No

ID sylw: 108049

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The HEDNA housing need is now out-of-date.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 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 The Core Strategy is out-of-date and housing needs must be measured against the Standard Method.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. 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.

Land at Walton Road, Wellesbourne forms part of SG16 Priority Areas 1. We support inclusion and Priority Area designation, which highlights the Site is sustainably and suitably located for growth in alignment with the spatial strategy. Development would assist with sustaining facilities and services in Wellesbourne, a smaller settlement. SG16 has been assessed against the SA Framework and generally performs favourably.

Other

ID sylw: 108050

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The policy direction broadly conforms with national policy requirements. Catesby Estates Plc are supportive of the aspiration to encourage sustainable transport and reduce reliance on private vehicles. The policy needs to acknowledge that given the spatial spread and rural nature of much of South Warwickshire, use of the private car will still be the preferred (and, in some cases, only) option for many residents, in the short-to-medium term.

The Council should therefore ensure there are appropriate parking standards in place for new developments. Concurrently, the Council should seek to identify and support improvements to sustainable transport throughout the plan period, to reduce dependency on private vehicles to a greater degree in the decades ahead. Residents should have the opportunity to use efficient and reliable public transport and safely walk or cycle to destinations where possible, as acknowledged in the policy direction.

It is stated that proposals must demonstrate how they will incorporate or contribute to high-quality infrastructure that facilitate sustainable travel. Commentary with regards to infrastructure provision has already been provided in relation to Policy Direction 5, and similar considerations apply here. It is recommended that the policy provides some flexibility, clarifying which types of proposals should address this within submissions (i.e. major development, but not renewable schemes, where this is not applicable).

Land at Walton Road, Wellesbourne is sustainably located. Development would encourage sustainable modes of travel as the site benefits from frequent bus services on Ettington Road to Warwick, Leamington Spa and Stratford-upon-Avon. The Site will seek to link to the existing pedestrian and cycle links. This aligns with the aspirations of this policy direction and Strategic Objective 11.

Yes

ID sylw: 108051

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Pegasus Group is promoting land at Walton Road, Wellesbourne for residential development on behalf of Rainier Developments.

The Site is part of SG16. Inclusion of this SGL is strongly supported. The Site is within Priority Area 1, a preferred location for growth under the spatial strategy. The Site is on the eastern edge of Wellesbourne and comprises 2.65 hectares of land southwest of Walton Road. The site comprises an agricultural field with associated agricultural buildings to the northeast, and is adjacent to the settlement edge. It is bound by vegetation along the borders. The closest primary school is situated 0.85 kilometres to the north. The nearest secondary school is 7.0 kilometres to the southeast. There is an existing access point to the Site off Walton Road. This currently provides access to the agricultural buildings, but could be used as the site entrance as shown on the illustrative masterplan (Appendix 2). A technical note has previously been prepared and submitted (Appendix 3), confirming a suitable access arrangement can be achieved.

The entire Site is within the Severn and Avon Vales national character area, characterised by western mixed agricultural landscape and vales and valleys broad landscape typology. The site is not designated as or in close proximity to 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. The site is within the Impact Risk Zone for Loxley Church Meadow SSSI. This could be addressed by suitable mitigation. There are other developed sites within the Zone, showing development in such areas can be acceptable. The Illustrative Masterplan shows how the site could accommodate circa 65 dwellings. The majority of the existing boundary vegetation could be retained and enhanced.

The site was assessed in the HELAA as ref 463. In Part B it scored 44.73. This score is average and should be considered favourably. Assessed against the SA Framework, the wider SGL has a major positive impact on Housing (Objective 9), positive impacts on Economy (Objective 13) and Flood Risk (Objective 2) – it is one of the best performing options for Flood Risk. Minor adverse impacts are identified in relation to Landscape (Objective 4), Cultural Heritage (Objective 5), and Pollution (Objective 6). It performs better than 9 other Strategic Growth Locations for Landscape, and 13 for Cultural Heritage, with minor adverse the best rating for any option.

The SA considers South of Wellesbourne among the worst performing for Biodiversity (Objective 3) because it is close to ancient woodland and Loxley Church Meadow SSSI. Given the distance from the Site to the SSSI (over 2.5km) and Wellesbourne Wood (over 750m), development of the Site would not have an adverse impact. On a site-specific level, an ecological survey will be carried out to assess ecological constraints, opportunities to deliver enhancements will then be established accordingly. The potential for development to deliver ecological benefits has not been acknowledged in the SA. The site in isolation performs better against Objective 3 than currently suggested. Assessment of the Site against other SA objectives has been undertaken:

1: Climate Change: The site would deliver circa 65 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Wellesbourne.

2: Flood Risk: The site is entirely within Flood Zone 1. There are areas of surface water flood risk, predominantly parallel with Walton Road. This could be addressed by suitable design and sustainable drainage systems. Much of the undeveloped land particularly in the north of Wellesbourne is constrained by flood risk with significant areas of flood zones 2 and 3 present, associated with the River Dene and River Avon.

4: Landscape: The site is characterised by modern residential development on two sides. The Ettington Park development adjoins Walton Road, as does The Oaks, a small office development immediately adjoining the site. The Grange development locates open space towards Walton Road however this development is south of this Site. Beyond the Grange is agricultural fields. The Site would continue the existing build line along Walton Road as established by Ettington Park and The Oaks. The Illustrative Masterplan shows how the site could be designed with on-site open space to link to open space provided by the Grange. This would create coherent development and minimise landscape impacts through good design. A landscape note has previously been submitted to the Council with previous representations and the Call for Sites submission. This concluded that the site benefits from total enclosure on three sides. For the eastern aspect towards the River Dene, sensitively designed buildings which reflect the local character can create an attractive settlement edge.

5: Cultural Heritage: The site is not close to any designated heritage assets. The listed buildings and Conservation Area are concentrated around Bridge Street/Ettington Road, to the north-west of the site and separated by existing development. The scheduled monument and registered park and garden referred to by the SA are located north-east of Wellesbourne and are a significant distance from this Site.

6: Pollution: The site is not near to an Air Quality Management Area. The SA refers to the A429 as a potential pollution source. The Site is separated from the A429 by existing modern residential development so it is reasonable to conclude any mitigation required would be minimal and achievable.

7: Natural Resources: The Site would result in loss of agricultural land however this would be a minor due to the relatively small site size. The Site is within a Mineral Safeguarding Area however the site is relatively small and given adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity.

8: Waste: Household waster generated by development can be managed with provision of suitable recycling facilities for all households.

9: Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing.

10: Health: Frequent bus services on Ettington Road provides access to hospitals. There is a recently developed doctors surgery within a mile of this Site. There is good access to leisure and recreation facilities within Wellesbourne with scope to provide on-site open space and connections to the public open space being provided by the Grange.

11: Accessibility and 12: Education: The existing bus stops on Ettington Road provide frequent services to Leamington Spa, Warwick and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are various local services and facilities in the local area, including a primary school. Secondary schools in Stratford-upon-Avon would also be accessible using public transport.

13: Economy: The site is well located to benefit from existing economic and employment opportunities associated with Wellesbourne which include the Distribution Park and the Wellesbourne Campus of the University of Warwick.

Other

ID sylw: 108055

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Pegasus Group is promoting land at Walton Road, Wellesbourne for residential development on behalf of Rainier Developments.

The Site is part of SG16. Inclusion of this SGL is strongly supported. The Site is within Priority Area 1, a preferred location for growth under the spatial strategy. The Site is on the eastern edge of Wellesbourne and comprises 2.65 hectares of land southwest of Walton Road. The site comprises an agricultural field with associated agricultural buildings to the northeast, and is adjacent to the settlement edge. It is bound by vegetation along the borders. The closest primary school is situated 0.85 kilometres to the north. The nearest secondary school is 7.0 kilometres to the southeast. There is an existing access point to the Site off Walton Road. This currently provides access to the agricultural buildings, but could be used as the site entrance as shown on the illustrative masterplan (Appendix 2). A technical note has previously been prepared and submitted (Appendix 3), confirming a suitable access arrangement can be achieved.

The entire Site is within the Severn and Avon Vales national character area, characterised by western mixed agricultural landscape and vales and valleys broad landscape typology. The site is not designated as or in close proximity to 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. The site is within the Impact Risk Zone for Loxley Church Meadow SSSI. This could be addressed by suitable mitigation. There are other developed sites within the Zone, showing development in such areas can be acceptable. The Illustrative Masterplan shows how the site could accommodate circa 65 dwellings. The majority of the existing boundary vegetation could be retained and enhanced.

The site was assessed in the HELAA as ref 463. In Part B it scored 44.73. This score is average and should be considered favourably. Assessed against the SA Framework, the wider SGL has a major positive impact on Housing (Objective 9), positive impacts on Economy (Objective 13) and Flood Risk (Objective 2) – it is one of the best performing options for Flood Risk. Minor adverse impacts are identified in relation to Landscape (Objective 4), Cultural Heritage (Objective 5), and Pollution (Objective 6). It performs better than 9 other Strategic Growth Locations for Landscape, and 13 for Cultural Heritage, with minor adverse the best rating for any option.

The SA considers South of Wellesbourne among the worst performing for Biodiversity (Objective 3) because it is close to ancient woodland and Loxley Church Meadow SSSI. Given the distance from the Site to the SSSI (over 2.5km) and Wellesbourne Wood (over 750m), development of the Site would not have an adverse impact. On a site-specific level, an ecological survey will be carried out to assess ecological constraints, opportunities to deliver enhancements will then be established accordingly. The potential for development to deliver ecological benefits has not been acknowledged in the SA. The site in isolation performs better against Objective 3 than currently suggested. Assessment of the Site against other SA objectives has been undertaken:

1: Climate Change: The site would deliver circa 65 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs as it would benefit from access to existing service and facilities in Wellesbourne.

2: Flood Risk: The site is entirely within Flood Zone 1. There are areas of surface water flood risk, predominantly parallel with Walton Road. This could be addressed by suitable design and sustainable drainage systems. Much of the undeveloped land particularly in the north of Wellesbourne is constrained by flood risk with significant areas of flood zones 2 and 3 present, associated with the River Dene and River Avon.

4: Landscape: The site is characterised by modern residential development on two sides. The Ettington Park development adjoins Walton Road, as does The Oaks, a small office development immediately adjoining the site. The Grange development locates open space towards Walton Road however this development is south of this Site. Beyond the Grange is agricultural fields. The Site would continue the existing build line along Walton Road as established by Ettington Park and The Oaks. The Illustrative Masterplan shows how the site could be designed with on-site open space to link to open space provided by the Grange. This would create coherent development and minimise landscape impacts through good design. A landscape note has previously been submitted to the Council with previous representations and the Call for Sites submission. This concluded that the site benefits from total enclosure on three sides. For the eastern aspect towards the River Dene, sensitively designed buildings which reflect the local character can create an attractive settlement edge.

5: Cultural Heritage: The site is not close to any designated heritage assets. The listed buildings and Conservation Area are concentrated around Bridge Street/Ettington Road, to the north-west of the site and separated by existing development. The scheduled monument and registered park and garden referred to by the SA are located north-east of Wellesbourne and are a significant distance from this Site.

6: Pollution: The site is not near to an Air Quality Management Area. The SA refers to the A429 as a potential pollution source. The Site is separated from the A429 by existing modern residential development so it is reasonable to conclude any mitigation required would be minimal and achievable.

7: Natural Resources: The Site would result in loss of agricultural land however this would be a minor due to the relatively small site size. The Site is within a Mineral Safeguarding Area however the site is relatively small and given adjacent residential development mineral extraction is unlikely to be acceptable in terms of residential amenity.

8: Waste: Household waster generated by development can be managed with provision of suitable recycling facilities for all households.

9: Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing.

10: Health: Frequent bus services on Ettington Road provides access to hospitals. There is a recently developed doctors surgery within a mile of this Site. There is good access to leisure and recreation facilities within Wellesbourne with scope to provide on-site open space and connections to the public open space being provided by the Grange.

11: Accessibility and 12: Education: The existing bus stops on Ettington Road provide frequent services to Leamington Spa, Warwick and Stratford-upon-Avon. These locations have train stations for onwards journeys, including to Birmingham. There are various local services and facilities in the local area, including a primary school. Secondary schools in Stratford-upon-Avon would also be accessible using public transport.

13: Economy: The site is well located to benefit from existing economic and employment opportunities associated with Wellesbourne which include the Distribution Park and the Wellesbourne Campus of the University of Warwick.

No

ID sylw: 108058

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

With regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire. Therefore, opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

. The policy direction suggests that there are 17,068 existing commitments which will form part of the supply over the plan period.
In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.40-year housing land supply at the present time.
Stratford District Council claim to have a 24.65-year housing land supply as of 1st April 2024, as set out in their Information Sheet dated 16th October 2024. We strongly dispute the assertion that the Council can demonstrate this level of supply at the present time.
If the Core Strategy is out of date, the five-year housing land supply for Stratford needs to be measured against the housing need calculated using the Standard Method, in accordance with the PPG. The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase).
4.14. Regardless of the current land supply Stratford have published, for the emerging SWLP, there is a minimum local housing need of 1,126 dpa, which equates to a need for at least 5,630 homes over the period 2024-29. The latest assessment by Stratford suggests that 3,505 homes will be delivered from 2024-2029, meaning there is a demonstrable substantial need for 2,125 homes irrespective of the housing land supply position. It also equates to a five year supply of just 3.11 years if the published land supply figures are taken as read.
. It is also important to emphasise that both Stratford and Warwick’s calculations are based on a number of assumptions regarding deliverability. The housing land supply figures may reduce further if sites do not deliver as expected, permissions expire without being implemented, or fewer windfall sites come forward than expected.
When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply (3.11 years and 4.40-years respectively), and as such the presumption in favour of sustainable development will apply, which may lead to a substantial number of speculative planning applications in locations which the Councils do not consider favourable for growth under the selected spatial strategy. Any under-delivery which may occur would result in an even lower supply. Specific and deliverable sites must be allocated for housing across South Warwickshire to ensure that there can be a steady supply of housing in Stratford and Warwick over the plan period, and certainly for five years following adoption, in line with Paragraphs 72 and 78 of the NPPF.
The Councils express a preference to concentrate growth on brownfield sites, Priority 1 areas, prior to considering development elsewhere. However, it is important to emphasise that there is insufficient previously developed land within South Warwickshire to accommodate the level of housing required. Indeed, the Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – just 11% of the minimum housing need required over the plan period (54,700 dwellings). As such, the study concludes (on page 37) that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (emphasis added).
The identification of a myriad of Priority 2 and 3 areas, where development can occur in accordance with the spatial growth strategy, is supported, to ensure that needs can be fully met. Proportionate growth directed away from brownfield sites to settlements which are comparatively smaller than Stratford, Warwick, and Leamington Spa will also support their viability and vitality, whilst providing opportunities to enhance sustainable travel options at these locations, resulting in positive impacts on transport and accessibility (SA Objective 11), as acknowledged in Appendix E of the SA, paragraph 3.1.6.
Twenty-four Strategic Growth Locations are identified, twenty-one of which would accommodate housing. It is stated that these locations could accommodate development which exceeds South Warwickshire’s housing need; The Councils suggest that allocations will not be made in all areas given that this exceeds their housing requirement. It is agreed that allocating land for 74,521 dwellings would be excessive, since the evidence is unlikely to justify this, and the plan must be deliverable. Notwithstanding, the Councils clearly have an opportunity to allocate some additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher-growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.

Other

ID sylw: 108079

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier are promoting Land East of Vicarage Lane, Sherbourne for residential development.
The Site was assessed positively in Part A and Part B of the latest HELAA and is located within Priority Areas 2 and 3, where growth, under the selected ‘Sustainable Travel and Economy’ spatial strategy, is considered acceptable. The land is well-located within the existing village and meet housing needs in the area. This land is suitable, available and deliverable and should be identified as a location for future residential development as part of the South Warwickshire Local Plan.
The representation demonstrates that there are no significant contains that would preclude the development of the site for residential development.
Rainier Developments welcome the opportunity to continue to comment upon the emerging SWLP Part 1. If the Councils require any further information in respect of Land to the east of Vicarage Lane, Sherbourne to assist in accurately assessing it, this can be provided upon
request.