No

ID sylw: 107858

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This relates to securing a net gain in ecosystem services. At this stage, no framework for Environmental Net Gain (ENG) has been provided, and the concept is vague. Very limited detail is provided within the policy direction, which simply states that the focus of ENG will be BNG and carbon sequestration, both of which have their own standalone policy directions, and desired requirements for both do not need to be repeated here. This brings into question the necessity for an ENG policy, and substantial work is clearly needed to formulate a policy which is sound. Crucially, the evidence base does not currently demonstrate a need for this policy, as acknowledged by the Councils, thus it is unjustified.

No

ID sylw: 107861

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction encourages green and blue infrastructure (GBI) and proposes delivery through a Greening Factor for South Warwickshire. Various Greening Factor requirements are to be calculated for different types of development, and BNG will contribute towards the Greening Factor of a site. The Warwickshire, Coventry & Solihull Sub- Regional Green Infrastructure Strategy (August 2024), which is part of the evidence base, provides some support for this policy. It refers to seizing opportunities to introduce landscaping, trees/woodland, green roofs, and allotments, all of which are listed in the policy direction as features which can contribute towards the Greening Factor. The policy is justified to an extent, in encouraging GBI. The need to impose a numerical Greening Factor lacks justification, as this is not explicitly recommended within the evidence. The Greening Factor requirement must be justified for the policy to be sound.

The policy direction makes no reference to how and where green infrastructure can be delivered to meet the Greening Factor. No clarity is provided on what the approach would be where the developer is unable to provide sufficient green and blue infrastructure on site. If this policy is taken forward, the Councils must confirm whether off-site provision would be acceptable, adopting a similar locational hierarchy to BNG, and whether financial contributions are an option. It is imperative for the Greening Factor threshold to be reasonable and to allow a degree of flexibility so that it does not risk rendering developments unviable due to ceding potentially substantial amounts of otherwise developable land to provide green infrastructure, which may be surplus to requirements. Proposals should be considered on a case-by-case basis. Overall, the policy direction and the Greening Factor seem poorly thought through and this needs to be carefully considered by the Councils moving forward.

Other

ID sylw: 107863

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

Other

ID sylw: 107864

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

Other

ID sylw: 107866

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Broad support in principle for protecting and providing different typologies of open space. NPPF Paragraph 103 stipulates planning policies relating to open space must be underpinned by robust and up-to-date assessments of need. Such assessments haven't been undertaken to date. This is somewhat acknowledged by the Councils in stating technical evidence is lacking to determine thresholds. Considerable work is required to ensure the evidence exists to formulate a fully justified and sound policy.

Where open space cannot be provided on-site, the Councils propose a contribution will be requested to enhance or provide open space within 400 metres of the development. There may not always be scope for this. The figure should serve as guidance; the policy should read “within 400 metres of the development where possible”.

The policy direction states multi-use games areas (MUGAs) will be requested as part of all major development sites. As defined in the NPPF, a major residential development comprises 10 dwellings or more. A development of 10 dwellings is unlikely to generate need for a new MUGA. The policy should be amended to clarify the requirement is only applicable to larger-scale major development (e.g. 100+ dwellings), providing the evidence on need exists to justify this.

No

ID sylw: 107867

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Further evidence is required to justify the content and inclusion of this policy, in accordance with Paragraph 103 of the NPPF, with the Playing Pitch Strategy still yet to be completed. The policy direction’s commitment that the need for sports and leisure facilities will be considered on a case-by-case basis having regard to the type of scheme and the site is supported, over what would be an unnecessary requirement for all major residential schemes to deliver such facilities, when the need many not exist to justify this.

Other

ID sylw: 107868

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Designated Areas of Restraint already exist within Stratford District; these seek to protect areas that make an important contribution to the character of a settlement. A study to review and identify Areas of Restraint, and whether they are needed as a policy designation, needs to be carried out to provide the evidence for a justified policy.

If Areas of Restraint are retained/designated, the policy should be clearer that these would not restrict development, as stated in the supporting justification, and that residential development of an appropriate design and scale would be permissible within them, providing that they do not harm the Area of Restraint, and subject to compliance with other development plan policies.

No

ID sylw: 107869

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Special Landscape Areas only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Evidence needs to be prepared on which parts of South Warwickshire merit a Special Landscape Area designation.

Such a designation would not be based on national guidance and policy. It is also not included in Natural England's approach. Paragraph 187 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes’. It is considered that the special landscape character across South Warwickshire can be suitably conserved and enhanced through a generic landscape policy, without need to create an additional landscape designation, which would require another study to be undertaken to form part of the evidence base.

If the Councils do wish to proceed with Special Landscape Areas regardless of the above, it is imperative that these do not restrict development in what may be sustainable locations for growth. The policy direction currently recognises this; thus, this aspect is supported.

Other

ID sylw: 107870

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction is broadly supported, with it generally aligning with the aspirations in the NPPF with regards to the protection and enhancement of landscapes, set out in, for example, Paragraph 187. However, it should be noted that Paragraph 135(c) does state that whilst development should be sympathetic to the surrounding landscape, this should not prevent or discourage appropriate innovation or change, such as increased densities. This should be acknowledged within the policy. It is affirmed that it is unnecessary for all major developments to provide Landscape and Visual Impact Assessments (LVIA) as currently suggested. This will need to be fully justified, and such justification has not been provided within the Preferred Options document. The need for an LVIA should be considered on a case-by-case basis, and/or specific criteria for when one is required should be prepared by the Councils.

Yes

ID sylw: 107872

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

NPPF Para 187 b) states "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 states the quality of farmland should inform choices about future use within the planning system. A policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising there may be circumstances where development on best and most versatile (BMV) land is appropriate, when the planning balance favours approval. The exemption from protection for the Strategic Growth Locations and New Settlement Sites is strongly supported. This will ensure the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both the sites which are allocated in the Pre-Submission plan and those which are not, since they have already been identified as suitable growth locations in the Preferred Options document. The SA does not suggest any negative impacts would arise from excepting sites from this policy.