No

ID sylw: 107240

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The current Reg 18 Preferred Options consultation has been prepared on the basis of the lower HEDNA housing figures, relying upon the broad approach of growth options as providing flexibility to achieve the new Standard Method. As per the August 2024 Cabinet endorsed recommendation, we would encourage a period of reflection and that future drafts of the SWLP reflects on the outcome of the revised NPPF December 2024 and new Standard Method, update the approach to unmet need (see below) and revise the development strategy accordingly.

No

ID sylw: 107245

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

There is an over reliance on new settlements to meet the housing need identified in the Plan.

No

ID sylw: 107247

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

We are concerned that there is a lack of clarity as to how the small sites will be identified and allocated. There is reference within the SWLP Jan 2025 to various approaches including a return to the Site Allocations Plan, identification of reserve sites (to meet neighbouring unmet need and/or to address 5 year housing land supply) and as per the above allocation of small sites through Part 2 documents and Neighbourhood Plans.
In our view there is a need to positively plan to meet the housing requirement and unmet need, moreover ensure a 5 year housing land supply. Subject to understanding housing trajectory, the settlement boundary review presents an opportunity to identify and allocate appropriate small sites to allocate to meet housing land supply. CEMEX’s Long Itchington site is suitable, available and achievable and should be reviewed as part of this process.

No

ID sylw: 107250

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The policy direction is not consistent with the intentions of the NPPF 2024, notably paragraphs 11(b), 27 and 28. The new paragraph 27 provides that plans should ensure that unmet needs from neighbouring areas are accommodated where it is practical to do so. Moreover, the changes to paragraph 28 acknowledge that plans come forward at different times, and that there may be a degree of uncertainty about the future direction that there is a need to come to an informed decision on the basis of available information rather than waiting for a full set of evidence from other authorities.
There is a need to fully understand the growth strategy, how this meets the housing requirement as per the Standard Method, including any unmet need. Moreover, how a 5-year HLS will be maintained.

No

ID sylw: 107251

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

It is not clear what evidence base is relied upon to justify the exceptional circumstances to review and release Green Belt. This will need to be published and subject to testing consistent with the NPPF.

Other

ID sylw: 107252

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

• The SWLP will be prepared in the context of the NPPF 2024.
• It will need to plan for sufficient new homes to meet the new Standard Method. This is a notable step change to that currently planned for based on the HEDNA housing figures.
• Factors such as infrastructure improvements, economic growth, unmet need from neighbouring authorities and affordable housing need can justify a higher housing requirement than the Standard Method.
• Neighbouring authorities have identified, or are anticipating, unmet need.
• The housing requirement is therefore likely to rise beyond the Standard Method.
• There is a need for a period of reflection to ensure that the growth strategy reflects the above, moreover that it will facilitate a 5-year HLS.
• In our view there is an undue reliance on new settlements to meet need.
• There is a lack of clarity as to how sites beyond new settlements and strategic growth locations will come forward.
• The approach to SWLP Part 2 is unclear and the programme for preparation is likely to result in a gap in 5-year HLS.

Yes

ID sylw: 107253

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

Site 391-
The CEMEX Long Ichington site is suitable, available and achievable and would contribute to a mix of sites that would be needed to supply variety to the market and maintain housing land supply. Consistent with the NPPF 2024, it would provide the opportunity for housing development to meet the increased Standard Method housing requirement and as yet undefined unmet housing need of the surrounding authorities.
5 We support the identification the CEMEX Long Itchington Site as a Part B site for further consideration. There is however merit in a move beyond the HELAA methodology and weighting to understand the settlement hierarchy and sustainability of settlements and sites beyond the strategic growth Priority Areas. This is needed if the housing requirement is to be met and indeed exceeded.

No

ID sylw: 108657

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The current Reg 18 Preferred Options consultation has been prepared on the basis of the lower HEDNA housing figures, relying upon the broad approach of growth options as providing flexibility to achieve the new Standard Method. As per the August 2024 Cabinet endorsed recommendation, we would encourage a period of reflection and that future drafts of the SWLP reflects on the outcome of the revised NPPF December 2024 and new Standard Method, update the approach to unmet need (see attachment) and revise the development strategy accordingly.

Other

ID sylw: 108658

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The Growth Strategy overly relies on the creation of new settlements and thus greenfield and Green Belt land.
• 12 potential settlement locations are identified of the four identified as ‘More Suitable’ two are located in the Green Belt.
• It is not clear what evidence base is relied upon to justify the exceptional circumstances required by the NPPF to justify a review and release of Green Belt land.
• As per the NPPF this justification should include making as much use as possible of suitable brownfield sites and underutilised land.
• Based on the information published with the SWLP Jan 2025, exceptional circumstances have not been demonstrated.
• The NPPF highlights the importance of allocating a sufficient amount and variety of land. Moreover, the benefit of mixed-use schemes.
• The future of Core Strategy Policy AS.11 and the Former Southam Cement Works is not clear in the SWLP consultation. Unlike the previous Reg 18 consultation, there is no schedule confirming the relationship to the SWLP Part 1 to the Core Strategy, with the policies to be saved, replaced etc.
• Based on the HELAA, the Former Southam Cement Works appears to be sifted out of the SWLP based on arbitrarily HELAA methodology.
• The site scored one ‘Red’ rating relating to minerals and as such was discounted.
• This ‘Red’ rating does not reflect the provisions of the Core Strategy AS.11, NPPG nor the Adopted Minerals Plan.
• It does not consider the current operational status of the site, its operational lifetime, nor how this relates to SWLP plan period and the fact that there is potential for the site to contribute to housing and economic growth in the short, medium and long term whilst maintaining operational interests.

Other

ID sylw: 108659

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

The Opportunity
5.1 The former Southam Cement Works is an existing large brownfield site that sits outside of the settlement boundary of Southam. It is a site with a long employment history, with CEMEX a long standing business and local employer. It has an active operational life of 20-25 years working the existing mineral working and extraction permissions and could therefore be released in totality within the SWLP plan period to 2050.
5.2 Part of the site is available for redevelopment now and could actively contribute to the SWLP growth strategy in terms of both job creation and new housing in the short to medium term consistent with the policy objectives of the NPPF.
5.3 A Vision Document has been prepared and is enclosed at Appendix 2. The core principles of the opportunity build on the ’20-minute Neighbourhood’ concept and includes:
• Provides for the release of non-operational brownfield land for further CEMEX investment and jobs to the site.
• Retains and consolidates the existing CEMEX business and diversification of CEMEX’s employment offer through new training facilities, together with wider employment floorspace creation.
• Releases land for other employment that could contribute to the objectives of ‘Silicon Spa’.
• A range of jobs within easy community distance.
• Releases land for mixed tenure homes, and housing types, that need identified local need and affordability.
• Beautifully designed homes with gardens, reflecting local character and materials.
• Development that enhances the natural environment, maintaining and enhancing the existing green infrastructure network, wider opportunities for biodiversity net gain and public access.
• Prioritisation of low carbon and energy efficient technology with the aim of achieving a climate resilient development.
• Enabling walkable recreation on site.
5.4 In the short term there is the opportunity for existing known non-operational land to come forward for redevelopment now. In the short to medium term CEMEX are also reviewing processes on site and the efficiency of operations generally, but also as part of CEMEX’s Corporate Nature Positive policy. This is a commitment to explore opportunities to de-carbonise the business, including reducing ‘mineral miles’, i.e. the distances travelled with raw materials and commercial products to customers and a review of the efficiency of the car and vehicle fleet. CEMEX are also reviewing opportunities to meet Biodiversity Net Gain across their wider portfolio. This could release further land within Southam from operational requirements.
5.5 These releases could be to other non-operational CEMEX functions such as laboratories, staff training and development etc as well as other non-CEMEX commercial uses on site or business start-up units / industrial units. These commercial / education uses would be compatible with the operational use and mineral workings that would continue in the medium term whilst making best use of brownfield land and contributing to economic growth and job creation. In short, rather that the site and landscape become redundant, this would enable managed growth and reuse.
5.6 Collectively this would provide a revised ‘context’ and organic growth for when the remainder of the site is released from operational use. As noted above, this could occur within the current SWLP plan period to 2050. The opportunities could be explored through a phased Masterplan linked to the growth objectives of the SWLP. The approach would need to be based on a wider understanding of the existing economic base and the challenges and opportunities facing the local community. This could include start-up businesses units which are consistent with the makeup of the existing local economy and prevalence of micro-businesses. They could also contribute to the ‘Silicon Spa’ economic asset identified by the South Warwickshire Employment Land Study October 2024 prepared by Iceni.
5.7 The western parcel is also available for release now and could come forward for residential development consistent with the original Model Village. The housing would generate value and would facilitate a co-ordinated scheme with the above employment offer. This would offer opportunity for workers to live in proximity to their jobs. Moreover, provide the critical mass for other on-site local services. This could include supporting small scale retail (i.e. a Co-op etc) for both workers and residents in a ‘convenience’ role. Such facilities would be local in nature and not compete with those already provided in Southam and / or Long Itchington.
5.8 There is also the potential for residential development in the northern parcel in the medium to long term.
5.9 There is also the opportunity to enhance the biodiversity and ecological value of the wider land holdings beyond the existing mineral extraction restoration requirements. This includes the opportunity for parts of the site to be used for Biodiversity Net Gain for the wider CEMEX portfolio as part of their Nature First Policy and for any development proposed on site. Land to the west of the Model Village, that already falls partly within Flood Zone 1, has been identified for this purpose.
5.10 CEMEX could also review the potential to open up some areas of the wider land holdings to the public subject to operational health and safety restrictions, ecological sensitivities and meeting amenity needs of any proposed residential development and for surrounding settlements. In this respect it is noted that the ‘made’ Southam Neighbourhood Plan July 2023 sets out a desire to expand the available green space for Southam and nearby villages by opening up the southern extremity of the existing CEMEX Quarry. This land is currently unsuitable for public access as it is subject to Quarry regulations at present. This is expected to be the case for the operational lifetime of the Quarry.
5.11 CEMEX propose to work with the District Council, Town, the community and stakeholders in developing and assessing the development proposals for the site and opportunities for access to other areas in the land holding. This could also explore the potential improved connections with wider communities in Long Itchington and Southam making walking, cycling and public transport the most attractive forms of transport.
6.1 The Former Southam Cement Works site enables an efficient use of existing previously developed land, reducing the pressure to release Green Belt and greenfield land to development for homes and jobs. Consistent with the NPPF 2024, it would secure the existing and new jobs in the long term and provide the opportunity for housing development to meet the increased Standard Method housing requirement and as yet undefined unmet housing need of the surrounding authorities.
6.2 The site is suitable, available and achievable and would contribute to a mix of sites that would be needed to supply variety to the market and maintain housing land supply.
6.3 In our view, the SWLP should retain the principles of the Core Strategy Policy AS 11 and progress a new ‘live’ policy in SWLP Part 1 that facilitates the phased release of the Former Southam Cement Works site to encourage organic employment growth and enabling housing development ahead of the release of the remaining operational land.
6.4 We would welcome the opportunity to meet with the Council to review the above