No

ID sylw: 108159

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We object to Draft Policy Direction 1.
As drafted, the policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the NPPF, and associated update to the Standard Method, were in draft form only and subject to change. However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to the Standard Method requirement and make no reference to the HEDNA.
As such, the SWLP should be taken forward having regard to Table 3 (Housing calculation 2024 NPPF Standard Method), which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62, whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF paragraph 69.
In terms of the Strategic Growth Location (SGL) options, the Emerging Spatial Growth Strategy Paper November 2024 proposes 24 locations identified for potential strategic growth. At this stage, to be able to consider reasonable alternatives, the identified strategic growth locations could accommodate significantly more land for employment and housing need, and it is not anticipated that all areas will be allocations within the SWLP. It is expected that the SWLP evidence base will continue to grow while the plan is being drawn up, and there are a number of key pieces of evidence expected after the Preferred Options consultation which will further inform the eventual selection of sites for allocation -this will include the Sustainability Appraisal, Estimation of Emissions, Green Belt review and Infrastructure Delivery Plan.
A Sustainability appraisal for this Reg 18 consultation has been undertaken, and the SGL’s have been assessed for likely impacts on the 13 SA objectives (all currently desktop) as follows:
SA Objective 1: Climate Change- no single SGL can be identified as the best or worst option for climate change due to limitations of current information.
SA Objective 2: Flood Risk – the majority of SGLS are predominantly located on greenfield land and likely to lead to loss in vegetation coverage and permeable soils which contribute to capturing rainwater and slow run-off rates. SG18 is not currently identified within the best


performing option (Coventry Airport and East of Lillington) or the worst performing option, West of Warwick.
SA Objective 3: Biodiversity, Flora, Fauna and Geodiversity – all SGLs have potential to result in adverse impacts on biodiversity. 5 SGL’s including West of Stratford-upon-Avon (SG18) lie withinclose proximity to a SSSI (within the IRZ) which indicates that consultation with Natural England will be required prior to development. SG18 is also located within close proximity to a LNR which is likely to adversely impact upon them. All SGLs coincide with LWs and have the potential to result in the direct loss and/or degradation of these habitats. The worst performing option is South of Coventry SGL.
SA Objective 4: Landscape – the majority of SGLs have potential for adverse impacts on landscape. Coventry Airport is considered to be the best performing option and West of Studley is expected to be the worst performing.
SA Objective 5: Cultural Heritage – All SGLs will have potential to result in adverse effects on heritage features and settings of conservation areas. The best performing is East of Gaydon, and the worst Southeast of Whitnash.
SA Objective 6: Pollution - All SGLs are identified to result in adverse effects to some extent with the exception of East of Lillington. The East of Stratford-upon-Avon (SG18) and West of Stratford-upon-Avon slightly coincide with the Stratford-upon-Avon AQMA, whilst the Coventry Airport and South of Coventry SGL’s lie adjacent to the Coventry AQMA. 20 SGLS are located within 200m of a main road and the West of Stratford-upon-Avon, and 4 other SGLs are located within 200m of a railway line within may impact end users in terms of noise and air pollution. The best performing option is identified as East of Lillington, and the worst is West of Stratford. This SGL lies in proximity to the AQMA, and A roads leading to the town centre and could hence worsen poor air quality within the AQMA.
SA Objective 7: Natural Resources – all 24 SGLs are expected to result in adverse impacts. 23 of SGLs comprise of land of Grade 3 and above. 23 also coincide with Mineral Safeguarding Areas. Coventry Airport is identified as the best performing option, with Bidford-on-Avon identified as the worst performing option.
SA Objective 8: Waste – the large scale residential-led development across the Plan area is likely to result in an increase in waste. No single SGL can be identified as best or worst option at this time.
SA Objective 9:Housing – all 21 residential-led and mixed-use SGLS are likely to result in a significant net gain in housing. There is currently limited information available to form ranking against this objective.
SA Objective 10:Human Health – all 24 SGLs are likely to have adverse impacts on access to one or more health receptors. 17 SGLS are located beyond 5km to a hospital with A&E services. 20 SGLs are located beyond the 800m sustainable distance to an existing GP surgery. 18 are located outside of a 1.5km distance to leisure facilities. The West of Studley SGL is identified as the best performing option with East of Gaydon the worst performing option.
SA Objective 11: Accessibility – Mixed effects have been identified against this option. East of Lillington has been identified as the best performing option for accessibility and the North of Wellesbourne and Alcester SGLS being joint worst options.
SA Objective 12: Education – all 21 SGLs with residential capacity are identified to result in negative impacts on sustainable access to education based on existing school provision. The best performing option is West of Studley and North of Leamington, the worst is East of Gaydon.
SA Objective 13: Economy: - positive effects are expected on the economy from the majority of SGLs. All except North of Henley-in Arden are located within 5km of an existing key employment location.

Other

ID sylw: 108160

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

Bellway’s site at Bordon Hill is located within Strategic Growth Area 18 – West of Stratford-Upon- Avon Group. The site is marked with a red dot and sits immediately to the southwest of Stratford Town within non-Green Belt land. (See attachment for the maps)

The site (reference number 259) has been assessed within the HELAA part A and part B and received a score of 32.00 and remains in consideration for allocation within the emerging plan. No major constraints were identified, although it is reported that 66% of the site intersects with Landscape Descriptor Units (defined areas of land with particular landscape characteristics) (LDU) with moderate visual sensitivity and 34% of the site intersecting with LDU with low visual sensitivity.

It was noted that 68% of the site is within 800m of an existing primary school and that 100% of the site is within 15km of an existing secondary school and was noted to be accessible to local services as an edge of settlement site.
Cerda Planning has been engaging with the SWLP consultation process on behalf of Bellway Homes since the initial Scoping consultation in June 2021 (when the site was also submitted to the call for sites) and the subsequent Issues and Options consultation in January 2023. They are committed to delivering residential development on this site.
We consider the site to be wholly suitable for development and have produced technical notes in relation to landscape and visual impact and highway impact, which are attached to these representations. We are in the process of producing a site layout plan which has evolved taking into account the previous reasons for refusal 18/01664/FUL dated 5/10/2018. This demonstrates that the site could deliver 100 dwellings in a sensitive way, within an area of Stratford supported by the Councils in principle within this latest version of the Plan.
The Technical Note produced by Capricorn Transport Planning notes that the site is within close proximity to the West Shottery development, which is under construction, and which will eventually provide 800 dwellings, a new primary school and a local centre, all to be served by the West of Shottery Relief Road (which connects Evesham Road with the A46 on the western side of Stratford). It concludes that the proposed scale of development is not expected to result in material traffic flow increases on the surrounding road network. Access into the site would be

taken from Evesham Road, most likely served by a new ghost-island priority junction. The straight horizontal alignment affords good visibility in both directions with no improvements to the roads alignment to achieve satisfactory visibility. The scheme would also most likely include widening of the existing footway to provide a 3m wide shared use footpath/cycleway on the south side of Evesham Road between the site access and Luddington Road, to connect with the new roundabout.
The site is highly sustainable and lies within the 400m desirable walking distance of the nearest bus stops, which are on Evesham Road near to its junction with Limes Avenue, east of Luddington Road. The nearest existing local shops are on Evesham Road, west of the Seven Meadows Roundabout. The nearest primary school is the Shottery St Andrews school on Hathaway Lane. The proposed Shottery local centre is understood to include retail facilities, a health centre and a school. All of these facilities are within or just beyond a 1km walking radius of the site shown in the figure below. ( A wider range of services and facilities is available in the town centre which is within the 2km radius of the site. The main Stratford railway station is also within the 2km walking radius).

The nearest bus stops are located on Evesham road at the junction with Limes Avenue, and within 400m of the centre of the proposed development. Local bus services available from these stops are routes 27 and 28 which connect Stratford with Pebworth, via Welford-on-Avon and Evesham, Bidford and Stratford. Summary provided below: (See attachment for the table).

Frequent trains services from Stratford station, 2km to the north-east of the site (accessible by cycle, on-foot or using the bus) are provided to Birmingham, Leamington Spa, Worcester and London Marylebone.
Records of personal injury collision show no evidence of road-safety related issues on Evesham Road immediately adjacent to the site or at the Seven Meadows roundabout to the east.
The forecast traffic flow increases arising from the proposed development are anticipated to be modest but would be fully assessed within any future Transport Assessment. Any mitigation required is likely to be to sustainable travel infrastructure – with improvements to pedestrian, cycle and public transport infrastructure which would improve access to local facilities, bus services and the railway station.
The Landscape Summary Note provided by Goldby and Luck was prepared to support these representations following a visit to the site and surroundings in February 2025. The key points are summarised below:
• The site is located within the Avon Valley landscape character area, and more specifically the Vale Orchard Belt landscape character type. The character and qualities of Vale Orchard Belt are identified as “ An open and rolling intensively farmed landscape of large poorly defined fields, orchards and prominent hilltop woodlands.”
• The characteristic features of this landscape are identified as:
o Rising ground with large scale rolling topography
o A large scale often poorly defined field pattern
o Large orchards on hilltops and south facing slopes
o Prominent hilltop woodlands
o Steep wooded scarp slopes and associated unimproved grassland
o Varied settlement pattern of small, nucleated villages and loose clusters of roadside dwellings
o Local vernacular Blue Lias stone buildings
• The prescribed management strategy for the Vale Orchard Belt is to “Enhance the structure and unity of the landscape through large scale woodland planting.”
• At a local level, the site forms part of the farmland fringe to Stratford set within a defined framework of highways, modern housing development, ribbon development with expansive gardens, the racecourse landscape and a major commercial nursery. This framework imparts an urban fringe setting to the character of the site making it distinct from the wider setting of uninterrupted farmland that extends well beyond the settlement.
• The landscape constraints are considered to be:
o The rising landform – that continues to rise sharply to the west towards the summit of Bordon Hill which is prominent in the setting of the settlement and local landscape;
o The gateway location of the site with views both into and from the settlement along Evesham Road
o The amenity of the properties at the southern boundary residing on lower ground adjacent to Luddington Road; and
o The tree and hedgerow cover associated with the northern boundary of the site.
• In the LSA the site was assessed as part of a wider land parcel S124 and assessed as being of high sensitivity to housing land. This parcel extends well beyond the site taking the whole of Bordon hill to the west and the land extending north towards Ann Hathaway’s Cottage.
• Within the context of S124, the site comprises the lower slopes of Bordon Hill that are of a much shallower gradient, consistent with developments to the north at Whittington Way that also sit on the lower slopes of Bordon Hill seen in the same panorama to the north-east of Ann Hathaway’s Cottage.
• It is concluded that the site must be less susceptible to change in the form of a settlement extension when compared to the wider setting of parcel S124, this suggests a reduced sensitivity when compared to the wider land parcel of medium sensitivity.
• A considered development brought forward in response to the above identified landscape constraints is unlikely to result in any greater harm to the character and setting of Stratford when compared to the other opportunities for the expansion of the settlement, and recent areas of expansion to the north also set across the lower slopes of Bordon Hill.
• The adoption of a landscape led approach to development proposed secures the following benefits:
o The reinstatement of the remnant hedgerow at the western boundary with new tree planting measures to secure a defined and robust landscaped edge to the development;
o A considered layout that includes designated green space capable of securing tree planting that will mature to soften the roofscape of the development. It is envisaged that this may take the form of a green edge at the eastern boundary facing the settlement, and a gateway space within the site presenting to a highway access from Evesham Road;
o The possibility of securing new woodland planting measures that extend into the field to the west (under the same ownership)- could include orchard planting and enhancement scheme entirely consistent with the overarching landscape character
o Possible public access into the field to the west taking advantage of views back across Stratford and the wider landscape setting.
Even though the wider parcel of land in which the site sits – SG18 is not one of the top scoring parcels (against the SA objectives) noted above, the site is capable of coming forward independently as a standalone site. It provides the opportunity to extend the southern edges of Stratford-upon -Avon in a logical and sensitive manner to provide much needed dwellings in a highly sustainable location. The Council can have confidence in the deliverability of the site as it is under the control of a PLC Housebuilder who will be able to bring the site forward for development very quickly in the event that it is allocated within the emerging plan.

No

ID sylw: 108161

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We do not support this policy direction and made extensive comments in the last consultation response. Our views have not changed in that new settlements can take years to come forward before housing can be delivered. This can seriously jeopardise the ability of the local plan to deliver both open market and affordable homes across the district for which there is a critical need.

Yes

ID sylw: 108162

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the approach set out in Policy Direction 3. Built Up Area Boundaries should be reviewed to take account of committed development which has occurred since the adoption of the Core Strategy, and also to take account of new allocations proposed through the SWLP to ensure that ‘countryside’ policies do not apply to allocation sites.

Yes

ID sylw: 108163

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support that the SWLP will be underpinned by a housing need and availability evidence base that considers the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and Black Country Housing Market Area.
Whilst there is evidence that there is a significant shortfall between housing requirements and supply within the Greater Birmingham and Black Country HMA, the overall scale has not been collectively quantified beyond 2031 since the GBBCHMA Strategic Growth Study 2018. The Coventry and Warwickshire Housing and Economic development Needs (HEDNA) 2022 states that Stratford-on Avon will need to consider the unmet needs from Birmingham in setting housing targets, but this figure is not quantified. It appears also that the unmet needs figures from Coventry are also not yet known. It is clear therefore that a refresh of the Strategic Growth Study is required as well as further discussions with Coventry to discuss the cross-boundary issues.
On this basis the clear indication now is that the SWLP will need to make a contribution by way of a duty to co-operate and accommodate unmet housing needs arising from outside the SWLP plan area. The policy justification states that the policies on unmet housing need will be dealt with at Reg 19 Submission stage through consideration of the draft reserve housing allocations within the Stratford-on-Avon District Council’s Site Allocation Plan. This approach is not supported, It is imperative that this unmet need is planned for now, having regard to NPPF paragraph 69. It is not appropriate to defer the duty to co operate to reserve sites – which infers that a commitment to the duty to co-operate will be deferred by stealth. The approach to deferring the duty to co-operate to the development management function as a result of a deficiency against the 5 year housing land supply position is worse still. The planning system is plan led, and the plan led system should accommodate all of the housing needs arising from both within the plan area and within the wider HMA’s. To do otherwise would be a serious failing of the SWLP, a matter which would go to the heart of the plan and not able to be rectified through any examination process/main modifications.

Other

ID sylw: 108164

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We recognise that all development proposals should provide appropriate on and off site infrastructure requirements.
This is subject to those requirements meeting the CIL tests.
Where infrastructure goes beyond that necessary to mitigate the impacts arising from development, this should be offset against other development management requirements, and/or put in the planning balance as a matter of significant weighting.
We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations. This is not a matter to be deferred to the Publication Consultation (this being the final consultation prior to the SWLP being submitted for examination).
We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options. The process should be workshop based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each subsequent workshop – to get to an agreed position by way of an iterative process. In so doing, the SWLP can be progressed and put to examination with a suite of completed SoCG’s underpinning each chosen site within the spatial growth locations, such that the Councils can be confident about the deliverability of each site and thus the soundness of the SWLP as a whole.

Yes

ID sylw: 108165

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the proposal to carry forward existing safeguarding measures as set out in the Core Strategy.
Specifically, we endorse the safeguarding at the A46/Bishopton roundabout, which is a long standing commitment and remains a key part of the strategic road network which the Councils and National Highways are seeking to improve.
Co-locating new development with safeguarded land/strategic network improvements has significant advantages. New development can assist in assimilating infrastructure upgrades in to the receiving landscape, by designing in buffers and landscape strategies avoiding the landscape and visual effects of hard engineered proposals. Furthermore, co-locating new development with network upgrades allows for a proportion of the upgrade costs to be borne by new development, which is fiscally prudent and in the public interest.

Yes

ID sylw: 108166

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the proposal to carry forward existing safeguarding measures as set out in the Core Strategy.
Specifically, we endorse the safeguarding at the A46/Bishopton roundabout, which is a long standing commitment and remains a key part of the strategic road network which the Councils and National Highways are seeking to improve.
Co-locating new development with safeguarded land/strategic network improvements has significant advantages. New development can assist in assimilating infrastructure upgrades in to the receiving landscape, by designing in buffers and landscape strategies avoiding the landscape and visual effects of hard engineered proposals. Furthermore, co-locating new development with network upgrades allows for a proportion of the upgrade costs to be borne by new development, which is fiscally prudent and in the public interest.

Yes

ID sylw: 108167

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

Policy Direction 7 – Green Belt
Although Bellway’s site at Bordon Hill is outside of the Green Belt, we support the Councils approach to undertaking a Green Belt review as an integral part of the evidence base underpinning the SWLP.
We attended the workshop run by the two Councils during which focussed working groups were formed to discuss how the SWLP housing requirements (at that time based upon the HEDNA and not reflective of the now far higher Standard Method) could be sustainably distributed across the plan area. It was clear that with a ‘policy off’ approach the distribution of housing was

challenging, in a ‘policy on’ scenario excluding the Green Belt it was not possible to deliver a sustainable development strategy. Applying the Standard Method makes the position more acute still.
It is clear therefore that Green Belt release is an essential component to the SWLP, and as a result undertaking a Green Belt Review is vital if the SWLP is to be found sound – put simply, the plan cannot proceed without Green Belt release.

Other

ID sylw: 108168

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We consider that policy should avoid expressing specific densities but instead should make reference to the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban quality, some of the Councils highest valued urban areas deliver densities at what might be considered to be very high. By way of worked example, a maisonette doubles the density of a building over a traditional house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish what each spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means that site viability, and thus deliverability, cannot be established with promoters since the infrastructure requirements will be fixed by the SWLP based upon sites with an unquantified yield.