No

ID sylw: 106183

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The SWLP has taken 5 years to reach this stage and 7 years by the current timetable to reach adoption. Part 2 will presumably not be adopted until well into the 2030s. Many of the policies are outdated following the revised 2024 NPPF and continuing changes will undermine the Government's target to deliver Plans within 30 months. The Preferred Options is clearly not at an advanced stage, with tentative and vague policies/proposals and a 'pick'n'mix' list of large sites. It is unclear what will happen with Stratford-on-Avon's SAP, and after 6 years delay it seems sites will be put back into the pot for the SWLP. Two allocated self-build sites have taken 4 years to get outline consent because of 'limited weight'. The SWLP is focused on large-scale development in proposed New Settlements and Strategic Growth Locations which will distort development to volume builders with standardised 'anywhere' types of new development, while squeezing smaller local builders out of the market.

No

ID sylw: 106184

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

Only 37% of consultees supported the Council’s Vision (at the Issues and Options stage). This is not a ringing endorsement of the ‘vision’ as it stands.

Comments were apparently made that:

1. More clarity was needed around the current housing and employment needs,
2. Unmet housing need from other authorities should be given greater priority, and
3. Definitions of "strategic growth" and “sustainable development needs" should be provided.

These are all legitimate criticisms and should be reflected more in the current SWLP. In particular the current Government now attach much greater importance to strategic planning and the value of a formal co-operation between authorities to deliver housing on a wider canvas. This needs to be built into the SWLP more explicitly.

No

ID sylw: 106185

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The SWLP does not set out firm proposals. It lists 12 potential new settlements and yet it is implied only a handful will be taken forward. By implication most new development will be accommodated on large strategic sites, each having to build a range of services and facilities from scratch. This is unsustainable as it as it will leave older established towns (and villages) where services may be struggling, to decline and wither on the vine. This may be convenient for politicians to avoid objections from local people but towns and villages need to grow ‘organically’ to survive and thrive.

In practice any growth option will need to be a hybrid of all 5 options (and others). The choices are not mutually exclusive and the practical solution must reflect all needs across the two districts. The Councils have apparently rejected No.5 ‘Dispersal’ because a marginally larger proportion said it would be inappropriate rather than appropriate, but It would be catastrophic to abandon Warwickshire’s villages from new development just because a theoretical question produced a ‘wafer thin’ preference for a more concentrated strategy. This will lead to a cycle of decline in rural areas and move towards mediocrity elsewhere.

No

ID sylw: 106186

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The December 2024 NPPF and the new Standard Method figures have completely altered the context for the Plan’s housing requirements. Authorities cannot submit figures which don’t conform to the Standard Method without clear justification. The housing proposals will need to conform with Table 3 of the Plan, subject to additional unmet need from other authorities (such as Birmingham and the Black Country) which have yet to be factored in. Draft Policy Direction 1 needs to be adjusted accordingly and Table 2 should be deleted. This is important since the new standard method figures are 30% higher.

We would expect most of South Warwickshire’s housing needs to be accommodated within Priority Areas 1, 2 and 3 and accompanied by associated infrastructure. This should not preclude development in smaller settlements. Some development is essential to meet market demand and local needs in communities and use existing infrastructure more efficiently. Paragraph 77 of the NPPF provides an option, not an instruction. The Growth Locations and Potential New Settlements should not ‘soak up’ all residual housing and investment – provision of new infrastructure and facilities is a very expensive option.

The Government has signalled a new approach to Green Belt, including introducing ‘grey belt’. This should trigger green belt reviews at strategic level and locally where necessary within smaller communities – such as Offchurch, where the local pub has closed partly due to a lack of modest organic growth. Elsewhere shops are closing, bus routes are being withdrawn and schools are at risk.

Other

ID sylw: 106187

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

I welcome the bold decision to recommend a range of suggestions for new settlements in order to give choice and options for new growth in the area. But the Council will know that new settlements (in addition to being land hungry and expensive to build) take time to deliver and hence ensure that people moving to those areas will be in a constant climate of change with evolving services and continuing disruption. This is not to denigrate the concept of new settlements but to point out that organic growth in towns and villages (where people can slot into existing communities and friendship patterns) should not be rejected. Both have their place. Paragraph 4.2 floats the suggestion that new settlements offer the opportunity of 20 minute neighbourhoods and car free communities. The reality is very much the opposite.

Other

ID sylw: 106188

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The SWLP is unusual in highlighting 12 potential new settlements but the policy wording refers to ‘one or more’ new settlements coming forward. More clarity is needed, even at this stage. I don’t propose to offer comments on the specific proposals.

Other

ID sylw: 106189

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

I am pleased that the SWLP acknowledges the role of small scale development in local communities, but it is very clear that small scale development will form a residual once the strategic sites have been allocated. The whole emphasis of the plan is about finding large sites to accommodate high numbers of housing (many of them in remote locations) which will have as little political impact as possible, rather than finding places in or around local communities where people actually wish to live. The Councils’ attitude towards rural settlements appears to be to define BUAB’s tightly, then devise policies which only allow development within village confines or on sites proposed in Neighbourhood Plans – i.e. with local consent, when the main ambition of most Neighbourhood Plan Teams is to prevent additional housing rather than to promote it.

No

ID sylw: 106190

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

This draft policy needs to be re-drafted to provide a more positive regime which starts from the principle that local communities should be kept alive rather than ‘protected’ from development. The Neighbourhood Plan should not be the only exception to a commitment to review BUAB’s – when this will simply draw boundaries around the edge of each village. The paragraph which states ‘Consideration should be given to the need for the SWDP to identify small sites etc’ is wholly inadequate. The need to deliver at least 10% of the housing requirement on small sites is an expectation of the NPPF. It is this policy requirement which delivers housing choice for consumers – with smaller sites delivered by smaller builders and a greater variety of types and tenures. The Government’s review of green belt policy (and the introduction of ‘grey Belt’ sites), should also signal more than just odd houses within BUAB’s in green belt villages.

Other

ID sylw: 106191

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

I support the policy approach. Further work needs to be sone before submission of the SWLP.

The SWLP will need to satisfy the Duty to Co-operate as a legal requirement. However, in recent years the strategic element of planning for housing has almost disappeared. No reliable assessment of housing shortfall in the West Midlands Conurbation has been carried out since the 2018 West Midlands Study. Shortfalls in housing delivery amongst Birmingham and the Black Country authorities have worsened over the past few years but they have not produced evidence to support their requests for assistance. The new Government is committed to introducing a new strategic planning system, but in the meantime, LPA’s will need to implement the Duty to Co-operate and further work will need to be done before the submission of the SWLP.

Yes

ID sylw: 106192

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

I broadly support the draft policy, in as far as it goes.