No

ID sylw: 108653

Derbyniwyd: 07/03/2025

Ymatebydd: Kingacre Estates Ltd (‘Kingacre’)

Asiant : Nexus Planning

Policy Direction 1 could, in principle, reflect a sound approach but there are several concerns that must be incorporated into any draft policy that the Councils advance, including:
a. The SWLP Housing Requirement must, as a minimum, meet the Standard Method (2024) derived Local Housing Need figure of +2,188 dpa over the emerging Plan period (2025 – 2050). Reference to the HEDNA (2022) housing need figure should be deleted.
b. Any unmet need set to be provided for as part of the SWLP should be identified in addition to the Housing Requirement for South Warwickshire and monitored independently.
c. The SWLP should actively seek to allocate appropriate sites at the Districts’ rural settlements to support modest growth for local communities. The development needs of rural communities should not be left to a Neighbourhood Planning process, which is piecemeal in its application and effectiveness.
d. Reasonable opportunities to support sustainable development outside of the Green Belt and the National Landscape should be fully examined and utilised.
e. The Councils should seek to allocate sufficient small and medium-sized sites to maintain a consistent and effective housing delivery trajectory throughout the plan period, consistent with national policy.
f. The Spatial Strategy must include allocation of sites at sustainable rural settlements where there are opportunities to enhance or maintain the vitality of rural communities.
g. Land South of Hardwick Road, Priors Marston (Site ID 419) should be allocated specifically, for between 10-27 new homes, to help maintain the sustainability of enable the development of a new pedestrian connection from Priors Marston village through to the Priors Sports and Social Club, to support its longer-term viability.

Other

ID sylw: 108654

Derbyniwyd: 07/03/2025

Ymatebydd: Kingacre Estates Ltd (‘Kingacre’)

Asiant : Nexus Planning

Policy Direction 3 seeks to identify ‘Built Up Area Boundaries’ (‘BUABs’) for settlements within South Warwickshire, alongside considering whether a revised settlement hierarchy classification is required across the Districts. Furthermore, this Policy Direction seeks to provide principles in relation to the appropriateness of development within and adjacent to the BUABs (where defined).
In non-Green Belt locations, Policy Direction 3 refers to ‘Housing, employment and other settlement related development, within or adjacent to Built Up Area Boundaries’. Kingacre supports the recognition that certain sites may be considered appropriate where they outside but adjacent to the BUABs. This will be critical to support the modest growth of the Districts’ rural settlements over the plan period.
However, Policy Direction 3 then provides that ‘Where such sites are adjacent to Built Up Area Boundaries, a threshold site size will be established, below which such developments are likely to be acceptable…’. This is problematic as what may constitute an appropriate quantum of development will necessarily be dependent upon the specific circumstances and context of each site. As such, it is inappropriate to apply an arbitrary number to the maximum number of homes considered to be appropriate on such sites.
Furthermore, should a limit of around 10 dwellings per site (or indeed fewer) be taken forward, as is indicated may be the case in the supporting text, it would be unlikely that much (if any) affordable housing would be provided. Given the stark need for affordable housing, particularly within rural villages, the implementation of this threshold approach is inappropriate and counter productive. Medium-sized sites may well be considered appropriate at these locations, depending on the context of the specific site, the potential benefits of developing it, and its potential harms. It is, therefore, recommended that such development at smaller villages should be assessed on a case-by-case basis.
Recommendation(s): a. Continue to provide an approach in which housing, employment, and other settlement related development in non-Green Belt locations may be considered appropriate, where it is outside but adjacent to the BUABs. b. Transition to an approach where such sites are to be considered on a case-by-case basis, rather than applying a numerical threshold above which development is inappropriate (whether the threshold relates to site size or development quantum).

Yes

ID sylw: 108655

Derbyniwyd: 07/03/2025

Ymatebydd: Kingacre Estates Ltd (‘Kingacre’)

Asiant : Nexus Planning

Policy Direction 4 indicates that the SWLP will be underpinned by a housing need and availability evidence base that considers the Coventry and Warwickshire Housing Market Area (‘HMA’) as well as the Greater Birmingham and Black Country HMA. Kingacre supports the Councils’ commitment to developing an evidence base that will consider and seek to address ‘…any shortfall of land availability to deliver in full the Housing Market Area's Objectively Assessed Housing Need or other evidenced housing need arising outside South Warwickshire’.
Furthermore, the draft Policy Direction clarifies that should the evidence and the duty-to-cooperate process clearly indicate that ‘…there is a housing or employment need that cannot be met within the administrative boundaries of 12 the authority in which the need arises and part or all of the need could most appropriately be met within the South Warwickshire Local Plan…’, then reserve sites will be released to meet that need.
Kingacre supports the Council’s commitment to meeting unmet needs arising, where evidenced, from other Authorities within the Coventry and Warwickshire HMA and Greater Birmingham and Black Country HMA. In meeting this commitment, the Council should identify specific sites that are set aside for these purposes and monitor their delivery independently of those sites allocated to meet the District’s own substantial housing needs.
Recommendation(s): a. Continue to develop an evidence base and policy position that assesses and seeks to meet identified unmet needs arising from Authorities in the Coventry and Warwickshire HMA and Greater Birmingham and Black Country HMA

Yes

ID sylw: 108656

Derbyniwyd: 07/03/2025

Ymatebydd: Kingacre Estates Ltd (‘Kingacre’)

Asiant : Nexus Planning

In addition, these representations promote Land South of Hardwick Road, Priors Marston (‘the Site’) for residential development as a component of a sound spatial / growth strategy. The proposals would support the sustainable growth of Priors Marston, assist in meeting local housing needs, and support the longer-term viability of local services. The proposed development comprises: a. Approximately 10 - 27 new homes to assist in meeting local housing needs; b. New public open space, including multi-functional SuDS; and c. Improvements to local pedestrian infrastructure, including the potential for a new link through the Site to the Priors Sport and Social Club to the south, to support its longer-term viability.
In accordance with the recommendations made at Section 2 of our representations, we advocate that the Councils should include an allocation for residential development of the Site as an opportunity to support local community infrastructure whilst meeting housing needs at a sustainable rural settlement, in accordance with the objectives of Paragraph 83 of the NPPF (2024).
The Site is available for development in the immediate term, suitable for the type of development proposed (it is neither within the Green Belt nor the Cotswold National Landscape) and achievable. As such, it is a deliverable site to assist in early to medium term plan-led delivery