No

ID sylw: 108009

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

1. The Inspector into the Stratford on Avon Core Strategy and Stratford on Avon Council both consider that the site lies within a sustainable location and is suitable for employment development.
2. Not only does SUA 4 lie in a sustainable location, the evidence also clearly shows that the Site lies within the Spatial Growth Priority Area and the Core Opportunity Area. In these circumstances, it cannot be the case that retaining the allocation does not adhere to the chosen Spatial Strategy ‘Sustainable Travel and Economy”.’
3. The real reason that SUA 4 has been de-allocated relates to the process. Due to the methodology of the HELAA, it is possible that a site that complies with the Spatial Strategy of the plan fails to pass the Part A test and is not considered further. However, in this instance Step 5 of the methodology was not implemented correctly for SUA 4.
4. Moreover, the Plan’s own economic evidence base recommended that the allocation be retained. There is no adequate justification proffering to not following this recommendation and no assessment has been made of the economic consequences of de-allocating SUA 4. Existing firms located at the Airfield surrounding SUA4 are drawing up proposals for expansion and there is no evidence to suggest that the allocation will not be built out within the Plan period.
5. Paragraph 85 of the NPPF requires planning policies to create the conditions in which businesses can invest, expand and adapt. The maintenance of SUA4 is required to enable new investment, as well as the expansion of the existing substantial businesses. This has been evidenced by letters from senior management of Yelo and Wealmoor.
6. For these reasons, the Plan fails the soundness tests:
o It has not been positively prepared.
o It has not been justified and evidenced based.
o It is not consistent with national policy.
7. To be made sound, the SUA 4 allocation should be re-instated into the Regulation 19 version of the plan.

Other

ID sylw: 108387

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

We support the proposed vision which responds to key facets of sustainable development in line with the NPPF. The principles align with our client’s aspiration to deliver sustainable, high quality and healthy places. Given the nation’s housing crisis, wording should be included to emphasise the importance of meeting the significant demand for housing. Tenures and sizes should address identified needs and affordability. The needs of existing businesses and their aspirations for growth should be accommodated. Meeting local housing and business needs in rural areas may require land adjacent to or beyond existing settlements, even if these are not well served by public transport (see NPPF Paragraph 89).

The Estate supports the 12 strategic objectives with the following additional commentary

Objective 1: The preferred development strategy aligns with this. We agree sustainable and proportionate growth should be located in areas with good transport connections. Larger-scale growth, such as new settlements, ensures a large supply of dwellings and employment land can be delivered in one go.

Objective 4: We wish to add that employment opportunities should be recognised in both urban and rural areas. Consideration should be given to NPPF Paragraphs 88 and 89 of the NPPF, which support a prosperous rural economy.

Objective 6: The Estate themselves have a 47-acre site for delivering biodiversity net gains and support the importance of conserving and enhancing the natural environment.

Objective 7: The Estate wishes to emphasise its deep-rooted sensitivity to the creation of an attractive landscape and countryside encompassing the villages of Preston on Stour, Atherstone on Stour, Clifford Chambers and Alderminster. This natural resource has been improved by nine successive generations of the same family. The Estate recognises the importance of creating high-quality, beautiful and sustainable developments that respect local character, as reflected in NPPF Paragraph 131.

Objective 8: The large rural estate owned by the Estate includes many heritage assets. The Estate understand the importance of conserving and enhancing the historic significance of such assets. New uses should be found where viable to ensure future longevity of heritage assets, which in turn helps Warwickshire retain its cultural heritage whilst enhancing its beauty.

Objective 11: The Estate wish to add that promotion of sustainable transport solutions should have regard to whether the site is in an urban or rural location. Opportunities for sustainable transport solutions in rural areas vary compared to urban areas. This should be taken into account in the preparation of this Local Plan. It is not unusual to support the growth of rural areas, as advocated by Paragraphs 82-84, 88 and 89 of the NPPF.

Other

ID sylw: 108388

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate welcomes the Council’s acknowledgement that the revised NPPF issued in December 2024 includes a new method for calculating local housing need and that the draft policy direction takes this into account.

From 12 March 2025 the SWLP must be assessed against the policies relating to plan-making in the revised NPPF. Paragraph 62 is clear that Local Plan policies relating to housing needs should, as a minimum, be based on the revised standard method calculation. This calculation should therefore be used rather than the HEDNA.

The Estate broadly supports the approach of identifying three Priority Areas as shown in Figure 5. We have a land interest within potential new settlement E1 and recognise a hybrid approach to the development strategy is required to ensure needs are met.

However, we wish to add that proportionate and sustainable growth can be delivered at rural settlements within priority areas, particularly Priority Area Three. The Estate own land within Alderminster and Clifford Chase that sit within the Priority Area Three. NPPF Paragraph 73 acknowledges the important contribution small-to-medium sites can make to meeting housing requirements, Paragraph 83 emphasises that policies should ‘identify opportunities for villages to grow and thrive, especially where this will support local services’. Consideration should be given to how sustainable growth of rural communities can help to achieve the forecasted housing need.

It should be made clearer in the next iteration of this draft policy direction that small-to-medium sites can be allocated within Priority Area Three. These could be built out relatively quickly and help the Council achieve a healthy land supply in the first five years of the local plan period.

Yes

ID sylw: 108389

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate supports the Councils’ approach of delivering one or more new settlements to help meet identified local housing need over the plan period. This aligns with NPPF Paragraph 77 and the Written Ministerial Statement ‘Building the homes we need’.

New settlements must meet the deliverability tests set out within the NPPF and the Councils must be comfortable that sites will be built out at a rate which ensures they maintain a healthy supply of housing each year.

The Lichfields ‘Start to Finish’ report is helpful in identifying average build-out rates. Its latest findings conclude:
• On average, it will take 6.6 years from validation of the first application to the first dwelling being completed on schemes of 2,000 or more dwellings.
• On average, the annual build-out rate range for schemes of 2,000+ dwellings is between 100-188 dpa.
• On average, the annual build-out rate range for schemes of 500-999 dwellings is between 44-83 dpa.
• It is 34% quicker to deliver greenfield sites of 500 or more units than some brownfield sites.

The Estate has prepared separate representations in support of E1 Long Marston Airfield, within which the Estate own land, which conclude that this is one of the more sustainable potential locations.

Yes

ID sylw: 108390

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate supports delivery of small-to-medium sites as they can contribute to housing needs relatively quickly, ensuring a healthy five-year housing land supply can be maintained in the early years of the plan period.

We support the identification of BUABs to ensure proportional and sustainable growth can be accommodated within settlements without exacerbating demand on existing services, facilities and infrastructure. We support review of the settlement hierarchy. Clifford Chambers public transport can now be calculated as ‘Very Good’ rather than ‘Good’.

We do not disagree that Neighbourhood Plans can allocate small sites, or that housing, employment and other related-development can be delivered within or adjacent to BUABs outside of Green Belt locations. However, we do not think a threshold size is necessary. We suggest using similar wording to Policy DS3 in the Cotswold Local Plan, which provides a flexible policy approach which allows rural settlements with greater sustainability credentials to grow incrementally and allows scope for rural settlements to grow where they have “reasonable access” to neighbouring rural settlements with a larger range of services and facilities, considering distance, route quality, topography and pedestrian safety.

The Estate supportive growth within the Spatial Growth Strategy Priority Areas 1-3. Any growth within such circumstances located within the Cotswold National Landscape should meet other relevant policies in the emerging Local Plan.

Yes

ID sylw: 108391

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate as a principle, support methods to assist the Councils to achieve a net zero future and therefore have no in principle objections to the purpose of this policy.

Yes

ID sylw: 108392

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate fully support Draft Policy Directions 22, 23 and 24.

Yes

ID sylw: 108393

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate fully support Draft Policy Directions 22, 23 and 24

Yes

ID sylw: 108395

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate fully support Draft Policy Directions 22, 23 and 24

Other

ID sylw: 108396

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate fully support ‘Draft Policy G – Climate Resilient Design’. As a manager of many properties both in residential and business use, the Estate are fully abreast of the importance of ensuring that any new built form is designed and built to achieve net zero carbon. In addition, any existing buildings where possible should be made more energy efficient, reducing the reliance on fossil fuels and in their replacement, include low carbon energy efficient measures.