Other

ID sylw: 106631

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We acknowledge and support the Council’s assessment in the HELAA that Land off Bush Heath Road, Harbury (RefID 540) should be taken forward for further consideration in the SWLP in terms of its suitability, availability, and achievability as a location for development.
Our site is, however, mistakenly considered together other County Council held land on the edge of Harbury. In the HELAA the site name is given as ‘Harbury (South and West)’ with a combined site area measuring 40.19ha. The submitted site measures 5.13 ha (12.68 acres) and lies immediately adjacent to the built-up area of Harbury, west of the Bush Heath Road and excludes the existing community allotments (please refer attached written reps, Appendix A). Further corrections are required in terms of:
• Proposed Use - Presently this is stated as being ‘Mixed’. The actual proposed use is ‘Housing/Residential’ with some supporting public open space.
• Current Use - Presently this is stated as being Agricultural / Residential. The current use is Agricultural.
It is requested that the site assessment is updated accordingly.
To help address any confusion, amended site details will also be formally submitted thru the Call for Sites.

Yes

ID sylw: 106632

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Yes, we broadly support the proposals in the introduction but have some concerns relating to what is currently proposed under a two-part Local Plan and its implications for housing delivery in the early years of the Plan period.
Given the scale of the housing and employment requirement for the two Councils, and a recognition that strategic urban extensions and /or new settlements are likely to form the main element of the spatial development strategy in the SWLP, WPDG support the preparation of a plan period extending to 2050. This approach is also broadly consistent with NPPF paragraph 22, that advises: ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’
Rather than have a single comprehensive joint Local Plan, we note the Councils intention that the plan will be broken down into separate parts. Whilst we have no objection in principle to the preparation of a two-part Local Plan, we do not support the Councils proposals in their current form in which only strategic sites (i.e. strategic allocations for new settlements and large scale urban extensions) are to be included in the Part 1 SWLP.
According to the Reg18 SWLP this consultation sets out the "Preferred Options" identified by both Councils for meeting the future development needs of South Warwickshire over the period to 2050 (Para 1.3). Whilst it is common for local planning authorities to consult on a few options at this stage in the local plan process, with a clearly defined preferred option being presented, we are concerned that having 24 Strategic Growth Locations (SGL's) and 12 potential new settlement locations in the Reg18 SWLP, not only does this result in a level of development far in excess of the requirements of South Warwickshire but means that the document in part reads more like an Issues and Options document. This is a cause for concern as we believe it will be difficult to move forward to a Pre-Submission version of the SWLP with details of specific sites for development and associated infrastructure requirements.
While we recognise the importance of ensuring that there is no further slippage in the programme for bringing the SWLP forward, within the above context there is a risk that the Plan when submitted will not be found sound. Therefore, unless the Councils have confidence that they can bring forward a Pre-Submission Local Plan (Part 1) with a clear spatial development strategy that includes an appropriate mix of site allocations best able to meet the housing needs of South Warwickshire over the whole plan period i.e. in the immediate and longer term, consideration, it should consider undertaking a further focused Reg18 consultation exercise on a more focused series of spatial development options ahead of the Reg19 Pre-Submission.

Yes

ID sylw: 106633

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

WPDG is generally supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities for South Warwickshire.
Strategic Objectives 1 and 2
As has been established, the SWLP is proposed to be a two-part Plan in which only strategic sites (i.e. strategic allocations for new settlements and large scale urban extensions) are to be included in the Part 1 Plan. Policies for the consideration of smaller sites specific to the local area (i.e. within and adjacent to existing settlements) are to be provided in the Part 2 Plan. There is a requirement for smaller allocations to meet the identified housing needs in the shorter term and therefore it is considered that Strategic Objectives 1 and 2 will not be realised until after the adoption of the Part 2 Plan.
Strategic Objective 3 is concerned with ensuring development has the infrastructure needed to support the growth in new homes and jobs. In principle this is an appropriate objective to be included in the SWLP, however, we note that the emphasis is on “providing” infrastructure in the right place at the right time. In the interest of supporting the delivery of sustainable development, the SWLP should first support new development in locations that are best able to make use of existing infrastructure.
‘Strategic Objective 3: Ensuring Providing infrastructure is available at in the right place at the right time to support growth.

No

ID sylw: 106634

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

No. The policy needs amending so that it is consistent with the NPPF (December 2024), and its stated requirement for use of the "Standard Method" the government-mandated formula to calculate the minimum number of new homes a local area needs to plan for in order to boost housing delivery.
The draft SWLP should have also acknowledged that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth, the delivery of affordable housing and / or to assist in meeting housing needs that cannot be met within neighbouring areas.
The pre-amble to Draft Policy Direction 4 - Accommodating Growth Needs Arising from Outside South Warwickshire states: ‘It is yet to be established to what extent and what uses (e.g. housing and/or employment) there will be any unmet need from elsewhere within these housing market areas [Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA]. Some of this need will be met by other constituent Local Planning Authorities within both HMA’s; however, through Duty to Co-operate discussions; the Councils will commit to continually consider this need and work with those authorities on how this can be achieved.’
the SWLP should provide, as a minimum, the new Standard Method housing requirement for the Plan area. We stress a minimum because other factors indicate that a further uplift in the housing requirement will be required in order to provide the level of affordable housing need identified in the HEDNA and to take account of allocated sites lapsing, non-implementation and the fact that the capacity of sites can often reduce between the outline and reserved matters stages.

Other

ID sylw: 106635

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We acknowledge and support the Council’s assessment in the HELAA that of Land off Bush Heath Road, Harbury (RefID 540) should be taken forward for further consideration in the SWLP in terms of its suitability, availability, and achievability as a location for development.
4.10 Our site is, however, mistakenly considered together other sites on the edge of Harbury. In the HELAA the site name is given as ‘Harbury (South and West)’ with a combined site area measuring 40.19ha. The submitted site measures 5.13 ha (12.68 acres) and lies immediately adjacent to the built-up area of Harbury, west of the Bush Heath Road and excludes the existing community allotments (please refer Appendix B). Further corrections are required in terms of: • Proposed Use - Presently this is stated as being ‘Mixed’. The actual proposed use is ‘Housing/Residential’ with some supporting public open space. • Current Use - Presently this is stated as being Agricultural / Residential. The current is Agricultural.
It is requested that the site assessment is updated accordingly.

No

ID sylw: 106636

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

It is also vitally important that deliverability and viability considerations are also addressed.
whilst the approach laid out in Draft Policy Direction 2 broadly aligns with Paragraph 77 of the Framework, which states: ‘The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).’
It has not been adequately demonstrated that the potential New Settlements will be supported by the necessary infrastructure and facilities, including a genuine choice of transport modes. Opportunities for rail links to these Potential New Settlements may be challenging and therefore further information is required to demonstrate how such development can help to meet identified needs in a sustainable way.
The need for significant new infrastructure and facilities to support the Potential New Settlements will mean that these growth locations are unlikely to be delivered until towards the end of the Plan Period to 2050. Clearly, there is a requirement for smaller allocations to meet the identified housing needs in the shorter term, in accordance with Paragraph 72 of the Framework.
It is submitted that Land off Bush Heath Road, Harbury should form part of a mix of sites within the Spatial Growth Strategy to assist in meeting South Warwickshire’s identified housing need. The site within lies in Spatial Growth Strategy -Priority Area 2 immediately adjacent to the built-up edge of the village, and of a scale (approx 100 dwellings) that can be delivered quickly to meet the Council’s 5yr housing land supply in the early years of the Plan.

Yes

ID sylw: 106640

Derbyniwyd: 05/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Warwickshire and that consideration will be given in the SWLP to identifying a number of “small sites” in order to ensure provision of a 5-year housing land supply. Instead the SWLP Part 1 should support “proportionate” development within and adjacent to existing settlements, in a comparable way to Policy CS.16 in the Stratford-on-Avon Core Strategy.
Unless an appropriate mix of sites of varying sizes are allocated in Part 1 of the SWLP, there is a real risk that an over reliance on Strategic Growth Locations and/or New Settlements will lead to identified housing needs for South Warwickshire in the shorter term not being met.

Yes

ID sylw: 106641

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While it is acknowledged that further work is required on the extent and distribution of the Greater Birmingham and Black Country HMA housing shortfall, and that further work also needs to be done in respect of Coventry housing need shortfalls, there is currently no unmet housing need figure on which to comment. We are therefore concerned that the first opportunity to comment on the unmet housing need figures for these areas will be the Pre-Submission version of the SWLP. Consequently there is a real risk of the SWLP’s progress towards the Submission stage being delayed whilst the extent of the housing shortfall is fully understood and the need for any amend to the SWLP housing requirement figure is addressed following re-consultation.
It is, therefore, our view that in the lead up to the preparation of the Pre-Submission SWLP the Councils should identify the extent of the HMA’s housing shortfall they intend to plan for, and invite comments from interested parties.

Yes

ID sylw: 106642

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While we recognise and support the stated aim of the Councils in making sure that there is sufficient and appropriate infrastructure to meet future needs, we found the approach laid out in Draft Policy Direction 5 to be rather unfocused and consequently not that clear.
Whilst we support the acknowledgement that the site specific policies included in subsequent versions of the SWLP will specify the infrastructure delivery requirements associated with each allocation, we are concerned that the first opportunity to comment on these policies will be the Pre-Submission of the SWLP. The Councils may receive comments at the Pre-Submission stage that require a change to a Policy, or potentially require allocations to be reconsidered. This may result in the need for further target consultation following the preparation of the Pre-Submission SWLP prior to submission. This would slow down the Plan making process. To avoid this, the Councils should actively engage with site promotors to understand potential infrastructure opportunities and constraints in order to assist in establishing the most appropriate development sites and their policy requirements ahead of the publication of the Pre-Submission SWLP.
We wish to reaffirm our position that thru the SWLP the Councils should place greater emphasis on a spatial development strategy which seeks to bring forward development in sustainable locations that are not reliant on the need for significant new infrastructure ahead of strategic allocations which are dependent on the delivery of new infrastructure.

Yes

ID sylw: 106643

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Yes, we support the proposals identified in Draft Policy Direction 6.