Yes

ID sylw: 100681

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

n/a

Yes

ID sylw: 100689

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

This Planning Statement supports the allocation of ID21 in the South Warwickshire Local Plan of land at Drayton Manor Farm on behalf of the main land owner, Drayton Manor Farms Ltd. According to the Masterplan, the allocation will deliver:
• Residential development located in five zones, amounting to net 13.4 hectares and 400 houses.
• Two hectares of employment land, subsuming 1 hectare of existing employment land (10 existing units measuring 3447m2 floorspace).
• A large amount of public open space, providing connectivity with existing PROWS.
There are no physical constraints to development. The site is not in Green Belt. About half of the land is contaminated, which prevents agriculture but not residential or employment uses. Most of the site is flood zone 1 and those parts in zones 2 and 3 are set aside for public open space and biodiversity enhancement. The site has direct vehicular access to A46 Alcester Road.
The Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on Avon Local Plan identifies this site is within the “800m buffer of urban extent” of Stratford-upon-Avon.
In terms of deliverability, the promotor/landowner has a strong track record of maximising the employment development potential of Drayton Manor Farm and delivering large-scale renewable energy (solar). It has funding and expertise to deliver mixed use development, integrating it with renewable energy infrastructure (eg solar modules and energy storge units) and the existing adjacent solar farms (one of Warwickshire’s largest) in order to deliver net zero.
A Transport Appraisal supports this proposed allocation of ID21. The proposed development of 400 houses and 2 hectares of employment land1 is ideally located in respect of the existing major, diverse employment opportunities at Drayton Manor Farm (East and West; see the schedule at Appendix 4) and the forthcoming SUA.2. The site is also well connected to the local bus service (to be enhanced at SUA.2) and other facilities and amenities at Drayton Manor Farm and Stratford-upon-Avon, all within a suitable walking and cycling distance from the site.
In conclusion, this is a highly sustainable location for the allocation of ID21 in the South Warwickshire Local Plan for mixed uses – 400 houses and employment use – as part of SG18.

No

ID sylw: 100698

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
The SWLP Preferred Options does not currently conform to national planning policy and should be
redrafted to reflect the latest version of the National Planning Policy Framework, currently that
published in December 2024 (with February 2025 amendments).
Taking this into account, Draft Policy 1 should confirm the key priorities of the SWDP as required
by the Framework - to significantly boost the supply of homes in a sustainable manner, and to
provide sufficient employment land to meet the Districts’ needs. The Policy must NOT set maximum
provision figures as this would unnecessarily restrict the ability of the area to meet the key aims.
In respect of housing provision, all reference to the 2022 HEDNA should be removed. Instead the
policy should set out the minimum number of homes needed assessed using the Standard Method
(in accordance with Framework paragraph 62). Adequate flexibility must be built in to meet
changing circumstances, and to accommodate housing needs arising from beyond the Districts’
boundaries.
The Plan proposes to meet much of the housing requirement though the allocation of new
settlements and significant extensions to existing settlements. This is supported as an appropriate
response to meeting housing needs within the Districts. Particular attention should be given to
accommodating development in locations which are already supported by necessary infrastructure
and facilities, as well as those where they can be provided.
In accordance with Framework paragraph 22 the plan period should be extended from 25 years to
at least 30 years, and the housing and employment requirements increased accordingly.

No

ID sylw: 100702

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
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.

No

ID sylw: 100707

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
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.

No

ID sylw: 100709

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

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: 100712

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
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: 100714

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
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

No

ID sylw: 100716

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
This Draft Policy Direction states that development will be expected to increase tree canopy cover,
supported by a tree canopy assessment, with further guidance to be developed. No justification
has been provided for including this within policy, nor has any information been provided regarding
how such a policy would function in practice. There are no other examples of adopted Local Plan
policies requiring an increase in tree canopies, and the matter is not covered by national planning
guidance. This requirement may harm viability, cause longer lead-in times and the uncertainty
could delay the deliverability of sites. Sites with many existing trees (and canopies) will be treated
different to sites with few or no trees. Sites with native trees will be treated differently to sites with
non-native trees. More tree canopy is not necessarily beneficial or necessary. More overshading
could harm residential amenity. This Policy Direction should be deleted from the Plan