Yes

ID sylw: 97123

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

Strategic Growth Location SG05 is the best location for development to meet housing needs in the Plan period. The site scores highest in the sustainability appraisal, and the three sites which make up the SGL all have low scores in the HELAA. The sustainability of the site, with close proximity to everyday services, facilities, schools and employment opportunities, coupled good transport connections, will have limited landscape impact and will not adversely impact any acknowledged interests including heritage assets, biodiversity, flooding and drainage. The land is available and can be developed without delay.

Yes

ID sylw: 97133

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The identification of Strategic Growth Location 05 and particularly Sites 97 Glebe Farm and 191 Bungalow Farm is strongly supported. The sites are highly sustainable and well connected, entirely suitable to meet future development needs.

Although both sites score well in the HELAA, some of the scoring is inaccurate and if properly assessed the scores will lower, further confirming their suitability for allocation and future development. Particular concern is raised regarding scores for:

• Green Belt
• Deliverability and Viability
• Minerals Safeguarding
• Surface Water Flooding
• Listed Buildings
• Connectivity

No

ID sylw: 97139

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The document does not conform to national planning policy and must be redrafted to reflect the latest National Planning Policy Framework version.

Draft Policy 1 must confirm the key priorities of the SWLP as required by the Framework - to significantly boost the supply of homes in a sustainable manner, and provide sufficient employment land to meet the Districts’ needs. It must NOT set maximum provision figures. These would unnecessarily restrict the ability of the area to meet the key aims.

For housing provision, references to the 2022 HEDNA should be removed. The policy should set out the minimum number of homes needed assessed using the Standard Method (see NPPF paragraph 62). Adequate flexibility must be incorporated for changing circumstances, and to accommodate housing needs arising from beyond the Districts’ boundaries.

We support meeting much of the housing requirement though new settlements and significant extensions to existing settlements. Particular attention should be given to accommodating development in locations already supported by necessary infrastructure and facilities, and those where they can be provided. In accordance with NPPF paragraph 22 the plan period should be extended from 25 years to at least 30 years, and housing and employment requirements increased accordingly.

No

ID sylw: 97144

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The National Planning Policy Framework states, at paragraph 11b), that strategic policies should provide for the objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas. This need for cross boundary provision is reiterated in Framework paragraph 36 a). As drafted, Policy Direction 4 does not go far enough towards meeting the needs of the Greater Birmingham and Coventry areas. Some cross boundary requirements are already acknowledged yet the SWLP does not currently propose to make any allocations to meet those needs from the outset and should be amended to do so, reflecting the latest information available.
That notwithstanding it remains appropriate for the SWLP to allocate additional sites which can be released if there is a shortfall against the Districts’ own requirements or needs arising from adjacent areas. A policy of reserve sites must be clearly set out in the SWLP and not left to a separate document, to be adopted at a later date.

Other

ID sylw: 97157

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The Policy Direction indicates that the SWLP will take a sequential approach to allocating strategic areas of growth and new settlements, with the release of land from within the Green Belt where there is sufficient justification on the grounds of sustainability to meet the Framework test of
‘exceptional circumstances’. The Direction indicates that further work on this is ongoing.
This approach, and the allocation of sustainable sites within the Green Belt in Stratford and Warwick Districts to meet future development needs, is strongly supported.
That notwithstanding, the SWLP Preferred Options does not currently conform to national planning policy and must be redrafted to reflect the guidance in the PPG on Green Belt, published on 27 February 2025. In particular this requires Councils not only to assess Green Belt but also to identify what land within the Green Belt is grey belt, and to prioritise the allocation of grey belt sites ahead of other Green Belt land.
It is clear from the wording of the current Framework that the Government recognises there will now be occasions when land within the Green Belt should be released for development. New paragraph 146 makes this particularly clear, stating that ‘exceptional circumstances’ for altering Green Belt boundaries will include, but are not limited to, instances where an authority cannot meet its identified
need for homes, commercial or other development through other means. Paragraph 147 outlines further instances when land might be released. In respect of Stratford and Warwick Districts, there is insufficient previously developed and underutilised land, and opportunities to increase density on existing sites, to meet the identified housing needs. It is not reasonable for land to be allocated in neighbouring local authority areas (indeed Stratford and Warwick will be required to assist their own neighbours). Greenfield land will be required instead.
The thrust of national planning guidance is that land to be allocated must be sustainably located. Given historic development patterns, many of the most sustainable locations are now within the Green Belt and this should be acknowledged by removing land from the Green Belt to meet future housing needs. The Part 2 Green Belt assessment will confirm this.
To consider this further, the current Local Plans focused development on areas outside of Green Belt and have used many of the available opportunities for allocations in such locations. For example, in Warwick District, substantial allocations were directed to the areas south of Warwick and Leamington, providing housing close to existing employment areas. Further development in
the same location will extend the settlements away from their core centres leading to an imbalance of growth and extending travel distances back to the centre. Development on other edges of the settlements would be closer to local service and facilities, shops, schools, employment and have a greater range of sustainable transport opportunities and must be fully explored, particularly where development will have limited impact on the Green Belt across the area of the plan (as required by Framework paragraph 146)

No

ID sylw: 97163

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The Policy Direction indicates that the Local Plan will require the provision of pitches and plots on large scale development sites, being sites providing over 500 homes. The proposed policy direction is unjustified and therefore does not comply with the requirements of Framework paragraph 36b).
Provision of gypsy, traveller and show peoples accommodation is an essential part of meeting housing needs across the District area and it is important that the SWLP includes a policy to consider the matter, and more particularly to meet the needs identified by the Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Assessment (August 2024) or any subsequent update. The current need, identified in the August report, is for up to 89 gypsy and traveller pitches, and 18 additional travelling showpeople plots, and provision for this level of accommodation is required.
The Councils consulted on the best location for these sites as part of the Issues and Options, suggesting three options – part of large development sites, on sites identified in the Plan, or assessed on a site by site basis against an agreed list of criteria. As the Preferred Options confirms, allocation within large development sites was the least favoured option. It is therefore surprising that this is now the preferred option.
The August report confirms that ‘there is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security’. Thus to comply, small sites will be required. Provision, even of relatively small sites, as part of large developments, would not seem to conform with this requirement, and are unlikely to sit comfortably within large development areas.

The policy should revert to either specific allocation or a criteria based approach on a site by site basis.

Yes

ID sylw: 97167

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The thrust of this policy is supported, including the concept of 20 minute neighbourhoods which will achieve sustainable developments, providing residents with a genuine alternative to the private car to reach everyday services and facilities including shops, schools, employment and social opportunities.

In making this comment is it noted that Strategic Growth Area SG5 is particularly well located and capable of achieving sustainable development. It can be brought forward quickly and easily to meet housing needs in the early part of the Plan period, in compliance with the 20 minute neighbourhood concept.

No

ID sylw: 97172

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

The final paragraph of Draft Policy Direction 32 indicates there will be a robust policy for the provision of EV charging infrastructure in new developments. Framework paragraph 16 f) states that Development Plans should serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area. Electric Vehicle Charging Points, with associated infrastructure, are required under Building Regulations Approved Document S for all new dwellings and commercial developments. As such, there is no need for the duplication within planning policy and the references should be removed.

No

ID sylw: 97178

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

Meeting the statutory 10% BNG requirement is challenging and causes delays and viability concerns to many developments but is unavoidable as a national validation requirement. Draft Policy Direction 38 indicates the Council’s will explore evidence to adopt a higher percentage to achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006 Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of knowledge of the industry it seems highly unlikely such justification could be provided. The policy proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as to how any such policy could be implemented – particularly in respect of viability, without undue pressure on applicants to undertake lengthy and complicated viability assessments.

No

ID sylw: 97184

Derbyniwyd: 05/03/2025

Ymatebydd: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Asiant : Stansgate Planning

Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to and enhance the natural and local environment there is currently no requirement, or indeed reference, to Environmental Net Gain at a national level.
The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any information about how such a policy would function in practice. There are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty could delay the deliverability of sites. As such this policy direction should be removed from the emerging Plan.