Other

ID sylw: 107985

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Broad support in principle for protecting and providing different typologies of open space. NPPF Paragraph 103 stipulates planning policies relating to open space must be underpinned by robust and up-to-date assessments of need. Such assessments haven't been undertaken to date. This is somewhat acknowledged by the Councils in stating technical evidence is lacking to determine thresholds. Considerable work is required to ensure the evidence exists to formulate a fully justified and sound policy.

Where open space cannot be provided on-site, the Councils propose a contribution will be requested to enhance or provide open space within 400 metres of the development. There may not always be scope for this. The figure should serve as guidance; the policy should read “within 400 metres of the development where possible”.

The policy direction states multi-use games areas (MUGAs) will be requested as part of all major development sites. As defined in the NPPF, a major residential development comprises 10 dwellings or more. A development of 10 dwellings is unlikely to generate need for a new MUGA. The policy should be amended to clarify the requirement is only applicable to larger-scale major development (e.g. 100+ dwellings), providing the evidence on need exists to justify this.

Other

ID sylw: 107986

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Further evidence is required to justify the content and inclusion of this policy, in accordance with Paragraph 103 of the NPPF, with the Playing Pitch Strategy still yet to be completed. The policy direction’s commitment that the need for sports and leisure facilities will be considered on a case-by-case basis having regard to the type of scheme and the site is supported, over what would be an unnecessary requirement for all major residential schemes to deliver such facilities, when the need many not exist to justify this.

Other

ID sylw: 107987

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Designated Areas of Restraint already exist within Stratford District; these seek to protect areas that make an important contribution to the character of a settlement. A study to review and identify Areas of Restraint, and whether they are needed as a policy designation, needs to be carried out to provide the evidence for a justified policy.

If Areas of Restraint are retained/designated, the policy should be clearer that these would not restrict development, as stated in the supporting justification, and that residential development of an appropriate design and scale would be permissible within them, providing that they do not harm the Area of Restraint, and subject to compliance with other development plan policies.

No

ID sylw: 107988

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Two of South Warwickshire’s most sustainable locations for growth fall within this potential buffer - Shipston-on-Stour and land at Long Marston, identified as a Strategic Growth Location (SG17) and Potential New Settlement (E1) respectively.

This appears to have been influenced by comments from the Cotswold National Landscape Board to the Issues & Options Consultation. However, there is no basis for a National Landscape buffer in national policy. No evidence been provided to suggest that this is needed. The Cotswolds National Landscape Management Plan 2023 – 2025 doesn't refer to a buffer or suggest that one should be established. The Management Plan serves as a material consideration in the determination of planning applications within the National Landscape and its setting. The current policy approach to the National Landscape in the Stratford Core Strategy should be carried over in the absence of evidence or justification tor a buffer. Development shouldn't be precluded in sustainable locations where schemes can be designed in a manner which doesn't adversely impact the National Landscape or its setting.

NPPF Paragraph 189 already requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in National Landscapes. It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” The requirement for development within the 'setting' of National Landscapes to be sensitively located and designed means that a policy on this matter and a buffer are unnecessary.

No

ID sylw: 107989

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Special Landscape Areas only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Evidence needs to be prepared on which parts of South Warwickshire merit a Special Landscape Area designation.

Such a designation would not be based on national guidance and policy. It is also not included in Natural England's approach. Paragraph 187 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes’. It is considered that the special landscape character across South Warwickshire can be suitably conserved and enhanced through a generic landscape policy, without need to create an additional landscape designation, which would require another study to be undertaken to form part of the evidence base.

If the Councils do wish to proceed with Special Landscape Areas regardless of the above, it is imperative that these do not restrict development in what may be sustainable locations for growth. The policy direction currently recognises this; thus, this aspect is supported.

Other

ID sylw: 107991

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This policy direction is broadly supported, with it generally aligning with the aspirations in the NPPF with regards to the protection and enhancement of landscapes, set out in, for example, Paragraph 187. However, it should be noted that Paragraph 135(c) does state that whilst development should be sympathetic to the surrounding landscape, this should not prevent or discourage appropriate innovation or change, such as increased densities. This should be acknowledged within the policy. It is affirmed that it is unnecessary for all major developments to provide Landscape and Visual Impact Assessments (LVIA) as currently suggested. This will need to be fully justified, and such justification has not been provided within the Preferred Options document. The need for an LVIA should be considered on a case-by-case basis, and/or specific criteria for when one is required should be prepared by the Councils.

Yes

ID sylw: 107992

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

NPPF Para 187 b) states "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 states the quality of farmland should inform choices about future use within the planning system. A policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising there may be circumstances where development on best and most versatile (BMV) land is appropriate, when the planning balance favours approval. The exemption from protection for the Strategic Growth Locations and New Settlement Sites is strongly supported. This will ensure the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both the sites which are allocated in the Pre-Submission plan and those which are not, since they have already been identified as suitable growth locations in the Preferred Options document. The SA does not suggest any negative impacts would arise from excepting sites from this policy.

Other

ID sylw: 107998

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Pegasus Group is promoting land south of Darlingscote Road on behalf of Rainier Developments for residential development, including on-site play and green infrastructure.

The site is identified on the interactive map as Ref 460, part of SG17. It is adjacent to Shipston-on-Stour's settlement boundary. Allocation for residential development is strongly supported. The Site is adjacent to Shipston-on-Stour's settlement boundary. To the north are established employment uses, to the south a school and leisure centre, and residential uses beyond in both directions. Land to the north and west is predominantly undeveloped agricultural land.

Shipston-on-Stour is a sustainable settlement within Priority area 1. The settlement includes a number of shops and services, a medical centre, schools (primary and secondary), a leisure centre and employment opportunities. A new site access would be provided from Darlingscote Road to serve proposed development. The Site gently slopes, descending from northeast to east. There are no Public Rights of Way within the Site or adjacent.

Shipston High School is adjacent to the Site and includes a leisure centre facility. The nearest heritage asset, Shipston House, is Grade II listed and 250m east.

The site was given a score of 30.40 in HELAA Part B. The council concluded it should remain in consideration for allocation. The Site scores very well compared to other sites. In the Sustainability Appraisal, SG17 scored second best for accessibility and was found to have some positive impacts on health. The SA Appraisal is based on the SGL as a whole. The Site individually would score better.

1: Climate Change: The site would deliver circa 90 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would benefit from access to existing service and facilities in Shipston-on-Stour and support delivery of 20-minute neighbourhoods

2: Flood Risk: SG17 as a whole is 4th worst-scoring for Flood Risk. However, the promoted site is entirely within Flood Zone 1. There is a small amount of surface water flood risk on the north-western boundary parallel with the existing farm access road. The indicative masterplan shows this area as undeveloped green space.

3: Biodiversity, Flora, Fauna and Geodiversity: The site is not a Special Conservation Area, Site of Special Scientific Interest, National Nature Reserve, ancient woodland, Local Nature Reserve, Local Wildlife Site, Local Green Space or priority habitat. Suitable design and landscaping could mitigate the proximity of the Shipston High School Sheep Field LWS. The SSSI Impact Risk Zone for Midsummer Meadow is triggered by proposals of 100 or more dwellings. The proposed development of c. 90 dwellings does not meet this threshold.

4: Landscape: Previous landscape evidence for this Site is attached at Appendix 4. The site is located on the middle plateau, higher than the town. However, it has a limited range of intervisibility with publicly accessible routes in the wider area and the screening provided by the topography. The Site does not interrupt long distance landscape views. The landscape strategy includes retention of existing boundary vegetation and careful consideration of building heights and materials. The concept masterplan shows how this could be achieved on this site.

5: Cultural Heritage: The closest designated heritage assets are the Grade II Listed Buildings Shipston House and Our Lady & St Michael Church, both located between Darlingscote Road and Tilemans Lane. These are separated from the site by existing development. There would be no intervisibility.

6: Pollution: The site is not within or close to an Air Quality Management Area. The SA notes the proximity of the A4300 and River Stour as potential minor negative impacts - these are located on the other side of the SGL and are separated by the existing settlement.

7: Natural Resources: Natural England mapping shows the site as Grade 3 agricultural land. The Site would only result in a minor loss. The Site is within a Mineral Safeguarding Area. Development would be a minor loss in the context of the large MSA designation and would require consultation with the Country Council.

8: Waste: 90 houses would generate some household waste which can be managed with provision of suitable recycling facilities for households.

9: Housing Provision: The Site would deliver housing in a sustainable location, including affordable housing.

10: Health: The site is close to the existing GP surgery and adjacent to the leisure centre. The site is close to the wellbeing zone identified in the NDP to facilitate resident wellbeing and access to outdoor greenspace.

11: Accessibility and 12: Education: The site is adjacent to the High School and 6 minutes walk from the Primary School. The site is well-located to access a variety of services and facilities primarily to the north of the settlement. The closest bus stops are on Darlingscote Road, providing a good service to Stratford where onwards services can be accessed, including trains to Birmingham.

13: Economy: SG17 scored 5th worst for Economy due to a lack of employment areas in Shipston-on-Stour. However, there are existing employment uses directly opposite the Site within walking distance. Bus connections to A roads mean residents can access larger towns with a range of employment opportunities.

No

ID sylw: 108005

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.

Other

ID sylw: 108006

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.

The Site at Milcote Road, Welford-on-Avon is in Priority Area 3 but not in an SGL. The site is sustainably located, suitable, achievable, and deliverable for a high-quality residential development of 40 dwellings. Development needn't be limited to Strategic Growth Locations. Other areas within and adjacent to settlements can accommodate growth.