No

ID sylw: 107753

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The Policy Direction requires major development to be supported by a Health Impact Assessment. It is considered that the plan should set a threshold for what the policy considers to be ‘major’ to ensure that the policy and requirements are clear (NPPF paragraph 16d). Without a clear threshold, assessments could become inconsistent and create uncertainty. Therefore it is important that the Policy Direction provides the necessary clarity to ensure the requirement is justified (as required by paragraph 36 of the NPPF).
Policy Direction 30 states that: “developments with significant negative impact on health and wellbeing will not be supported unless mitigated or compensated for through planning obligations”. This is a broad statement and does not define what is considered a constitute a negative impact on health. It should accordingly be made clear that any mitigation / compensation should be site specific, and would need to comply with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (as amended).

Other

ID sylw: 107754

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We are generally supportive of draft Policy Direction 31.
The second part of the Policy proposes to require developments to demonstrate that they will incorporate or contribute towards the provision of cycle lanes, pedestrian paths and public transport and public transport links should be integrated into the development. The policy should specifically note that not all development will be of a scale to enable public transport links through the site. Additionally, only developments subject to a S106 Agreement would be able to contribute to off-site sustainable access improvements and any requests for upgrades will be required to demonstrate that they are complaint with Section 122 of the Community Infrastructure Levy Regulations 2010.

No

ID sylw: 107755

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway object to draft Policy Direction 32, providing that it does not seek to go beyond the Building Regulations Approved Document S
Bellway supports the installation of EV infrastructure and notes that Part S of the Building Regulations11 sets out requirements for EV charging in new development, with an EV charger required for every house with dedicated parking, as well as non-residential development requirements.
The policy notes the greatest challenge is installing EV charging infrastructure in existing areas, in particular this will include urban areas with terrace housing, where the lack of charging infrastructure and low cost charging is a barrier to uptake of EVs.
Turley have agreed in their review that any provision beyond the Building Regulations will need to be justified, evidenced and considered as part of a viability assessment.

Other

ID sylw: 107756

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We understand that the Warwickshire Local Nature Recovery Strategy (‘LNRS’) is in the early stages of consultation, and it is not yet clear what the draft LNRS will include. This work will need to be completed in order to inform the draft policy. If not, the feasibility and viability of ‘maintaining and enhancing local ecological networks through habitat creation, protection, enhancement, restoration and/or management’ as currently stated in the draft Policy Direction, should be considered to ensure that allocations coming forward in the plan are positively prepared and that allocated sites can deliver housing to meet South Warwickshire’s need. The policy should be worded with additional flexibility, such as adding ‘where possible and practicable’.

No

ID sylw: 107757

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to the consideration in draft Policy Direction 38 to seek a higher percentage of biodiversity net gain (‘BNG’) than the mandatory 10%. If a higher percentage is sought, then the policy should be supported by evidence base to ensure that the policy is justified in line with NPPF paragraph 36. Consideration should also be given to the implications that a higher BNG would have on the viability of sites and their ability to be delivered efficiently. The provision of on-site BNG above 10% will have implications on site yields and is likely to lead to more sites requiring allocation to meet the significant development needs of South Warwickshire.

No

ID sylw: 107758

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works in practice. To our knowledge, there are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 107759

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 107760

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The policy seeks to protect and enhance carbon sinks. Reference is made to a supporting plan but these plans are unclear. More detail needs to be provided to demonstrate how much of the district is considered to be a ‘carbon sink’ and the Council’s justification for this identification.

No

ID sylw: 107761

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The policy seeks to protect trees of ‘value’. It is unclear what the LPA consider is a tree of ‘value’. National policy only seeks to protect irreplaceable habitats which include veteran trees and ancient woodland (NPPF paragraph 193). The SWLP should not seek to protect every tree which is not ‘dead’ or ‘dangerous’. The policy should seek for trees to be protected ‘where possible’.
The policy also states that development will be expected to increase tree canopy cover. We object to this requirement. The feasibility of this requirement as well as its impact on the viability and a site’s ability to be delivered efficiently has not been evidenced and justified. Trees with a large canopy cover need to be properly located on development sites away from proposed built development (e.g. to avoid shading / shadowing and root damage to hard standing). Therefore, the more trees proposed, the greater the likelihood that the developable areas of a development site will be impacted.

No

ID sylw: 107762

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to the proposed requirement for developments that result in the loss of open space to only be permitted where they provide significant public benefits. This does not align with national policy (NPPF paragraph 104) and should be properly justified.
Where off-site open space provision is required, the policy seeks to ensure this is delivered within 400m. The policy will need to state that this is required ‘where possible and practicable’. Enhancements within 400m of the site may not always be achievable and should be determined on a site by site basis.