No

ID sylw: 108331

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

No - Caddick Land do 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.

Deferring the allocation of sites does not reflect a positive approach to Plan making as required by chapter 3 of the NPPF.

No

ID sylw: 108334

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

As part of the SA process, a SA at Preferred Options stage should identify and assess ‘reasonable alternatives’ to the ‘preferred option’ in order to ‘sense check’ and justify the pursuing of the preferred strategy.

There are two issues with this approach used. The first is that the Councils have determined the reasonable alternatives themselves based upon their preferred strategy, rather than the reasonable alternatives being driven by the iterative process of the SA.

The second is that the above ‘reasonable alternatives’ are in fact the preferred development plan options that the Councils are consulting on within the SWLP; there are no alternative to the above strategies. The SA itself is clear that the SA should assess ‘development plan options
and reasonable alternatives’ [emphasis added].

For example, whilst there is no prescribed formula or procedure about which aspects of a local plan require reasonable alternatives, the Councils have not evidenced or justified how they came to the decision to pursue a two-part plan. A reasonable alternative would have been to
consider the sustainability implications of an all-encompassing local plan, inclusive of identifying
non-strategic development allocations, which has simply not been considered or assessed.

The SA suggests that ‘small settlement locations’ inclusive of developments between 50-500 dwellings were considered in the Issues and Options SA, but no explanation is provided within this SA as to why this approach was discounted.

Similarly, in respect of growth options, the Councils have only tested the prevailing standard method at the time of writing (2,188 dwellings or 54,700 dwellings across the Plan period) versus the HEDNA originally produced in 2022. The purpose of both of these methods is to determine the local housing need (LHN) for the Plan area. The SA has not tested the implications of providing growth in excess of this figure, either to boost economic growth or the delivery of affordable housing. This is despite the SA including a sequencing flowchart from the Royal Town
Planning Institute at Figure 3.1, which includes an illustration of alternative amounts of housing to be provided, such as LHN plus a 5% or 10% uplift.

This is a fundamental failing of the SA arising from the pre-determined nature of the Councils’ preferred development strategy.

Other

ID sylw: 108335

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Caddick Land 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: 108336

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

No it is evident that that ‘to find’ figure ought to be a minimum of 28,257 dwellings with a 5% buffer applied (29,670 dwellings). This figure also assumes that the Councils’ windfall estimate of 375dpa across the plan area is accurate and has been robustly evidenced and justified. No evidence has been provided to support this figure
to date.

No

ID sylw: 108337

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Draft Policy Direction 2 describes how one or more new settlements will be identified and considered for strategic site allocation where they can be developed to a suitable minimum size to provide the required infrastructure. 12 potential new settlement locations have been identified
which have been categorised as more or less suitable based on the work undertaken to date.

Whilst Caddick Land recognise that the provision of large scale development such as new settlements is supported through Paragraph 77 of the NPPF, part d) nonetheless requires Local Planning Authorities to make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Paragraph 22 similarly recognises that such developments take time to deliver and that relevant policies should accordingly be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.

Conversely, Paragraph 72 makes clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes, and are often built-out relatively quickly.

As referred to in this Representation, it is accordingly disappointing that the Councils are deferring the consideration of smaller sites to individual ‘part-two’ plans. As mentioned previously, 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.

This approach is accordingly not in the spirit of national policy.

No

ID sylw: 108339

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Draft Policy Direction 3 confirms that the SWLP will identify Built Up Area Boundaries (BUABs) for settlements in South Warwickshire. In this respect Leek Wootton is currently identified as a ‘Growth Village’ through Policy H1 of the adopted Warwick District Local Plan. Growth Villages were identified through the Settlement Hierarchy Report (2014) which underpins the Local Plan which describes Growth Villages as being “the most suitable for housing growth according to a range of sustainability indicators”. The findings in respect of Leek Wootton remain relevant.

In respect of Green Belt locations, the Draft Policy Direction outlines how small scale development will be supported where it constitutes limited infilling within Built Up Area Boundaries. This approach is not supported as it does not align with the provisions of the December 2024 NPPF, including paragraphs 153–158 which describe the circumstances in which development in the Green Belt may be acceptable.

It is not evident how the SWLP will identify small sites, given the plan is predicated on focusing on strategic development. This issue is linked back to the deferral of site allocations to subsequent two-part plan/s as described previously.

Policy Direction 3 suggests that Neighbourhood Development Plans will be relied upon to deliver housing and employment allocations in smaller settlements. Whilst Neighbourhood Development Plans are a useful tool, there is no guarantee that a Neighbourhood Plan will come forward for every small settlement and, even if they do, they often do not come forward in a timely fashion to meet development requirements.

There is a genuine risk the Councils will be unable to demonstrate a five-year housing land supply following the adoption of the SWLP, given the inherent and well documented lead-in times associated with strategic
development. To this end, it is notable that the Councils have not published a housing trajectory as part of the SWLP evidence base – this should be published as part of the next consultation.

Policy Direction 3 should explore opportunities to increase the sustainability of existing settlements. This can include including identifying sites for development that can provide or support existing or new services and facilities to benefit local communities. This is the case for Leek Wootton.

No

ID sylw: 108340

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

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.

Draft Policy Direction 4 sets out how it is yet to be established to what extent there will be any unmet need from elsewhere within these housing market areas, however, 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 sites in the north and western parts of the Plan area, which includes Land North and South of Hill
Wootton Road.

Other

ID sylw: 108341

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Caddick Land supports this approach as it aligns with the requirements of the NPPF. However, it is worth emphasising that the above paragraph, in conjunction with the Green Belt Review Stage 1 (September 2024), make clear the Stage 1 Review considers only broad parcels and areas of Green Belt and that there will be a need to undertake more detailed site-specific Green Belt assessment work as the SWLP progresses.

The Stage 1 Review methodology clarifies that this site-specific assessment will form part of a Green Belt Review Stage 2 which will consider the status of washed over villages within the Green Belt and assess these against paragraph 149 of the NPPF.

Caddick Land reserves the right to comment on the Stage 2 Review at the appropriate time and further comment is made in respect of the Stage 1 Review in Chapter 8 of this Representation in the context of the HELAA findings regarding Land to the North and South of Hill Wootton
Road.

Other

ID sylw: 108342

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Draft Policy Direction 9 confirms that the SWLP will make “full use” of urban brownfield land before development is considered in other locations.

Whilst this approach is common practice and enshrined in national policy, the Councils should ensure that any consideration of brownfield sites is robustly tested for viability to ensure deliverability. It is commonly accepted that brownfield sites often have development constraints
that render the viability of such schemes marginal, often to the detriment of affordable housing delivery.

It is submitted that the Councils should look to provide a balanced approach between using brownfield land and green field sites in sustainable locations, such as Land North and South of Hill Wootton Road, Leek Wootton.

Other

ID sylw: 108343

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Caddick Land supports Draft Policy Direction 25 - Strategic Design Principles insofar as the Policy seeks to support neighbourhoods which provide for and meet local needs, including:
 Considering mix and amount of development and getting the right range of complementary
uses.
 …Ensure[ing] that the built environment provides healthy and inclusive communities through spatial planning.
 …Support[ing] and provid[ing] for community needs through appropriate physical and social infrastructure, as well as making sure there is sufficient land provision for play, sport, and recreation.

However, as described previously within this representation, the above principles (and others within the Policy) will not be realised in non-strategic locations without a positive approach to allocating sites for development.

This is recognised in the second bullet point highlighted above, that these principles are achievable through “spatial planning” i.e a positive intervention.

At present, the SWLP does not propose any sort of spatial planning beyond strategic growth locations or new settlements.