest and most sustainable settlement in the District, the most housing growth should be directed to Stratford-on-Avon and SG19, and Bellway’s land, is well placed to deliver this growth.
In light of the above, proposed SGL SG19 is one of the higher performing proposed SGL in the SA and it should therefore be allocated wholly or in-part within the SWLP. Bellway’s land (Site ID 466/471) is located within SGL SG19 and has been assessed positively within the HELAA. We therefore strongly support the proposed allocation of SG19 and Site ID 466/471.

Other

ID sylw: 107801

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway’s site (Site ID 466/471) is located within the proposed SGL SG19. As stated in our separate responses, Bellway strongly support the proposed allocation of their land. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).
Site ID 466 scored 34.40 overall and Site ID 471 scored 33.30 overall. Across all sites assessed in Part B, the median score was 45. We note a lower score is considered better and therefore Site ID 466/471 score reflects a very positive assessment and is better performing than the majority of sites assessed in the HELAA.
In the ‘Settlement Design Analysis’ (January 2023), Site ID 466 has also been given a ‘connectivity grade’ of ‘B’ which is good connectivity. The SWLP evidence base therefore recognise that the Site ID 466/471 is in a sustainable and accessible location.
Site ID 466/471 is located on the edge of the largest and most sustainable settlement in the District which offers a wide range of services and facilities and is served by public transport. The Site is also not located within the Green Belt or restricted in terms of any landscape or ecological designations. Site ID 466/471 also offers the opportunity for housing delivery in the short term as it is in single ownership and being promoted by a housebuilder.
In light of the above, Site ID 466/471 should remain as a proposed residential allocation within the SWLP.