Other

ID sylw: 108452

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

It is clear that this Plan will be examined against the 2024 NPPF, as confirmed by the transitional arrangement at Paragraph 234 of that document. Therefore, this Plan must be written in a way to accommodate the full housing need of the area, as calculated by the 2024 NPPF Standard Method.
The Draft Policy Direction recognises this reality by mentioning both the HEDNA figure of 41,975 dwellings across the Plan period (at 1,679 dwellings per annum (dpa)) and the Standard Method figure of 54,700 dwellings at 2,188 dpa. Magdalen College, Oxford’s view is that the Plan must proceed on the basis of the higher NPPF figure to ensure a sound Spatial Strategy.
The publication of the 2024 NPPF was part of the Government’s aims to deliver a universal, ambitious local plan coverage, which is seen as being vital to deliver the Government’s commitments to achieve economic growth and build 1.5 million new homes. It is paramount that the Local Plan sets an ambitious agenda for growth in the district that seeks to allocate sufficient land to accommodate the 54,700 dwellings required by the 2024 NPPF.
It is likely that to achieve this higher target, the Council will need to allocate a wide range of sites, from new settlements, strategic urban extensions to towns and smaller sites in sustainable villages. The Council should “leave no stone unturned” in its search for additional sites.
It is not clear from the Draft Policy Direction to what extent this Plan will seek to allocate sufficient land to meet the housing target and what
proportion will be left to Part 2 of the Local Plan and Neighbourhood Development Plans (NDPs). Given the scale of the housing need identified by the 2024 NPPF, the approach is lacking in detail and certainty.

The College considers that its site at Goose Lane, Lower Quinton should be considered favourably for allocation in this Plan, as explored further within our representations. Magdalen College, Oxford considers that its site Adjacent to former Long Marston Depot, west of Campden Road (HELAA Refs 273 and 832) should be considered favourably for allocation in this Plan as explored further below.

Other

ID sylw: 108453

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Given the significant increase in housing need that the Local Plan will need to accommodate, an extra 12,975 dwellings to meet the NPPF figure relative to the HEDNA, Magdalen College, Oxford is strongly of the opinion that the Council will need to plan positively for a variety of new housing developments. Whilst the majority of new homes will no doubt be provided at new settlements and strategic growth locations, there will clearly be a new need to allocate smaller sites too. The very large allocations will likely take many years to deliver due to the need to provide supporting infrastructure. The College considers that smaller allocations will have a crucial role to play in helping the Council maintain a five-year supply of housing land during the early years of the Plan before the strategic scale allocations begin to deliver.
There is a need to provide a range and choice of sites, a need for flexibility and viability considerations to be taken into account and a need for the Council to consider whether higher levels of open-market housing are required in order to secure the delivery of affordable housing and/or support economic growth. Consequently, we strongly support the Council’s suggestion that it will consider, “the need for the SWLP to identify a number of small sites in order to ensure provision of a 5-year housing land supply…”.
Our Client’s land at Goose Lane is ideal for being a small to medium scale allocation in the Local Plan. It is a 1.7 hectare site capable of accommodating approximately 35 dwellings. It is relatively unconstrained and access can be easily achieved from Goose Lane. The development of this site would form a natural second phase to the Corfield Drive development that has been delivered.
Crucially, this site has already been assessed and deemed suitable for development as part of the Quinton Neighbourhood Plan. Policy HO.2 of that document reads, “The Plan safeguards land on the east side of Goose Lane (as shown at Figure 12) as a Reserve Housing Site, with the potential for future residential development of up to 30 dwellings. The safeguarded site will only be released during the plan period if it can be demonstrated through the submission of evidence that there is an identified housing need for its early release having regard to the criteria in Policy CS.16 of the Core Strategy 2011-2031.”
Consequently, given the increased housing need discussed above, this emerging Plan should allocate this site that has already been positively assessed, both within the Neighbourhood Plan and Site Allocations Plan.
As set out at paragraph 73 of the NPPF, the allocation of small and medium sites can not only make an important contribution to meeting the housing requirement of an area, but they are essential for Small and Medium Enterprise (SME) housebuilders to deliver new homes. The Housebuilding Market Study by the CMA (26 February 2024) sets out that “the planning system is one of the main barriers faced by SME housebuilders” (paragraph 4.181). The paragraph goes onto to say that “several studies suggest that the planning system favours large sites”. The Local Plan should identify a “good mix of sites” as per paragraph 73 of the NPPF.
The site at Goose Lane for circa 35 dwellings could not only contribute to the immediate delivery of housing in the district but could also support SME housebuilders. This can also support the local economy within Warwickshire by providing local jobs and supporting the local supply chain this delivering cumulative economic benefits.
The Draft Policy Direction continues to suggest that housing site outside the Green Belt will be supported within and adjacent Built Up Area Boundaries (BUABs). This is also strongly supported in principle. However, it is important that any threshold is not overly prescriptive so as to exclude potential development sites such as the College’s interest at Goose Lane. Any threshold should be flexible and relative to the size of the settlement.
The principle of a settlement hierarchy classification is supported and it is noted that Lower Quinton currently sits within the Local Service Village Category. However, it is vital for landowners, developers and the general
public alike to be able to understand the methodology that will be used to classify the settlements. Furthermore, it is equally important to understand how the resultant Settlement Hierarchy is used as a basis for determining where new housing allocations are directed.
Without this information, the College simply reserves the opportunity to comment on any future evidence and policy approach in respect of this principle.
The College considers that this policy should have provision for supporting the conversion of existing buildings, both within built-up area boundaries and within the open countryside. Agricultural buildings that are no longer suitable for modern agriculture provide opportunities for re-use to residential or alternative uses. There are many examples of the successful conversion of agricultural buildings, not just of brick or stone buildings, but also of traditional Dutch barns or modern barns that are redundant. The policy should therefore have flexibility to see the re-use of different buildings come forward.

Yes

ID sylw: 108454

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Magdalen College, Oxford strongly supports the Local Plan’s intention to consider the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and Black Country Housing Market Area (HMA).
It is important that this Local Plan is based on a Spatial Strategy that benefits from meaningful engagement between the authorities within the HMA. Paragraph 69 of the NPPF is clear that, “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
It is clear that the NPPF expects housing needs to be met in full and cross boundary working is a tool to achieve this. Given the general increase in housing need across the region following the 2024 NPPF, it seems more likely that places such as Coventry and Warwick, already constrained, will struggle to meet their housing needs within their administrative boundaries and South Warwickshire is a logical area to accommodate at least some of this unmet given the proximity and existing transport connections.
Whilst the College does not necessarily expect its land to be suitable for meeting the unmet needs of any town or city, any additional land that is needed for this purpose, will have a knock-on effect of increasing the number of additional sites subsequently needed to meet the districts own needs.
As discussed above, small sites such as our clients land at Goose Lane, have an important role to play in ensuring a strong supply of deliverable sites across the Plan period.

Yes

ID sylw: 108455

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Magdalen College, Oxford supports the inclusion of a Rural Diversification Policy. Where existing buildings are no longer suitable for modern agriculture, there should be support in this policy for their re-use, either for employment or residential purposes.

Yes

ID sylw: 108456

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

The College’s land interest: Land East of Goose Lane, Lower Quinton was assessed under HELAA Site Ref 272 and HELAA reference 822 as it was a Reserve Site Allocation in the draft Site Allocations Plan (Original Site Reference QUIN.A). Subsequently, the site has been allocated as a Reserve Site in the adopted Quinton Neighbourhood Development Plan. Policy HO.2 of that document confirms the site is suitable for 30 units and would be released, “if it can be demonstrated through the submission of evidence that there is an identified housing need for its early release having regard to .., the Core Strategy 2011-2031.” The site is suitable as a small scale site allocation for immediate delivery.
To support the College’s position set out by these representations, this correspondence is accompanied by:
• Goose Lane, Lower Quinton Vision Document by LDA Design (March 2025)
• Landscape Visual Appraisal by LDA Design (March 2025)
The site is a logical extension to the previously approved scheme at Goose Lane (outline application reference 14/01449/OUT and reserved matters application reference 17/00863/REM). The development would not extend the boundary of Lower Quinton further as it sits in line with existing residential development to the immediate west of Goose Lane.
Since previous representations, further masterplanning work has been completed to confirm the site has capacity for approximately 35 dwellings. Access would be taken from Corfield Drive along the northern boundary of the site. Corfield Drive and the adjacent green strip sit in the College’s ownership ensuring access is achievable within the same land ownership.
Landscape has been a key factor in developing an illustrative masterplan for the site and a Landscape Visual Appraisal has been completed. The assessment concludes that the proposed development can successfully be accommodated within the landscape. Appropriate mitigation and enhancement measures can be incorporated into the design of the scheme to address potential landscape and visual effects. It is considered that the development would:
• relate well to the existing settlement pattern;
• would be well-integrated into the landscape and existing built-up area of Lower Quinton;
• would not be a prominent feature in views; and
• would provide benefits for new and existing communities including recreational provision, improved ecological habitats, a stronger settlement edge and connections to the existing Public Right of Way network.
The masterplan seeks to frame views towards St Swithin’s Church along Corfield Drive and retain views to Meon Hill from Main Road and Goose Lane.
Ecology surveys are due to be completed during the 2025 survey season and further technical work is due to be instructed.
As part of identifying the Goose Lane site as a Reserve Housing site in the Neighbourhood Plan, the Parish Council reviewed the potential housing sites adjacent to the BUAB that were identified as potentially deliverable by Stratford-on-Avon District Council in the SHLAA 2019 proposals which was further updated in 2020 and 2021.
The identification of the Goose Lane site came about utilising information provided in the SHLAA, the 2018 survey of residents and discussions with the landowner. This demonstrates that the site is the preferred site for housing within the village. The site has also been proposed by SDC as part of the Site Allocations Plan consultation processes in 2020, 2021 and 2022.
It is important to note that Magdalen College has a track record for delivering high quality sustainable development. This is evidenced by the delivery of the Goose Lane scheme to the immediate north of the site. Given this delivery experience, the College emphasises the ability to deliver the site early in the plan period and within a 5 year timescale.

Other

ID sylw: 108471

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Given the significant increase in housing need, the Local Plan will need to accommodate an extra 12,975 dwellings to meet the NPPF figure relative to the HEDNA. Magdalen College, Oxford is of the view that the Councils will need to plan positively for a variety of new housing developments. Whilst the majority of new homes will no doubt be provided at new settlements and strategic growth locations, there will clearly be a new need to allocate smaller sites too. The very large allocations will likely take many years to begin to deliver due to the need to provide supporting infrastructure. Smaller allocations will have a crucial role to play in helping the Council maintain a five-year supply of housing land during the early years of the Plan before the strategic scale allocations begin to deliver.
There is a need to provide a range and choice of sites, a need for flexibility and viability considerations to be taken into account and a need for the Council to consider whether higher levels of open-market housing are required in order to secure the delivery of affordable housing and/or support economic growth.
Consequently, the College strongly supports the Council’s suggestion that it will consider, “the need for the SWLP to identify a number of small sites in order to ensure provision of a 5-year housing land supply…”.
Our clients land would be an ideal allocation for a small scale site to deliver housing on the edge of Meon Vale, a sustainable location for residential development that has already been positively assessed, both within the HELAA 2024 and the Site Allocations Plan. The ability of this site to deliver is not tied to the potential settlement at Long Marston Airfield.
The Draft Direction continues to suggest that housing site outside the Green Belt will be supported within and adjacent Built Up Area Boundaries (BUABs). This is also strongly supported in principle. However, it is important that any threshold is not overly prescriptive so as to exclude potential development sites such as our clients land at Campden Road. Any threshold should be flexible and relative to the size of the settlement.
The Draft Direction also proposes, “Reviewing, and where appropriate updating, existing adopted BUABs.” This is strongly supported provided it is done holistically alongside the allocations being made for each settlement.
The College considers that a BUAB should be prepared for Meon Vale, given the quantum of recent development here and the fact Meon Vale is now a self-sufficient settlement that could support further growth and reflect the allocation in the adopted Core Strategy for the Former Engineers Depot, a brownfield allocation for 965 new homes in Long Marston.
The BUAB should equally include the College’s land at Campden Road given how well related the site is to existing built development.
The principle of a settlement hierarchy classification is supported but it is vital for landowners, developers and the general public alike to be able to understand the methodology that will be used to classify the settlements. Furthermore, it is equally important to understand how the resultant Settlement Hierarchy is used as a basis for determining where new housing allocations are directed.
Without this information, the College simply reserves the opportunity to comment on any future evidence and policy approach in respect of this principle.

Other

ID sylw: 108472

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

The Magdalen College, Oxford is committed to highly energy efficient development so the principle of this Direction is supported. However, we strongly consider that the drive to net zero should be achieved through a national approach.
Criterion A of the proposed policy position would require all new development to demonstrate net zero operational carbon from total energy use (by achieving a 63% reduction in regulated emissions on site compared to 2021 building regulations. All improvements will be calculated using SAP.
The College considers that building regulations is the appropriate mechanism for delivering carbon reduction emissions. This standard approach provides certainty to housebuilders as efficiencies in supply chains will encourage delivery. These locally set standards complicate matters and could frustrate development.
Any locally set requirements must be consistent with the Written Ministerial Statement (WMS) published on the 13th of December 2023 and this has been confirmed by case law during 2024. The WMS sets out concerns that setting local standards increases complexity, reduces economies of scale and adds to the cost of building new homes. It is noteworthy that the Future Homes Standard will also be introduced nationally before this Plan is adopted and will likely further make the need for local standards superfluous.
Furthermore, there should be allowances for individual developments to make a financial viability case when achieving the requirements of this policy would render a proposal unviable.
It is important that the effect of costs is considered cumulatively along with other development costs. It is also particularly important to undertake ongoing monitoring and ensure that the standards sought are achievable so that housing delivery is not unduly restricted.

Other

ID sylw: 108473

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Similar to Draft Policy Direction 22, Magdalen College, Oxford considers that matters such as embodied carbon is best addressed at a national level to avoid different approaches and standards being set in different areas. The Planning and Energy Act 2008 does not state that LPAs can set specific standards with regard to the embodied carbon in new buildings. Nor is it included in the Planning Practice Guidance (PPG). This is a new technical standard that should not be established through a Local Plan at a time housebuilders are preparing to work to the Future Homes Standards.
The College has concerns about the impact on deliverability of development of imposing such requirements, particularly on SME developers.

Other

ID sylw: 108474

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Magdalen College, Oxford supports the aim of this Direction to achieve a minimum 10% Biodiversity Net Gain (BNG), which is consistent with national legislation. However, we are cautious about the proposal to seek out evidence that may support a requirement of above 10%.
The latest guidance was published by the Government in February 2024 and says, “… plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”
The Government guidance sets a high bar for justifying such a policy. The area in question should be significantly worse than the country as a whole and the decline should be linked to new development rather than generic changes such as to farming practices or industrial pollution. For example, the State of Nature Report 2023 (State of Nature Partnership, 2023), identified the primary cause of decline as being ‘Intensive management of agricultural land, largely driven by policies and incentives since World War II, has been identified as the most significant factor driving species’ population change in the UK’.
Therefore, it seems unlikely that there is sufficient evidence available to justify a higher BNG requirement.

Yes

ID sylw: 108475

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

Given its land-holding at Long Marston, Magdalen College, Oxford is supportive of the potential new settlement at Long Marston Airfield (New Settlement Location E1). Our clients site at Campden Road, Long Marston falls within the boundaries of this potential growth option.
We agree with the analysis in the New Settlements Assessment Document (November 2024) that Long Marston Airfield is one of the “more suitable” locations for a new settlement. However, as discussed below, we consider this site should be allocated for development regardless, either as part of the Airfield or as stand-alone allocation. If the site is included in the Long Marston New Settlement allocation, it should be acknowledged that parts of the allocation could come forward early where land ownership and infrastructure allow. There is potential for logical development parcels (such as the College’s interest) to simply be delayed from delivery, if unnecessarily linked to wider strategic delivery objectives.