No

ID sylw: 107783

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

It is apparent from the consultation version of the SWLP that it is now intended for the Development Plan for Stratford and Warwick Districts to comprise two parts; the SWLP as a ‘part one’ plan which considers strategic issues within South Warwickshire (including strategic
site allocations), followed by further ‘part two’ policy documents which would come forward and prescribe “…detailed policies for specific areas, neighbourhoods or types of development. This could include allocating sites and the provision of infrastructure at a local level, establishing design principles and setting out other more detailed planning policies.”
A two-part Development Plan was not suggested as part of the previously Regulation 18 consultation on the SWLP and is therefore a new proposition.
Catesby Estates does not support a two-part plan as it represents a failure of both Councils to properly grasp the difficult issues and decisions that need to be made in terms of allocating sites at the local level and delivering the development needs of South Warwickshire.
In all likelihood, the deferral of these issues to a part-two plan will result in three to five years delay whilst any subsequent plan is prepared, submitted for examination and subsequently implemented. It is also an inefficient duplication of Council resources.
This failure to make difficult decisions is particularly evident given section 1.4 of the SWLP identifies that:
“Some policy topics that would typically fall within Part 2 of the plan have been transferred to this Part 1. Given priorities within the two Councils it has been deemed
necessary to advance the creation of these policies. A list of these expedited policies can be seen below:
• Arts and Culture
• Climate Resilient Design
• Design Codes
• Multi-functional Sustainable Drainage Systems
• Outdoor sports and leisure
• Trees, Hedges and Woodland
• Parks Gardens, food Growing Open Space and local green space
• Providing the Right Tenure and Type of Homes
• Providing the Right Size of Homes
• Protecting Community Facilities
• Water Efficiency
• Whole Life Cycle Carbon Emissions Assessments.”
This list is clearly comprehensive and includes the vast majority of issues that would be expected to be covered by a part-two plan, except for the allocation of local sites for development.
This deferral does not reflect a positive approach to Plan-making as required by Chapter 3 of
the NPPF.

Other

ID sylw: 107784

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Catesby Estates broadly supports the Vision and Strategic Objectives as laid out within the
SWLP. However, it is submitted that Strategic Objective 2 (Delivering homes that meet the needs of all our communities) could be strengthened to make clear that the SWLP will also look to meet any unmet housing needs arising from neighbouring authorities within the Coventry and Warwickshire Housing Market Area.

No

ID sylw: 107785

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

No as the NPPF says that the Standard Method represents the minimum local housing need that should be planned for. The SWLP should plan for 2,298dpa or 57,435 over the plan period as a minimum. Catesby Estates strongly submits that the Councils should plan for a greater level of growth than this in order to meet affordable housing need and maintain previous levels of economic growth. The 'to find' figure ought to be a minimum of 28,257 dwellings with a 5% buffer applied (29,670 dwellings). This assumes that the windfall estimates of 375dpa is accurate and robust.

Yes

ID sylw: 107918

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

SG01 South of Coventry Group

Paragraph 146 of the NPPF is clear that exceptional circumstances to justify the release of Green Belt land for development include instances where an authority cannot meet its identified need for homes through other means. It is evident that the overwhelming need cannot be met without Green Belt release and exceptional circumstances accordingly exist to justify this approach.
Catesby Estates strongly agrees with the proposed SG01 (South of Coventry Group) Strategic Growth Location and consider the proposed location to be highly sustainable, given its proximity to the existing conurbations of Coventry and Kenilworth.
It is a basic principle of sustainable growth to identify and develop locations which are within close reach of existing facilities and employment opportunities by sustainable means other than the private car (such as walking, cycle and public transport). The development of the area south
of Coventry would represent such a development, given the prevalence of services and employment opportunities within Coventry that are already frequented by residents of South Warwickshire.
This is reflected within the Interim Sustainability Appraisal of the South Warwickshire Local Plan (December 2024) prepared by Lepus Consulting, which indicates that location SG01 generally scores among the most sustainable of the strategic growth locations against sustainability criteria such as accessibility and economy.
In this regard, Catesby Estates is continuing to promote Land at Gibbet Hill Road for a residential-led development. Land at Gibbet Hill Road falls within the Strategic Growth Location south of Coventry and accordingly constitutes a sustainable location for development.

Yes

ID sylw: 107919

Derbyniwyd: 13/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Catesby Estates strongly support Draft Strategic Growth Location SG01 (South of Coventry Group) as described above.
Specifically in respect of Catesby Estates’ interest at Land at Gibbet Hill (HELAA Ref: 122), the findings of the HELAA are largely supported (included at Appendix 4).
Detailed comments are provided in relation to:
- Green Belt - GB scores do not total 100%, Initial Landscape and Visual Appraisal findings mean that the HELAA overstates the site's contribution to the purposes of the Green Belt
- Grey belt - the site is considered to have limited or no contribution to purposes a), b) and d) based on the LVIA and does not have any 'footnote 7' designations and so meets the definition of 'grey belt'.
- Flood zones - these are peripheral to the site and so should be scored as zero
-Ancient woodland - Tocil Wood is outside of the site and so should score as zero.

Yes

ID sylw: 107920

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Under the Duty to Co-operate, the Council is obliged to engage proactively with neighbouring authorities to address strategic cross boundary issues. This includes a potential need to accommodate ‘unmet need’ from the Coventry and Warwickshire Housing Market Area (HMA)
and the Greater Birmingham and Black Country HMA. While both Stratford and Warwick districts are located within the Coventry and Warwickshire HMA, only Stratford lies within the Greater Birmingham and Black Country HMA.
The most recent GBBCHMA Position Statement Addendum was published in April 2023, reporting a total shortfall of some 106,654 dwellings with total contributions of only 18,181 dwellings committed. These figures are now out-of-date on account of Local Plan progress and revisions to the calculation of Local Housing Need derived from the Standard Method. However, it is understood that work is underway to update the Position Statement to 2025, and we still expect this work to still identify a significant deficit in supply across the GBBCHMA. This shortfall should be taken into account in the preparation of the South Warwickshire Local Plan.
Draft Policy Direction 4 sets out, the Councils will commit to “continually consider this need and work with those authorities on how this can be achieved.”
In this regard, Draft Policy Direction 4 suggests that reserve sites will be released for this purpose, or when the relevant authority’s 5-year housing land supply calculation falls below the thresholds set out in national planning policy guidance.
Whilst this is commendable in theory, it is not understood how the Councils intend to allocate reserves sites through the SWLP when the scale or type of development need has not yet been determined. For example, there is no direction as to the scale or number of sites that are
required.
Nonetheless, regarding location, it is logical to look to deliver unmet development needs as close as possible to where they arise. This principle further supports the allocation of land adjacent to the southern edge of Coventry, including Land at Gibbet Hill, although this should be brought forward as an allocation rather than a reserve site.

Yes

ID sylw: 107921

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Draft Policy Direction 7 states that:
“The SWLP will take a sequential approach to allocating strategic areas of growth and new settlements. Further evidence will be gathered on the relative sustainability
of each of these areas. Some of this evidence will come from the Stage 2 Green Belt review, regarding the contribution an area makes to Green Belt purposes, and the impact on the wider Green Belt if an area was to be released. This additional evidence will enable a considered assessment of whether there are sufficient
sustainable non-Green Belt locations to accommodate South Warwickshire’s housing and employment land needs. If so, then there will be no requirement to release land from the Green Belt. However, if there are clear sustainability benefits to utilising one or more Green Belt locations, then this will form the basis of an argument that “exceptional circumstances” exist to justify releasing that land from the Green Belt.”
Catesby Estates supports this approach as it aligns with the requirements of the NPPF.

Yes

ID sylw: 107922

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Catesby Estates supports the approach set out within draft Policy Direction 14 and, in particular, the recognition of the importance of area MIS.4; South of Coventry Area including Coventry Airport, Coventry Gateway and the National Battery Innovation Centre.
As rightly set out within the SWLP, the area of South Warwickshire to the south of Coventry has started to see considerable growth. Strategic allocations in the current Warwick District Local Plan include large housing sites at Kings Hill and Westwood Heath as well as a sub-regional
employment site to the south of Jaguar Land Rover’s Head Quarters at Whitley. Warwick University and Coventry Airport are also located within the area and a planning application has been granted for a battery gigafactory on the airport site to support the country’s shift towards electric vehicles and ultimately carbon neutrality. This development could complement existing facilities in the area including the Battery Industrialisation Centre, facilities at JLR and Warwick Manufacturing Group at the University. Significant transport infrastructure improvements have been implemented, are ongoing and are being explored in the area. These include a new bridge over the A45 and transport improvements to connect JLR/Whitley Business Park to the new
sub-regional employment site comprising Whitley South and Coventry Gateway. A new scheme will see a new bridge across the A46 and a new signalised gyratory system at the Stoneleigh Junction of the A46. Further transport investment is being considered in the area. The potential for a new railway station near Kenilworth is being explored. A possible transport corridor, potentially incorporating Very Light Rail and to cater for other sustainable travel modes connecting the new Stoneleigh Junction to Warwick University and with strategic connections towards the proposed HS2 Interchange at UK Central in Solihull is also being explored.
The above investment opportunities further lends credence to the allocation of residential growth
within Strategic Growth Location SG01 South of Coventry, in order to best co-locate homes, employment opportunities and infrastructure investment.

No

ID sylw: 107923

Derbyniwyd: 16/06/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

The preamble to Draft Policy Direction 38 correctly identifies that the Environment Act mandates that Local Planning Authorities may seek greater than 10% net gain for biodiversity, but only where there is justified local need.
Draft Policy Direction 38 then goes on to state that all development must achieve a minimum of 10% BNG.
However, it then goes on to state that “as work on the SWLP progresses we will explore evidence to seek a higher percentage of BNG above the statutory 10% requirement to achieve greater biodiversity benefits.”.
In this regard, Planning Practice Guidance (PPG) states:
Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for
development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher
percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.
Paragraph: 006 Reference ID: 74-006-20240214
In the context of the above, ‘local need for a higher percentage’ is considered to refer to areas where biodiversity is demonstrably in decline, thus requiring a greater percentage gain as compensatory mitigation. Similarly, viability evidence at the local level needs to be provided.
At present, the SWLP does neither of the above and accordingly any requirement for biodiversity net gain in excess of 10% is not justified.

No

ID sylw: 107924

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Draft Policy Direction 39 states:
“We will aim to have a policy that requires development to contribute positively to the natural environment by providing measurable net improvements in biodiversity and ecosystem services. The initial focus will be on BNG and carbon sequestration, but the policy will be updated to incorporate other ecosystem services as a comprehensive ENG framework is developed.”
The supporting text to this policy confirms that the intention is that this policy look at all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience and carbon sequestration, and will look to address these in tandem to ensure an overall net gain in ecosystem services.
Whilst this approach is commendable, it is difficult to foresee how such a policy will be formulated to deliver measurable outcomes. The evidence base for the SWLP must also include a thorough assessment of the viability of this policy to ensure that it does not unduly stifle
development.