Yes

ID sylw: 108265

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Yes, we fully support the identification of Long Marston Airfield (“LMA”) as a potential new settlement. It is suitable, sustainable and developable and can deliver a significant amount of residential and commercial development to assist in meeting the Plan’s development requirements. We do, however, have a series of concerns with the conclusions of the underpinning evidence base supporting the draft allocation.
1. It is our view that the Sustainability Appraisal of Site E1 – Long Marston Airfield, does not properly reflect the sustainability credentials of this potential new settlement location, and the significant benefits associated with its allocation for development.
2. The ISA’s approach to assessing flood risk is flawed. The flood zone assessment is based upon the proportion of site that falls outside of Flood Zone 1 and the proportion of the site affected by surface water flooding. The size of the new settlements varies from 242 hectares to 770 hectares. The significant difference in the size of the settlement distorts the assessment of flood risk.
3.We support the identification of Site E1 as the most sustainable settlement in terms of biodiversity and geodiversity.
4. New settlement E1 – Extension to Long Marston Airfield, is identified as the worst performing new settlement against the Landscaping Sustainability Objective. This is due to the suggestion it is likely to result in adverse impacts on the local landscape character, views from public rights of way and coalescence. In addition, it is suggested that it is likely to result in significant adverse impacts on the special quality of the setting of the Cotswold Natural Landscape Area which is located 45 metres from the settlement boundary.
We disagree with this conclusion.
5. Whilst we are supportive of new settlement E1 being identified as one of the most sustainable locations for development from a pollution perspective, we do not support the conclusion that the site should be marked down due to its proximity to a railway line on the basis this could potentially locate residents next to existing sources of air and noise pollution.
6. We support the identification of Site E1 as the most sustainable location for development in terms of impact on natural resources.
7.Spitfire are promoting HELAA site 175 – Stratford Agricultural Park and surrounding land, that forms part of the potential LMA new settlement. We are generally supportive of the HELAA’s conclusions regarding the suitability of the site for development.

Other

ID sylw: 108266

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Spitfire Homes support the preparation of a joint Local Plan with a Plan period extending to 2050. Given the scale of the housing and employment requirement, and the recognition that new and expanding settlements will need to form part of the development strategy, it is good and positive planning to prepare a Local Plan that is able to address issues in the long term.
Whilst we have no objection in principle to the preparation of a two-part Plan, both Councils should be mindful of the impact that this is likely to have on housing delivery and the geographic distribution of development and this gives rise to a number of concerns.
It is appreciated that the Part 2 SWLP is intended to be a solution to this, by identifying smaller scale housing allocations. However, it is unlikely to be adopted for a significant period of time. Figure 4 – Timetable for the SWLP, advises that it is expected that Part Plan 1 will be adopted by December 2027. This timescale assumes a ‘smooth path’ and it is possible that the reality may be longer, and the Plan may not be adopted until 2028 or beyond. It is stated that the Part 2 Plan will be prepared following the adoption of the Part 1 Plan, but it is likely that it will take at least 3 years to prepare the Part 2 Plan (Stratford on Avon is still yet to adopt its Part 2 Site Allocations Plan, which has been in preparation since the adoption of the Core Strategy in 2016, we are concerned that this delay will be repeated). This would mean that there would be no Plan in place for smaller scale housing allocations until at least December 2030. Following the adoption of the Part 2 SWLP planning applications will need to be prepared, submitted, and approved and development commenced in order for completions to take place. There is, therefore, no plan-making basis emerging to support the delivery of small scale sites for a significant period of time.
This is likely to cause problems for the five year housing land supply positions of both local Authorities.
It is, therefore, our view that the Part 1 SWLP should include policies to facilitate the development of smaller scale sites in sustainable locations whilst the Part 2 SWLP is being prepared.
Any additional development arising from Neighbourhood Plans should be welcomed, but not replied upon.

Other

ID sylw: 108267

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We broadly support the Vision and Strategic Objectives included within the draft SWLP. Spitfire Homes are, however, concerned that these objectives may not be realised through the plan making process.

No

ID sylw: 108268

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. Both the policy and its supporting text require amending.

Yes

ID sylw: 108269

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support recognition that new settlements and expanding settlements are required to meet the housing and employment growth requirements in the most sustainable way. However, these large-scale proposals should be complemented by smaller scale allocations in sustainable locations that are deliverable in the short term.

Yes

ID sylw: 108270

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

The Policy’s supporting text correctly recognises that smaller sites have a valuable role to play in delivering community led housing and boosting the local economy as they tend to be attractive to medium and smaller housebuilders, and especially local housebuilding companies. NPPF paragraph 73 specifically acknowledges the importance of SME housebuilders in bringing forward smaller sites. They can also help directly to meet the affordable and marketing housing need arising in a particular settlement. New development increases footfall in local shops, services and facilities supporting their viability. There are a number of primary schools in South Warwickshire settlements that are predicted to have decreased levels of pupil intake due to the aging profile of these settlements. Directing new development towards these settlements can help support the viability of local schools and enrich the local community.
However, the supporting text to Draft Policy Direction 3 advises that the Local Plan Part 1 Settlement Boundary Review will not allocate sites for development. This would be achieved through the Local Plan Part 2 and Neighbourhood Development Plans.
We note that Draft Policy Direction 3 proposes support for “small scale” development within or adjacent built up area boundaries. We do not support the use of the term “small scale”. The SWLP Part 1 should support “proportionate” development within and adjacent to existing settlements. “Small scale” development may not meet local market or affordable housing needs. In a similar approach to the Stratford-on-Avon Core Strategy Policy CS.16, the SWLP should confirm the amount of development that is appropriate at different settlements as this is a strategic policy matter that should be addressed in the Part 1 SWLP.

Other

ID sylw: 108271

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we support the recognition in Draft Policy Direction 4 that it may be necessary for the SWLP to help meet the unmet housing needs arising from the Coventry and Warwickshire HMA, and the Greater Birmingham and Black Country HMA, we are concerned with the lack of detail and the refences within the draft Policy.
The Policy Justification refers to the Coventry and Warwickshire HEDNA 2022 identifying the likely housing requirement for South Warwickshire and informing the unmet need arising from Coventry. The HEDNA is now out of date. Its housing requirements have been superseded by the new Standard Method in the NPPF December 2024. The Coventry and Warwickshire Authorities are required to prepare Plans using the revised Standard Method housing requirement and any unmet need against this requirement should be directed to another HMA authority.
It is also acknowledged that further work is required on the extent and distribution of the Greater Birmingham and Black Country HMA housing shortfall, especially given the age of the Strategic Growth Study, and the need to consider the revised Standard Method housing requirement.
It is appreciated that further work also needs to be done in respect of both the Coventry and Warwickshire, and Greater Birmingham and Black Country housing need shortfalls. However, there is currently no unmet housing need figure on which to comment. We are concerned that the first opportunity to comment on the unmet housing need figures for the Birmingham, Black Country and Coventry areas will be the Pre-Submission version of the SWLP. This may result in problems with the SWLP progressing towards the submission stage. Representations could be submitted regarding the extent of the shortfall that may result in the need to amend the SWLP housing requirement figure. It may be challenging for the Local Authorities to amend the Plan ahead of the submission without 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.

Other

ID sylw: 108272

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we generally support the approach identified in Draft Policy Direction 5, we have a number of comments on the policy’s supporting text.
We welcome the acknowledgement that the site specific policies included in subsequent versions of the SWLP will specify the infrastructure delivery requirements associated with each allocation. However, 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. In order 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.
The policy’s supporting text advises that in planning for new development the Councils will have regard to where existing infrastructure deficiencies exist, and the extent to which new development will impact on these deficiencies. New development has the potential to address existing infrastructure deficiencies. Whereas this is the case this should support the case for an allocation.
For example, Spitfire control Stratford Agricultural Park, located to the east of Long Marston Airfield. The development of Long Marston Airfield has stalled due to offsite highways infrastructure funding issues. Directing additional development to Long Marston Airfield will help address these constraints by providing additional appropriate and proportionate S.106 funding and making Long Marston Airfield more self-contained.
We support recognition that an Infrastructure Delivery Plan needs to be prepared, and note that an Infrastructure Delivery Plan (Part One) has been published which is a key evidence based document to inform the plan making process and the infrastructure required with specification allocations. In order for the Infrastructure Delivery Plan to be robust it should be prepared in collaboration with site promotors.

Yes

ID sylw: 108273

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Yes, we support the proposals identified in Draft Policy Direction 6. The SWLP should carry forward the existing safeguard measures that relate to transport schemes that are yet to be implemented. The Council should actively work with the development industry to deliver the schemes, or alternative mitigation required to facilitate the development of existing and the emerging allocations, including Long Marston Airfield.

Other

ID sylw: 108274

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we support the proposal for the emerging Plan to provide guidance on densities, including different density aspirations for different areas, there is no detail in the draft policy on the density levels that will be sought in any particular area or location. We therefore reserve the right to comment on this matter further once actual density levels are confirmed.
The Councils should be mindful of the fact that density levels should be realistic. The density levels sought should reflect the Councils housing mix requirements, the need for NDSS housing should it ultimately becomes a policy requirement, and other policy requirements that have an effect on size of properties and plots. In addition, consideration needs to be given to the mandatory requirement to achieve a minimum 10% biodiversity net gain on all sites.
In allocating sites and considering their capacity the Council should also carefully consider gross to net development ratios. Green infrastructure policies, the requirement to try and provide BNG on site, and open space requirements generally, are likely to mean that gross to net development ratios are likely to decrease. This means that site size will need to increase to accommodate green infrastructure.