Other

ID sylw: 108169

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.
However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.
Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities. Setting aside that broader sustainability objectives should be applied (for example, a Green Belt site on the edge of Stratford town performs significantly better than an isolated brownfield site in National Landscape) the NPPF contains no such sequential approach to previously developed land. The sequential approach to brownfield development was founded in PPS3 and PPG3 before it and was expressly removed from the NPPF ion 2012 and has not been re-introduced in any of the revisions to the NPPF since.

Other

ID sylw: 108170

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the principle that the SWLP should deliver a range of housing of differing sizes, types and tenures.
However, housing mix policies are often drafted in a rigid manner, with little opportunity for flexibility of application to reflect site specific circumstances.
For example, a town centre site is rarely able to deliver family housing, and nor need it given that town centre living is a housing market in and of itself. Conversely, with town centre sites delivering smaller housing types those sites in edge of settlement locations should deliver larger family type housing. Put simply, the policy should be drafted to allow for a range of housing types and tenures across the plan area, rather than across individual sites. The Councils could keep an up to date annual monitor to establish in each reporting year how the delivery is performing against the objectives of Policy Direction 10.
Insofar as housing tenures, the NPPF sets out what is now considered to be affordable tenures in meeting affordable housing need. We strongly support first homes and other forms of discount from open market level, which provides for ‘second tier’ affordable provision delivered by the private sector without the need for any public intervention.

Other

ID sylw: 108171

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We recognise that the SWLP is to meet a range of needs across different sectors. Gypsies, travellers, travelling show people and boat dwellers are an important components to overall needs.
The Councils should consider the strategy for delivering such needs. Specific sites could be identified for these needs, as an alternative or in combination with delivery such needs on spatial growth sites. If spatial growth sites are intended to assist in delivering these needs, site size thresholds require careful consideration; we question whether the as drafted site size threshold of 500 units is appropriate and whether a higher threshold is justified.

Yes

ID sylw: 108172

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the approach to the Core Opportunity Area, as a focus for investment in and creation of significant quantities of economic activity.
We note that Stratford town is a key part of the Core Opportunity Area, which we consider is entirely justified given its role as the financial administrative retail and leisure centre of the plan area. Consequently, we consider that Stratford should operate as the key location for housing in the SWLP, so as to co-locate housing and economic activity which is an inherently sustainable approach to land use. This is in addition to the significant role housing building plays in delivering economic activity in and of itself, at both construction and operational stages.

Yes

ID sylw: 108173

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support this policy direction. Existing cultural, tourist and leisure facilities should be protected and wherever enhanced. These cover a wide range of assets, including both built form and recreational sites such as the Welcombe Hills.

Co-locating new development in proximity to such assets has significant advantages, since new patronage supports the role of the asset and furthers people’s recognition of, and value placed in the asset. Co-location also provides the opportunity for assets to be integrated into a strategic scale masterplan for an area, and in so doing justifies consideration being given to asset enhancement via financial contributions to upgraded facilities therein, or the provision of new facilities upon a new development to serve the existing asset.

Other

ID sylw: 108174

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

Bellway recognises the implications of climate change and has a proactive approach to design to ensure development mitigates and adapts to climate change. We support measures to reduce carbon emissions through both construction and operation and recognise the Council’s ambition in setting policies which go beyond national requirements.
However, any specific requirements which go beyond the current Local Plan and national guidance need to be supported by an appropriate evidence base, including a viability assessment.
It is considered that any feasible and viable policy should be restricted to regulated energy only. As a housebuilder Bellway only has the ability to influence the regulated energy demand of homes through design and specification of materials and systems, and renewable energy technologies. The unregulated energy consumption, (often referred to as ‘plug in load’) of homes is ultimately the function of the residents’ use of the building, which cannot be influenced by the developer and therefore the requirement on the developer to reduce or offset emissions from residents’ unregulated energy use is not appropriate.
Post 2025 one of the greatest demands for unregulated energy in new homes will be to charge an electric vehicle. We consider it unreasonable to assume that a housebuilder could influence such demand or should effectively meet the cost of mitigating carbon from a resident charging their electric vehicle.
The FHS and FBS consultation states, ‘We consider that metrics which include unregulated loads are not a suitable because designers and housebuilders have little or no control over these end uses of energy’.

Other

ID sylw: 108175

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the application of Design Codes, in varying degrees of detail, consistent with the nature of the code itself - be it area wide or site specific.
Design Codes should however be prepared in consultation with promoters as key stakeholders, to ensure the code is proportionate and appropriate. Codes should support promoters’ objectives, where one site might be being delivered with a focus on GI and lower density development whereas another site might be being delivered at a higher density and seeking to support an offsite cultural asset.

A skeletal Design Code could form part of a Statement of Common ground prepared between the Councils and site promoters, applying the approach we have set out in responding to Policy Direction 5.
In all cases Design Codes should have regard to National Development Management Policies introduced through the Levelling Up and Regeneration Act 2023.

Yes

ID sylw: 108176

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the SWLP approach to prioritising access to public transport, walking and cycling routes.
Policy Direction 31 should also reference park and ride options as contributing to sustainable transport accessibility.
Applying the provisions of Policy Direction 31 it is clear that focussing development on the main towns, and locations at the main towns which have good connections including in relation to park and ride facilities, is a sound and justifiable approach.

Yes

ID sylw: 108177

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the provisions of Policy Direction 38. 10% BNG is a requirement which properly should be set out in policy.
Policy should go further and make clear that any voluntary commitment to delivering BNG beyond 10% is a significant benefit which should be put into a planning balance assessment at development management stage.

Yes

ID sylw: 108178

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the provisions of Policy Direction 43c, specifically in relation to the need for new development to deliver new open spaces. However, the guidance for new open spaces should be provided now, to enable GI strategies to be applied to Design Codes and a broader site by site assessment as to infrastructure delivery, site yield and overall site viability and thus deliverability.
We support a broad range approach to open space typologies, including in relation to food production via community orchards and allotments.