Other

ID sylw: 94631

Derbyniwyd: 03/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Turley

Rainier support the approach, providing it is supported by evidence around its viability.

Other

ID sylw: 94632

Derbyniwyd: 03/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Turley

Rainier support the approach, providing it is supported by evidence around its viability.

Other

ID sylw: 94633

Derbyniwyd: 03/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Turley

Rainier have broad support for this, but we note that the data and policy context around flood risk is in a state of flux, and that policies such as this need to ensure they take the right approach to flood risk. One example is around surface water flooding and ensuring that risk is informed by site specific FRA rather than high level Flood Map for Planning and the Flood Risk from Surface Water, which the draft policy currently suggests.

Other

ID sylw: 107936

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

These representations broadly support the vision. It reflects Paragraph 7 of the NPPF which states that the purpose of the planning system is to contribute to sustainable development. The overarching principles do not align with the vision. None of them refer to delivery of homes and jobs which are key to sustainable development. Reference must be made to this to then feed into the Strategic Objectives which do reference housing and employment. The selected spatial growth strategy, ‘Sustainable Travel and Economy’ should be referred to and woven into the other principles.

The vision and first principle strongly emphasizes the climate emergency. While generally supported this should not dominate the vision and strategic objectives to the detriment of delivery of development to meet identified needs. The second principle refers to a beautiful south Warwickshire. This is supported and Paragraph 131 of the NPPF makes reference to beauty but this needs to be defined and supported by guidance on what it means in practice.

The Strategic Objectives cover the social, economic and environmental dimensions of sustainable development as set out in Paragraph 8 of the NPPF and they are therefore considered consistent with national policy.

No

ID sylw: 107937

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction suggests this is the maximum number of homes but additional housing may be required to help deliver affordable homes and meet unmet need from neighbouring authorities. This would be deliverable as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years. Windfall delivery has varied from between 30 and 933 dwellings per year in Stratford. Overreliance on windfall should be avoided given this wide variation.

We strongly dispute Stratford District's housing land supply figure. Deducting past over-supply undermines the conclusion of the 2021 review as this has been used to substantially lower the housing requirement. The Core Strategy is out-of-date and housing needs must be measured against the Standard Method. The emerging SWLP identifies a minimum need of 1,126 dpa, or 5,630 homes for 2024-2029. The latest assessment by Stratford suggests 3,505 homes will be delivered in this period, creating a demonstrable need for 2,125 homes. The five year supply is therefore just 3.11 years. Following a recent appeal decision it is confirmed Warwick District has only 4.40 years of supply. Therefore the presumption in favour of sustainable development applies which may lead to speculative applications outside the preferred growth strategy.

We support identification of Priority 2 and 3 areas given the limits to brownfield capacity identified in the Urban Capacity Study. This will help support the viability and vitality of smaller settlements and provide opportunities to enhance sustainable transport. While we agree not all strategic growth areas will be required, the Councils have an opportunity to go beyond minimum local need to deliver much-needed affordable homes, accommodate unmet demand from neighbouring authorities, and ensure flexibility in case of shortfalls of delivery. The SA undervalues the positive contribution housing development can make to biodiversity. Baselines may be low, particularly in the case of arable land. The SA does not recognise the positive impacts on transport and accessibility in terms of improving public transport options.

Darlingscote Road, Shipston-on-Stour is within SG17 and it is a priority 1 Area to which growth should be directed. It is sustainably located, available, achievable, and deliverable, It performs better than other parcels in the SGL as it close to services and has low flood risk.

Other

ID sylw: 107939

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

New settlements can make an important contribution towards meeting South Warwickshire’s housing requirement but they also have long lead-in times and, if too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations to ensure the delivery of a range of sites. This aligns with Paragraph 61 of the NPPF, which states that a variety of land should be brought forward for housing, i.e. sites of different scales, ranging from minor development through to new settlements.

Other

ID sylw: 107940

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This policy and review of existing settlement boundaries are supported, particularly since the Urban Capacity Study identifies that development within existing boundaries cannot meet South Warwickshire’s housing requirement. Support for small-scale development adjacent to settlement boundaries is welcomed. The threshold site size should only be guidance to ensure that the policy does not discourage efficient use of land.

Growth adjacent to villages should be encouraged where there are not adverse sustainability implications. Growth across a range of settlements will help provide homes for those who grew up in rural communities and who wish to stay local to their roots, families and social networks. This assists with achievement of Strategic Objective 2. Going beyond minimum housing numbers will help deliver more affordable housing in villages.

No

ID sylw: 107941

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The evidence on shortfalls in the HMAs is out-of-date and should be refreshed as a matter of priority. To deliver the housing the HMAs require will necessitate a clear delineation of responsibility under the duty to cooperate to address any shortfalls, including through the SWLP Part 1.

In anticipation of significant shortfalls and in the context of significant increases for many authorities under the Standard Method, the Councils should plan appropriately and identify reserve sites for this purpose in order for the plan to be sound.

Other

ID sylw: 107942

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.

Other

ID sylw: 107943

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The Councils acknowledge that the evidence to justify safeguarding land for transport proposals is emerging. Paragraph 111(c) of the NPPF supports identification and protection of routes which could be critical to developing infrastructure to widen transport choice, but also states that policies should do this only where there is robust evidence. It will be necessary for the policy and safeguarding of land to be underpinned by appropriate evidence, to ensure that this is justified and sound.