Other

ID sylw: 107803

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

We support the vision. It reflects Paragraph 7 of the NPPF which states that the purpose of the planning system is to contribute to sustainable development. The overarching principles do not align with the vision. None of them refer to delivery of homes and jobs which are key to sustainable development. Reference must be made to this to then feed into the Strategic Objectives which do reference housing and employment. The selected spatial growth strategy, ‘Sustainable Travel and Economy’ should be referred to and woven into the other principles.

The vision and first principle strongly emphasizes the climate emergency. While generally supported this should not dominate the vision and strategic objectives to the detriment of delivery of development to meet identified needs. The second principle refers to a beautiful south Warwickshire. This is supported and Paragraph 131 of the NPPF makes reference to beauty but this needs to be defined and supported by guidance on what it means in practice.

The Strategic Objectives cover the social, economic and environmental dimensions of sustainable development as set out in Paragraph 8 of the NPPF and they are therefore considered consistent with national policy.

No

ID sylw: 107807

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction seems to suggest this is the maximum number of homes. Additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall allowances should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. The latest analysis from Landstack indicates that using the new Standard Method results in a supply of just 2.96 years. Following a recent appeal decision it has been confirmed Warwick District does not have a five year land supply. Specific deliverable sites must be allocated for housing in South Warwickshire to ensure supply of housing over the plan period and particularly the five years following adoption or the Councils risk speculative applications outside of the preferred spatial strategy.

We support identification of Priority 2 and 3 areas given the limits to capacity for brownfield development. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all of the strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Land South of Main Street, Tiddington is part of SG19 and Priority Area 2 and we support its inclusion.

Other

ID sylw: 107810

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Planning for new settlements is supported by Paragraph 77 of the NPPF. However, Paragraph 22 stipulates that the vision in such cases should look at least 30 years ahead. The Plan period would therefore need to be revised if a new settlement is pursued. New settlements have a long lead-in. It is critical for sufficient sites to be allocated across the Strategic Growth Locations, forming most of the housing supply. This aligns with Paragraph 61 of the NPPF.

Other

ID sylw: 107811

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy and review of existing settlement boundaries are supported, particularly since the Urban Capacity Study identifies that development within existing boundaries cannot meet South Warwickshire’s housing requirement. Support for small-scale development adjacent to settlement boundaries is welcomed. The threshold site size should only be guidance to ensure that the policy does not discourage efficient use of land.

Growth adjacent to the village, such as Tiddington and Catesby Estates’ land interests should be encouraged where there are not adverse sustainability implications. Growth across a range of settlements will help provide homes for those who grew up in rural communities and who wish to stay local to their roots, families and social networks. This assists with achievement of Strategic Objective 2. Going beyond minimum housing numbers will help deliver more affordable housing in villages.

No

ID sylw: 107812

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The evidence on shortfalls in the HMAs is out-of-date and should be refreshed as a matter of priority. To deliver the housing the HMAs require will necessitate a clear delineation of responsibility under the duty to cooperate to address any shortfalls, including through the SWLP Part 1.

In anticipation of significant shortfalls and in the context of significant increases for many authorities under the Standard Method, the Councils should plan appropriately and identify reserve sites for this purpose in order for the plan to be sound.

Other

ID sylw: 107813

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle. The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.

Other

ID sylw: 107815

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The Councils acknowledge that the evidence to justify safeguarding land for transport proposals is emerging. Paragraph 111(c) of the NPPF supports identification and protection of routes which could be critical to developing infrastructure to widen transport choice, but also states that policies should do this only where there is robust evidence. It will be necessary for the policy and safeguarding of land to be underpinned by appropriate evidence, to ensure that this is justified and sound.

Yes

ID sylw: 107816

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy is broadly supported as it recognizes a flexible approach to density should be taken. This is consistent with national policy as the NPPF states that densities should be appropriate to the character of the area. Paragraph 130 states that density should reflect the accessibility and potential of different areas. The approach is justified The Guide to Existing Housing Densities Topic Paper provides evidence of the varying existing densities in South Warwickshire.

Other

ID sylw: 107817

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This is consistent with national policy. However, the Urban Capacity Study has shown there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. While there are other brownfield sites outside of settlement boundaries in Stratford and Warwick, the Urban Capacity is clear that ‘significant greenfield development’ including Green Belt will be needed. It should be recognized that use of both brownfield and greenfield sites is required to meet South Warwickshire’s development needs.

Other

ID sylw: 107829

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This provides little direction. It is solely a statement that the Councils will have regard to latest evidence when drafting this policy in full. The Further Advice on Housing & Employment Land Needs report concludes that there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows that 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR identifies that the annual need for 374 affordable dwellings has only been met 3 times since the start of the plan period. The number of households on the two Councils’ housing registers has increased from 7,048 in April 2021 to 7,684 in April 2023.

The HEDNA identified a need for 4,200 units of specialist housing, and around 1,450 care and nursing home bedspaces. This specialist accommodation accounts for 13% of overall housing need. The Further Advice on Housing & Employment Land Needs report does not provide updated figures, but states the provision of retirement housing, extra care and residential care/nursing home spaces will all be necessary to meet the needs of an ageing population. Policy requirements for housing for older people must be justified by the latest evidence.