Other

ID sylw: 101844

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

Creating a new standalone settlement of 6000+ homes is extremely challenging due to the required infrastructure and associated costs. There is a commercial Catch-22 since much infrastructure must be provided up-front for sustainable growth. New residents are required to sustain the infrastructure but without infrastructure sales rates will be lower. This impacts viability.

This is illustrated by Meon Vale which was acquired in 2004, allocated in the July 2006 Local Plan Review, received a first planning permission for 500 in 2010, and 550 further homes in 2015. Adopted allocation to completion of 1,050 homes has taken almost 20 years.

See our representations for Section 4.5 for further comments where we explain how these challenges can be overcome and the clear sustainability merits of focusing strategic development on large sites well-related to existing settlements. Land at Welsh Road and Daventry Road, Southam can deliver 1,500 homes in the plan period and the HELAA B indicates it outperforms all but one of the 1,000+ home locations. This is partly because residents would have immediate access to existing services and facilities.

Other

ID sylw: 101850

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

No objections to the Vision as drafted but it should more strongly articulate the drive for sustainable growth to reflect the Labour Government’s ambitions and the significant changes in national policy. The wording could be more assertive regarding the necessity to meet the community's needs and enhance housing delivery.

The same goes for the Strategic Objectives. We recognise Strategic Objective 2 relates to meeting South Warwickshire’s current and future housing needs. However, the language of this objective is passive and not as proactive as we consider necessary.

There is a national housing crisis. Stratford-upon-Avon and Warwick are the first and fourth most unaffordable authorities to live in the West Midlands region. The cost of housing combined with recent inflation has resulted in a cost of living crisis. This means many households cannot afford to but or rent suitable accommodation.

We consider there should be greater emphasis on housing affordability, meeting needs and working proactively to deliver a boost to housing supply. This would set the tone for following policies. In later representations we comment on the draft policies themselves and how they could respond to the housing crisis with a more positive and ambitious approach.

No

ID sylw: 101896

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

It's unclear what status SGLs will have in developing future versions of the SWLP. The Southam SGL is a suitable, sustainable, deliverable opportunity for strategic-scale development. However, the parcel selection is illogical, which impacts assessment in the Sustainability Appraisal. Land at Welsh Road and Daventry Road, Southam was not included in the SGL despite better HELAA performance than other Southam sites to the west and north. The site is within the Spatial Growth Strategy Priority Area, while some sites included in the SGL are not. Inclusion of less sustainable sites skews Southam's outcomes.

A fairer, more robust approach would be to select the best-performing HELAA sites to test the merits of the SGLs. The SA methodology is too rigid and applied to large, unconnected areas of land without accounting for the proposed form of development or mitigation measures. The SA outputs have little value for plan-making. Of greater value are site-specific assessments through the HELAA combined with an understanding of the broad sustainability of places.

Specific comments on SA Objectives for SG12:

Climate Change
Agree all SGLs should have the same score. This should be "0" in the absence of any detailed analysis on the climate change impact of not meeting future growth needs.

Flood Risk
All sites should be assigned "0". Testing broad areas without regard to form, scale or mitigation is meaningless.

Biodiversity
Masterplanning measures could avoid or mitigate development impacts on protected habitats. The broad comparison is helpful so retain same scores.

Landscape
Particularly sensitive to site-selection. In Southam land to the west is considerably more sensitive than land to the east. If better-performing locations were selected as part of the SGL then lower impacts would have been assessed. Revise to '-'.

Cultural Heritage
Particularly sensitive to site selection. Selecting Land at Welsh Road and Daventry Road, Southam rather than more sensitive land to the West would reduce the impact of the SGL. Revise to '-'.

Pollution
Meaningless without clear understanding of the proposed form and type of development. Score should be same for each SGL but no rationale for this being negative.

Natural Resources
Land to the South and East of Southam is Grade 3 and 4 with no BMV. We suggest minor negative rather than major negative. Currently 23 of 24 SGLs are scored equally against this objective despite national Planning Policy prioritising use of non-BMV land.

Waste
Agree SGLs should score equally but not major negative. New homes are needed and no reason to assume the SGLs are worse than alternatives.

Housing
Score agreed.

Health
Meaningful assessment impossible without further details on proposals. Consistent minor negative not unreasonable.

Accessibility
Agree with a consistent score. Strategic sites would enhance public transport and active travel. Measuring performance without understanding opportunities for enhancement through development would be incomplete.

Education
Consistent neutral score is the only option until a more in-depth analysis is carried out of existing provision and opportunities to enhance through growth.

Economy
Support consistent positive score as all residential-led SGLs will have a positive impact.

Other

ID sylw: 101983

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

Draft Policy Direction 1 still makes reference to the HEDNA. This may be relevant to the economic requirement but NPPF Paragraph 62 is clear that the Standard method must be used as the basis for calculating housing requirements. All references to the HEDNA should be removed from sections applying to the proposed housing requirement. The policy should also be changed to make it clear that the 54,700 dwellings to be planned for through the SWLP is a minimum rather than an "up to" figure. This is essential to comply with Paragraph 62 as well as 36(a) and 36(d) of the NPPF.

Table 3 lists sources of housing supply and a residual "to-find" figure to be delivered through new allocations. It isn't clear whether this represents all sites with a permission or a 'discount' has been applied for non-delivery. There is also an assumption of 375 dwellings on windfall sites. The supporting text should explain the evidence these numbers have been derived from. The only relevant evidence on the website is the Urban Capacity Study which has a figure of 19,950 dwellings rather than the 26,443. It is difficult to judge the soundness of the emerging SWLP without this information.

Other

ID sylw: 101991

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

We agree that sustainable development on brownfield land should be maximised before development on greenfield land is proposed.

However, not all brownfield land will be suitable for residential development. These reasons may not be known during plan-making particularly if they relate to contamination or ground condition. In some cases demolition and remediation costs may make a site unviable entirely or reduce viability such that it cannot contribute fully to infrastructure or affordable housing. Available brownfield land may also be suitable for a range of uses other than housing. "Suitable, viable and" should therefore be inserted before "available" in the description of the spatial hierarchy and calculation of capacity from such land and its contribution towards meeting growth needs must be pragmatic and cautious.

We agree with concentrating greenfield development in fewer, larger areas of strategic growth, which is compliant with NPPF Paragraph 77, while noting there is an important role for smaller-scale development to meet localised housing needs in various settlements within South Warwickshire. Large strategic sites are well placed to deliver significant growth alongside and in conjunction with supporting infrastructure. We expand on this elsewhere in our representations on Land at Welsh Road and Daventry Road, Southam.

Other

ID sylw: 101999

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

The December 2024 revised NPPF is clear that the plan-making authority must plan for a scale of growth accommodating their own local housing need as defined by the Standard Method and, where appropriate, some or all of the local housing need of the neighbouring authorities if those needs cannot be accommodated within their respective authority areas. In particular see paragraphs 24, 27, 36 and 62. If an unmet need from a neighbouring authority exists, t is a responsibility of the plan-making authority to engage through the duty to cooperate to determine where that need is to be accommodated.

The SWLP acknowledges a degree of uncertainty regarding unmet need from neighbouring authorities. The new NPPF paragraph 28 is clear that statements of common ground should be produced during the plan-making process. If there is still uncertainty at the time of the Regulation 19 production, it is therefore incumbent upon the authorities to come to an evidenced judgement and to uplift the housing land supply to reflect those needs.

We see no need to designate 'reserve sites' separately to other allocations. It would fit better with the NPPF to simply uplift the housing requirement and allocate sufficient land.

Other

ID sylw: 102006

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

Our other representations argue for caution in selecting and allocating new communities. Availability of infrastructure such as public transport, services and facilities is a particular challenge for standalone settlements lacking a close functional relationship to an existing large town. Historic settlements contain more and a wider variety of services and facilities than would be planned for a new settlement as their commercial cores pre-date large supermarkets and internet shopping. It is inconceivable that a new settlement with a similar number of residents and households to Southam would have a similar range of services and facilities. These promote internalised trips and make communities more vibrant and attractive for residents.

Therefore we suggest a sustainable growth strategy should be focused in locations which already have a wide range of local infrastructure in close proximity. This will reduce need to travel and create attractive places to live consistent with the Vision and Strategic objectives. Investment can be focused on enhancing and supplementing existing infrastructure, to benefit both new residents and existing communities. Existing facilities will be available to the first residents of new developments rather than waiting for a critical mass before the first shop and school. Combined existing and future residents will provide greater critical mass to support sustainable public transport and provide opportunity to use existing services from the outset rather than subsidising lengthy new routes.

Other

ID sylw: 102014

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

Large scale developments such as that proposed at Land at Welsh Road and Daventry Road presents an opportunity to deliver a wide variety of house types, sizes and tenures in order to respond to local housing needs. We therefore have no objection to the broad policy approach and would indeed anticipate contributing towards its principles and purpose through the proposed development.

Other

ID sylw: 102015

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

The Government response to the consultation on housing accessibility standards in 2022 concluded that Building Regulations ought to be changed to require that all new homes are M4(2) compliant, but this change has not been implemented. Current Paragraph reference ID: 63-009-20190626 of the PPG states that the accessibility standard must be based upon evidence of need, viability and a consideration of site specific factors, and should not be applied to all development proposals as currently proposed in Draft Policy A. Current policy guidance must be followed, and as the Government's intended implementation mechanism for changes to accessibility standards is the Building Regulations any change in the government position would automatically come into force as compliance with Building Regulations is mandatory.

Other

ID sylw: 102049

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

We understand why the Council would look to include a policy approach which duplicates the requirement of the Environment Act to provide a 10% Biodiversity Net Gain (BNG) on site. We do however question whether there is any merit in doing so since the requirement is covered by separate legislation and therefore has a higher status than a development plan policy in any event.
Notwithstanding, there is potential for the details of national BNG policy to change and, over time, for the legislation and local plan policy to diverge. On balance therefore we recommend removing the policy and leaving the requirements to deliver BNG to separate legislation.