Other

ID sylw: 108057

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

These representations broadly 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: 108059

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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The HEDNA housing need is now out-of-date.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 suggests this is the maximum number of homes but 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 should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. The presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given limits to brownfield capacity identified in the Urban Capacity Study. This will help support viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all 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 at Russells Garden Centre, Mill Lane, Baginton is within Spatial Growth Priority Area 2 and whilst not in an SGL it is to the northeast of SG03 Coventry Airport Group for employment. A highly sustainable location combined with excellent access to existing employment opportunities and future employment growth in the immediate locality means it is an excellent Site for allocation. Whilst the Site is within Green Belt it aligns with the proposed Spatial Growth Strategy, which seeks to prioritise development of brownfield land. The Site is partly previously developed land. The remainder meets the definition of grey belt land. Baginton was identified as a Growth Village in the 2017 Warwick Local Plan and is already established as a sustainable location for housing growth. Housing site H19 (a greenfield site) was identified to deliver approximately 80 dwellings and now has outline consents (W/22/1038 and W/20/0808) totalling 119no. dwellings. This highlights Baginton's suitability for housing growth and strong deliverability of allocations in Baginton.

Other

ID sylw: 108060

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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.

The SA assesses the potential new settlement locations. They would all make a major positive contribution to housing (SA Objective 9), All options will generally result in minor adverse to major adverse impacts across most of the other SA objectives. The Emerging Spatial Growth Strategy Topic Paper recognises new settlements will have a harmful impact due to the amount of land they would occupy in existing countryside locations. The SA suggests that the Strategic Growth Locations are generally more sustainable, in terms of having lesser adverse impacts on SA Objectives. However, this is only a high-level exercise which has not taken potential mitigation into account. This could include ecological and landscape enhancements which would give rise to major positive impacts. As with the Strategic Growth Locations, the positive impacts on transport and accessibility (SA Objective 11) and, as a result, Climate Change (SA Objective 1) have not been recognised.

Other

ID sylw: 108061

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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 villages 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.

The Policy Direction should make reference to grey belt land to be consistent with the latest national policy. Currently the wording suggests very limited development would be allowed in or adjacent to settlements in Green Belt. If the tests in NPPF Paragraph 155 are met small-scale development adjacent to boundaries on sustainable grey belt sites should be supported.

No

ID sylw: 108062

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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: 108063

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

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: 108064

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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.

Other

ID sylw: 108065

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Seven Homes support a Green Belt review. The Green Belt in South Warwickshire Topic Paper shows several of the best-connected settlements are within or surrounded by Green Belt. So are most train stations. Half the SGLs are within Green Belt. The Topic Paper is correct that Green Belt options should be considered to ensure development is suitably distributed and directed to the most sustainable locations and that a full Green Belt review is essential.

Exceptional circumstances as required by NPPF Paragraph 145 exist because of the significant number of homes required and limited capacity in existing settlements as evidenced by the Urban Capacity Study. Paragraph 146 states that exceptional circumstances include when authorities cannot meet identified housing needs through other means. The December 2024 NPPF introduced ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then grey belt, then other Green Belt locations. The Council will need to follow this sequential approach when considering sites release.

The Green Belt Review Stage 1 doesn't consider grey belt but concludes only 9 out of 113 parcels made a strong contribution to the Green Belt purposes. With over 100 parcels not strongly contributing, Seven Homes would expect a significant number of grey belt sites can suitably accommodate development. The next stage of the Review should draw clear conclusions. The Green Belt policy should make reference to Grey Belt and acknowledge that development in Green Belt can be appropriate if the Paragraph 155 criteria are satisfied. The ‘Golden Rules’ for residential development may also be referenced.

The draft Policy Direction suggests areas of land may be safeguarded to meet longer-term needs. This is supported, and would align with NPPF Paragraph 149(c). This could be for future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within. Further discussions and evidence-gathering is required to ascertain the level of unmet need in the HMAs. ‘Safeguarded land’ would be in addition to ‘reserve sites’ referenced in Policy Direction 4. These would meet the shorter-term needs of neighbouring authorities over the plan period, not beyond it.

Land at Russells Garden Centre, Mill Lane, Baginton is within parcel BAG2 assessed in the South Warwickshire Green Belt Review Stage 1. The Site is in the far north western corner of the parcel. The wider parcel is quite large and generally rural and open. Overall, the parcel is considered to play no contribution to checking the unrestricted sprawl of large built-up urban areas (purpose a), a weak contribution to prevent towns from merging (purpose b), and no contribution to preserving the setting and special character of historic town (purpose d).

Development of the site would include a large area of previously developed land and whilst the remainder of the site is not PDL it is horticultural in character with numerous structures, including greenhouses and polytunnels. The floodplain to the south of the site limits the extent of development across the wider site. Whilst the Site is a short distance from the edges of Coventry the existing Kenilworth Bypass creates a physical barrier between the two settlements. Whilst not discussed within the latest Green Belt Review, the Joint West Midlands Green Belt Study 2015 did discuss long-range intervisibility with the historic core of Coventry from areas of high ground to the south. Given the site’s location in the far northwest corner of the Green Belt parcel and its PDL character, development is not considered to undermine purpose (d). In addition, the Site is beyond the boundaries of the Baginton Conservation Area.

Yes

ID sylw: 108066

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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: 108067

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

In encouraging the use of previously developed land, this Policy Direction aligns with national policy, with Paragraph 124 emphasising that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the Urban Capacity Study is still clear that “significant greenfield development” (including Green Belt) will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.