Other

ID sylw: 107995

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG Land Promotion I (UK) Limited (hereafter “CEG”) and Dr D Brightman, control land east of the M40, Junction 12 (“the site”). The site has been previously promoted and submitted to the Call for Sites exercise as part of Site 759. Representations were also made to:
• South Warwickshire Local Plan Scoping and Call for Sites consultation in June 2021; and
• South Warwickshire Local Plan Issues and Options consultation in March 2023.
The site comprises 18.6 hectares is located off Junction 12 of the M40 and is considered to be an appropriate location for a major employment development. The site has the potential to deliver a range of commercial floorspace including medium to large industrial/warehouses, medium size local business park and small enterprise park, as well as roadside focuses and general retail/drive thru uses.
As set out these representations, there is significant demand and immediate need for B2 and B8 floorspace within Stratford-on-Avon District which is unlikely to be met in the short-term through either existing commitments or the local plan process. The Proposed Development, in scale and locational terms, will help to meet this demand as well as supporting the 3,000 dwelling Upper Lighthorne community, improving sustainability within the area by providing a range of local employment opportunities. This flexible proposal will both build on the strengths of the existing automotive cluster in the District related to Jaguar Land Rover and Aston Martin Lagonda by providing flexible space appropriate for related activities and business start-ups (Class E(g)(ii & iii) and B2 uses) whilst also providing space for B8 logistics, helping to realise the economic potential of the M40 corridor.
These representations are made specifically in the context of CEG interest in the site, which forms part of the identified site within the plan known as SG14. SG14 is listed in Chapter 4 of the SWLP as a Strategic Growth Location and is therefore considered within the Interim Sustainability Appraisal supporting the SWLP Preferred Options Consultation. Therefore this representation focuses on matters that are relevant to the spatial strategy of the Plan and the options proposed for the future growth of South Warwickshire.
Accompanying this representation is a red line boundary outlines CEG’s land interests in red.
The representations follow the structure of the Regulation 18 Preferred Options consultation document, providing responses under the topics and questions identified, as relevant.

Yes

ID sylw: 107996

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG supports the Plan’s Vision and objectives, which determine how development will be delivered. CEG’s proposals for land east of the M40, Junction 12 are considered against each of these principles to demonstrate how the site’s development can help to achieve the vision.
A climate resilient and Net Zero Carbon South Warwickshire – Proposals for the site could contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy.
Moreover, the site is situated in a sustainable location being strategically placed next to the new settlement Lighthorne Heath, Jaguar Land Rover (JLR) and Aston Martin Lagonda (AML). Furthermore, the site provides the opportunity to introduce an integrated transport network including the provision of demand response transport (DRT), which could be funded through Section 106 contributions. This will influence and change travel behaviour of commuters to and from the site and neighbouring sites such as that of JLR, and to benefit from new and existing residents in the vicinity of the site i.e., within Gaydon and Lighthorne Heath.
To summarise, the site can improve existing infrastructure and generally promote a culture of change towards active travel which in turn aids the climate resilience of South Warwickshire.
A well-designed and beautiful South Warwickshire – Development at the site, will provide a mix of commercial units all designed to the highest standard. Moreover, proposals would provide substantial landscape areas, enhancing visual and physical connections.
A healthy, safe and inclusive South Warwickshire – Development within the site provides the opportunity to provide pedestrian and cycling connections to the surrounding area. This will help to foster a cohesive working environment which will support health and wellbeing.
A well-connected South Warwickshire - The site is located in an inherently sustainable location for commercial development. The M40 provides a direct route to Banbury to the south-east and Warwick to the north-west. Banbury benefits from a railway station as does Warwick. There are two bus stops along the B4100 adjacent to the Site that provide services to Temple Herdewyke, Avon Dassett, Leamington Spa, Milverton and Banbury Town Centre.
A biodiverse and environmentally resilient South Warwickshire –Biodiversity net gain will be incorporated into the proposals for the site. The conceptual framework for the site will feature and cohesive ecological network that retains existing landscape features including hedgerows and tree belts and a network of swales. SWLP Strategic Objectives
In addition, the Plan includes 12 strategic objectives which reflect the area’s social, environmental and economic issues. Where relevant, CEG provide comment below on how development at land east of Gaydon can help to meet the Plan’s objectives:
SO1: Providing sustainable levels of growth in the area
The Core Strategy recognises the importance of the area, specifically stating that:
“The Gaydon Site is a key economic asset within the District and the wider region, employing several thousand people, together with indirect employment in relation to logistics and suppliers. The site is located adjacent to an established highway network, including the M40 which is an important transport gateway into Coventry and Warwickshire.”
The importance of this location is further reflected in both the emerging SWLP and the December 2023 and South Warwickshire Economic Strategy. The SWLP Preferred Options document identifies the Gaydon Area/M40 Junction 12 as a Major Investment Site which sits within a wider ‘Economic Core Opportunity Area’. This area includes Gaydon and the M40 corridor and comprises the main towns of Stratford-upon-Avon, Warwick, Whitnash, Leamington Spa and Kenilworth, the A46 corridor, the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre and Stoneleigh Park.
Draft Policy Direction 13 of the SWLP also confirms the area will be the focus for new employment development in the South Warwickshire Area, building on existing employment hubs, harnessing the potential offered by co-locating businesses and research facilities and support the strategy for attracting significant inward investment to the area. The South Warwickshire Economic Strategy identifies the same area as ‘Core Investment Opportunity Area’. The focus for the area is attracting inward investment to drive the South Warwickshire economy as well as encouraging inward investment in the most accessible parts of South Warwickshire. Indeed, the emerging South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy, whilst acknowledging national and local planning policies (e.g. Green Belt)”.
The SWLP preferred options also identifies the M40/A46 corridor as a Road Opportunity Area based on the West Midlands Strategic Employment Sites Study (WMSESS) which recommends the identification of 1-2 mixed/B8 sites and 1 B2 site to deliver 125 ha of strategic employment i.e. sites of over 25 ha and largely dedicated to units of over 9,300sqm. This clearly recognises the potential of this corridor to play an enhanced role in delivering strategic economic growth in South Warwickshire.
The site, which forms part of SG14, is located close to the principal design and engineering centre for Jaguar Land Rover (JLR) and Aston Martin Lagonda (AML). Directly to the north-east of the Site is 100ha of land specifically allocated for the expansion JLR in the Stratford-on-Avon Core Strategy under Policy CS.22 and policy GLH (Gaydon/Lighthorne Heath now known as “Upper Lighthorne Heath”).
To the west, beyond the JLR/AML site, is Lighthorne Heath, a historically small village built to originally support RAF Gaydon which now comprises a mixture of private and social housing together with a 3000 dwelling new settlement.
731 homes are now occupied within the new settlement (December 2024) and therefore with a community quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
The Core Strategy recognises the eventual sustainability and significance of Lighthorne Heath through the supporting text to policy CS.15, which confirms that; “In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.”
The settlement hierarchy for Stratford-on-Avon District clearly recognises the transformative nature of this new settlement to the local area. It is therefore considered that given the existing and anticipated future rate of completions and the services and facilities now being delivered on the at the allocation, Lighthorne Heath should be considered as a Main Rural Centre within the settlement hierarchy, alongside Alcester, Bidford-on-Avon, Henley-in-Arden, Kineton, Shipston-on-Stour, Southam, Studley and Wellesbourne.
AML’s headquarters within Gaydon provide the main production facility together with research and development. Further to Aston Martin Lagonda’s presence, JLR operate their advanced design and engineering centre at Gaydon. The design and research centre and extensive test track facilities have been established over the last 30 years.
The Site is therefore strategically positioned to drive significant inward investment within this ‘Core Economic Area’, supporting the automotive cluster whilst also increasing the provision of jobs, complimenting the role of Upper Lighthorne in the settlement hierarchy.
SO3: Providing infrastructure in the right place at the right time & S011: Connecting people to places
Significant investment has been made to highway infrastructure around J12 of the M40. Development at Junction 12 is there an appropriate location for employment development to come forward now as there is existing capacity on the highway network and delivery is not reliant on significant upgrades to the Junction. The SWLP recognises that significant upgrades would be required to facilitate the strategic employment growth options identified at Junction 13 (Land at Red House Farm) and 15 (Wedgnock Park Farm). This is not the case at J12 where the only major new investment in the medium / long term would be a new northern slip road onto the M40 that can be delivered on land within the full control of CEG and National Highways.
Proposals for the site, together with wider land parcels could deliver a comprehensive integrated transport network including the provision of pedestrian/cycle connections and the delivery of new/upgraded transport links.
Given that significant growth could be directed to J12, the site also provides the opportunity to deliver road side retail/drive thru uses to support the safety and welfare of road users in line with paragraph 111 of the NPPF.
SO4: Developing opportunities for jobs
The site would generate significant local employment of significant benefit to the local economy. The jobs created would make a significant contribution to the Stratford-on-Avon economy, provide a number of employment opportunities and help the economy to diversify. Securing these employment opportunities is critical, particularly following the impacts of the Covid-19 pandemic. Indeed, Stratford-on-Avon District Council have suggested that the District has been the fourth most adversely affected authority from COVID. The jobs created as a result will help the economy to recover. It should also be stated that the Government, since being elected in July 2024, have placed an important new emphasis on growth and economic development with this being their number 1 mission for the next parliamentary term.
It is evident from the HEDNA that there has been a shortfall in the supply of B8 floorspace within the District. The provision of further flexible space that is capable of providing space for storage and distribution (B8 use) alongside General Industrial (B2) will help to provide jobs that will help to diversify and strengthen the local economy.
At a national level the logistics sector has played an important role in providing jobs, it has seen job growth at a higher rate than across the economy as a whole. Furthermore, as technological advancements have continued there has been a greater focus on the use of innovative, cutting-edge technology which has resulted in considerably higher skilled jobs than may have been the case previously. This has been confirmed through the Department for Transport “Future of Freight” report published in June 2022 which states:
“Since 2010, the number of jobs in transport and storage has grown by 26% compared to only 14% across the whole economy. There is increasing sophistication of roles in the sector with Professional and Associate Professional and Technical roles increasing by 331,000 since 2010. Meanwhile in 2021, the number of UK businesses classified as transport and storage was 88% higher than in 2011, with fastest growth in the Midlands, East of England, Yorkshire and The Humber”
Further to the above, in terms of skills, The British Property Federation’s (BPF) “Levelling up - The Logic of Logistics” report published in 2022 reports substantial growth in technical and professional roles (+331,000) in the sector over the last decade.
In terms of B8 uses, examples of the type of jobs that will be provided on Site are set out below which are in addition to the jobs associated with class B2 and class e (g) (ii) and (iii):
•
Supply chain design and planning;
•
Procurement and supply management;
•
Warehouse design and management;
•
Distribution network design and management; and
•
Inventory management and control.
The importance of logistics to the automotive sector should not be understated. The automotive industry heavily relies on automotive logistics to manage the complex supply chain involved in the production and delivery of vehicles. In this regard, they are considered synonymous and provision of B8 in this location would support existing sectors, particularly the automotive cluster at Gaydon which is identified as a core opportunity sector within the SWES.
SO8: Protecting and enhancing our heritage and cultural assets and SO12: Protecting and enhancing our environmental assets
The SWLP ensures that appropriate environmental considerations have been made when considering and assessing the options to accommodate future development. The site can also be delivered without causing significant impact on environmental assets. There are no ecologically important sites within or adjacent to the site, it lies entirely within Flood Zone 1; although there is a small area of the site to the north which is susceptible to surface water flooding. This can be satisfactorily mitigated through design, layout and specific drainage design. Development be delivered to secure the mandatory levels of biodiversity net gain (BNG), and mitigation for any protected species, should any be discovered, can be secured in any future planning application.

Yes

ID sylw: 107997

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

The Gaydon/Junction 12 M40 area is acknowledged as being a location of strategic importance in both SWLP and the Economic Strategy. The SWLP identifies it as a ‘Strategic Growth Option’ and the South Warwickshire Economic Strategy refers to it as being within a ‘Economic Core Opportunity Area’. Indeed, the South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy”.
SG14, alongside SG13, is considered an appropriate location for economic growth in the short, medium and long term by concentrating commercial investment in an area that requires minimal infrastructure investment. The 100ha JLR site, which is expected to be released to the wider market, and CEG’s site east of Gaydon (30ha) and site east of Junction 12 (20ha) have the capacity to meet the Council’s strategic employment need in full.
CEG’s site at SG14 can come forward for a mix of employment uses that can help satisfy the need identified within the Alignment Paper. For reasons set out below, SG14 is considered logical by virtue of its sustainability and immediate access to the Strategic Road Network but also when compared with other locations, particularly along the M40/ M42 corridor it is the least constrained area.
Beyond Banbury Road (B4100) is the principal design and engineering centre for JLR and AML. Directly to the north-east of the Site is 100ha of land specifically allocated for the expansion JLR in the Stratford-on-Avon Core Strategy under Policy CS.22 and policy GLH (Gaydon/Lighthorne Heath now known as “Upper Lighthorne Heath”).However, it is acknowledged that the 100ha JLR site will likely be released to the wider market as part of the SWLP.
Furthermore, the site is accessible to significant emerging advanced engineering research and development investment at the University of Warwick’s Wellesbourne Innovation Campus. The planning application at the Campus (which is consistent with the adopted Wellesbourne Innovation Campus Masterplan SPD) will provide for up to 4 million sq.ft of research and development floorspace through the collaboration of leading industry investment and academic research. The site currently accommodates Lotus, Rimac and the West Midlands Manufacturing Group and is becoming a recognised regional and national automotive battery research and testing facility.
To the north-east, beyond the JLR/AML site, is Lighthorne Heath, a historically small village built to originally support RAF Gaydon which now comprises a mixture of private and social housing together with a 3000 dwelling new settlement.
731 homes are now occupied within the new settlement (December 2024) and therefore with a community quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
The Core Strategy recognises the eventual sustainability and significance of Lighthorne Heath through the supporting text to policy CS.15, which confirms that;
“In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.”
The settlement hierarchy for Stratford-on-Avon District clearly recognises the transformative nature of this new settlement to the local area. It is therefore considered that given the existing and anticipated future rate of completions and the services and facilities now being delivered on the at the allocation, Lighthorne Heath should be considered as a Main Rural Centre within the settlement hierarchy, alongside Alcester, Bidford-on-Avon, Henley-in-Arden, Kineton, Shipston-on-Stour, Southam, Studley and Wellesbourne.
AML’s headquarters within Gaydon provide the main production facility together with research and development. Further to Aston Martin Lagonda’s presence, JLR operate their advanced design and engineering centre at Gaydon. The design and research centre and extensive test track facilities have been established over the last 30 years
The Core Strategy recognises the importance of the site, specifically stating that:
“The Gaydon Site is a key economic asset within the District and the wider region, employing several thousand people, together with indirect employment in relation to logistics and suppliers. The site is located adjacent to an established highway network, including the M40 which is an important transport gateway into Coventry and Warwickshire.”
The importance of this location is further reflected in both the emerging SWLP and the December 2023 and South Warwickshire Economic Strategy. The SWLP Preferred Options document identifies the Gaydon Area/M40 Junction 12 as a Major Investment Site which sits within a wider ‘Economic Core Opportunity Area’. This area includes Gaydon and the M40 corridor and comprises the main towns of Stratford-upon-Avon, Warwick, Whitnash, Leamington Spa and Kenilworth, the A46 corridor, the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre and Stoneleigh Park.
Draft Policy Direction 13 of the SWLP also confirms the area will be the focus for new employment development in the South Warwickshire Area, building on existing employment hubs, harness the potential offered by co-locating businesses and research facilities and support the strategy for attracting significant inward investment to the area. The South Warwickshire Economic Strategy identifies the same area as ‘Core Investment Opportunity Area’. The focus for the area is attracting inward investment to drive the South Warwickshire economy as well as encouraging inward investment in the most accessible parts of South Warwickshire. Indeed, the emerging South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy, whilst acknowledging national and local planning policies (e.g. Green Belt)”.
The SWLP preferred options also identifies the M40/A46 corridor as a Road Opportunity Area based on the West Midlands Strategic Employment Sites Study (WMSESS) which recommends the identification of 1-2 mixed/B8 sites and 1 B2 site to deliver 125 ha of strategic employment i.e. sites of over 25 ha and largely dedicated to units of over 9,300sqm. This clearly recognises the potential of this corridor to play an enhanced role in delivering strategic economic growth in South Warwickshire.
SG13 and in particular CEG’s land interests at SG14 are therefore strategically positioned to drive significant inward investment within this ‘Core Economic Area’, supporting the automotive cluster whilst also increasing the provision of jobs, complimenting the role of Upper Lighthorne in the settlement hierarchy.
The NPPF sets out at paragraph 145 that ‘…Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced through the preparation or updating of plans.’
For plan-makers to reach a point where exceptional circumstances can be demonstrated, paragraph 146 confirms that this can include ‘…instances where an authority cannot meet its identified need for homes, commercial or other development through other means’.
And at paragraph 147 ‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.’
This assessment of whether all other reasonable options have been examined will take account, according to paragraph 147, of whether the strategy:
“a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
The NPPF clearly sets out a sequential approach to allocating land for development within the Green Belt – essentially dictating that utilising Green Belt land should be a ‘last resort’, where there are no other options to accommodate the required growth.
As detailed within CEG’s responses to Chapter 3, the site is considered to be inherently sustainable location for commercial development. However, it is also considered to be sequentially preferable to other locations within the area, specifically Green Belt locations that have been identified for economic growth. Therefore, SG13 should be identified as the economic hub for the SWLP by utilising the existing economic activity and the potential for supply chain synergies and the attractiveness of the location for businesses based upon the automotive sector.
SG13 and CEG’s site at SG14 has the capacity to deliver circa 150 ha of employment in a relatively unconstrained location and with limited highways improvements which would only be required after a significant amount of development has already been delivered therefore allowing delivery of economic growth at the earliest opportunity. This is currently being assessed but it is anticipated that some 2 million sqft (60ha) of land could come forward before any further major highway infrastructure is required.
An assessment of alternative junction locations on the M40 has been undertaken. These locations have been chosen as a result of the SWLP, clearly recognising the potential of the M40 corridor to provide further commercial space within the sub-region and the area being identified in the WMSESS as Opportunity Area 8, with a specific need in the Alignment Paper of 75- 125ha.
M40 Junction 15 and 14
The junctions and land surrounding them are located near to the existing labour force in Warwick and there are existing employment units close to Junction 15, off Edgehill Drive. Junction 14 does not currently allow the egress of vehicles travelling west along the M40, nor the entry of vehicles wishing to travel east. Substantial M40 junction improvements would be required to meet occupier requirements and to accommodate the vehicle movements associated with large scale employment development. The area to the west of the junction is within the Green Belt, the boundary of which follows the route of the A46, broadly north to south. Both Sherborne and Barford Conservation Areas are located close to the junction to the south/south east, whilst 3 Scheduled Monuments also lie within this area. Warwick Castle Registered Park and Garden forms an important heritage constraint to the North East of the junction, the grounds of which are also within the boundary of the Warwick Conservation Area. Areas of land to the west, south and east of the junction suffer from flood risk, with a significant area of land falling within either Flood Zone 2 or 3 associated with the River Avon. As per paragraph 147 of the NPPF, exceptional circumstances would need to be demonstrated to release land from the Green Belt and that it is sequentially preferable to alternative locations. The identified constraints, particularly Green Belt and Flood Zone 3, are
considered to have a significant impact on the suitability of this location for large scale commercial development and is therefore not sequentially preferable to Junction 12.
M40 Junction 13
The junction and surrounding land are located relatively close to the village of Bishop’s Tachbrook, with Leamington located to the North. In terms of access to workforce, the village of Bishop’s Tachbrook when compared with Lighthorne Heath, is considered to be less sustainable. As previously set out, 731 homes are now occupied within Lighthorne Heath (December 2024) and therefore a community is quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
Junction 13 does not currently allow for vehicles travelling east on the M40 to exit the motorway and not does it allow users to join the motorway in order to travel west. Substantial M40 junction improvements would be required in order to accommodate the vehicle movements associated with large scale employment development. A large area of ancient woodland and Local Wildlife Site is located to the south, also containing a Scheduled Monument. A further Scheduled Monument is also located to the south east of the junction. To the north lies Bishops Tachbrook Conservation Area. The configuration of the motorway junction is considered to be a significant constraint affecting the suitability of this location for large scale commercial development.
The above assessment confirms that junctions within the opportunity area are constrained, particularly by Green Belt. Furthermore, those junctions that are not within the Green Belt are also not considered, in their present form, to be suitable for employment of the scale proposed. For example, Junction 13 does not allow two-way access onto the M40 and would therefore need substantial upgrades. The SWLP recognises that significant upgrades would be required to facilitate the strategic employment growth options identified at Junction 13 (Land at Red House Farm) and 15 (Wedgnock Park Farm).
Junction 12 is unconstrained compared to other junctions within the Opportunity 8 area and importantly can come forward with minimal infrastructure investment. It would augment the existing automotive economic hub providing a major sub-regional / regional focus for economic growth that could be delivered in the short, medium and long term within the Local Plan period.
This analysis therefore further supports that Junction 12 is the most appropriate location for employment development within the M40 corridor where there is existing infrastructure capacity and where delivery is not reliant on significant and complicated upgrades.
In view of the above, CEG’s site at SG14 should be included within the draft plan as part of a focused strategy of economic growth building on an already established automotive hub.
Interim Sustainability Appraisal
The site is assessed in the Interim Sustainability Appraisal of the South Warwickshire Local Plan (the “interim SA”) alongside 23 other potential Strategic Growth Locations (“SGL”) considered as Reasonable Alternatives. According to paragraph 5.1.1 of the Interim SA the SGLs are expected to meet a proportion of the identified housing and employment needs for the SWLP period 2025-2050.
SG14 (Gaydon Lighthorne Heath) is considered as a mixed use site across 836 hectares. CEG controls around 20 ha of SG14 with no legal restrictions which could affect development. It is proposed that CEG’s land interests will come forward as primarily employment land.
Of the 24 SGLs considered within the Interim SA, three have been identified as potential locations for employment growth, including SG07, SG09 and SG13.
The Interim SA confirms at paragraph 2.7.3 that Green Belt is not considered as a ‘policy off’ position is adopted. CEG consider that in further comparing the SGLs following the work of the Interim SA, reference must be made
back to the NPPF which sets out a sequential approach to the use of land for development. As the SWLP accepts that there is insufficient brownfield land available to meet economic development needs it is important that before assessing and allocating Green Belt land, sustainably located non-Green Belt options should be considered first in line with the sequence as set out at paragraphs 145 to 147. SG07 is its entirety located within the Green Belt and is therefore sequentially less preferable to accommodate development than SG14 which lies entirely outside of the Green Belt.
In considering the scoring of SG14 for Economy, it scores just a single positive impact. However, other options such as SG08 score a major positive impact on employment provision. The Interim SA explains that spatial growth options expected to provide more than 1,000sqm of employment floorspace scored a major positive impact. Given SG14 includes CEG’s site which extends to approximately 20 ha in size and is being put forward for employment, it is considered that it should be rescored to having a major positive impact. The single positive impact does not reflect the Interim SA’s own methodology.
Furthermore, where negative scores are awarded in the Interim SA due to environmental or physical constraints present on the site, CEG confirm that sufficient mitigation can be secured through development, for example in relation to local wildlife sites, biodiversity, ancient woodland, landscape and heritage.

No

ID sylw: 107999

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG support the policy direction in so far as it relates to the plan period of 25 years. The approach to planning for a longer period than the minimum required by the NPPF will enable a more cohesive growth strategy to be prepared ensuring that large scale development has a better chance of delivering the housing and employment growth required for South Warwickshire.
Draft Policy Direction 1 looks to the Coventry and Warwickshire Alignment Paper (2024) which brings together the HEDNA (2022) and WMSESS (2024) to identify employment land residual needs. For up to 2050, the policy identifies a residual need of 217 ha. For strategic industrial, the policy identifies a residual need between 75-125 ha up to 2045 to include 1-2 mixed/ B8 sites and 0-1 B2 sites within Road Opportunity Area 8 along the M40/A46. Given the need for strategic employment identified within the WMSESS only covers the period up to 2045, CEG request that the need figure is uplifted to cover the SWLP plan period to 2050. The strategic site period spans 23 years therefore in lieu of commissioning additional evidence, CEG advise that the 125ha need figure identified by the Alignment Paper be subject to a 25% uplift which would take the total need for the plan period to approximately 156ha.
Junction 12 is excellently placed to accommodate the above employment need within Road Opportunity 8 Area as set out within these representations.

No

ID sylw: 108000

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

Draft Policy 12 identifies three potential sites: Land at Red House Farm; Wedgnock Park Farm; and JLR allocation at Gaydon. Each potential site is discussed in turn below:
Land at Red House Farm
Land at Red House Farm comprises approximately 121ha of employment land and appropriate use classes could include E(g)(iii), B2 and B8 uses. This site is reliant on the delivery of a new junction to replace the two one-way junctions at Junction 13 and Junction 14 of the M40, as well as changes to the A452 and B4100. Delivery of new or significantly altered motorway junctions is a complex and timely endeavour. Taking account of the necessary steps to delivery which includes approval of various business cases, obtaining necessary permissions, land assembly (including potential for CPO), numerous stages of design, funding and eventual construction the timeframe for delivering infrastructure of this nature is 5-7 years as a minimum. In CEG and its consultant’s experience it is much closer to 10 years. On this basis, CEG has serious reservations regarding the viability and deliverability of the Red House Farm site.
In addition, there is a large area of ancient woodland and Local Wildlife Site is located to the south, also containing a Scheduled Monument. A further Scheduled Monument is also located to the south east of the junction. To the north lies Bishops Tachbrook Conservation Area. The configuration of the motorway junction is considered to be a significant constraint affecting the suitability of this location for large scale commercial development.
In view of the above, CEG have serious concerns regarding the meaningful delivery of this site the within the period up to 2050. Therefore, the SWLP should be looking at alternative locations for employment growth.
Wedgnock Park Farm
Wedgnock Park Farm comprises approximately 141 ha and is located to the west of Warwick. The site falls entirely within the Green Belt. For this reason and when considering alternative options for employment development such as CEG’s site at Land East of Gaydon, Wedgnock Park Farm is not considered sequentially preferable. Notwithstanding, as set out within the draft policy direction, this site relies on a much broader strategy for growth west of Warwick/Leamington therefore in isolation would not be appropriate. It is also CEG’s understanding that existing capacity at is heavily constrained and would require significant infrastructure improvements to accommodate the level of growth identified.
JLR Allocation at Gaydon
CEG support the inclusion of this allocation within the SWLP however it would need to be released to the wider market. However, the inclusion of a restriction on B8 unit size should be removed. There is no evidence or justification that larger B8 units are not needed to support the automotive supply chain and such a policy restriction could suppress appropriate investment. Not having this site available for strategic B8 upon adoption of the plan
risks the ability for this type of development to be delivered within the first 5-10 years. This is particularly important as alternative sites cannot accommodate this easily, as outlined previously.
Land East of Gaydon and Land East of the M40, Junction 12
CEG request that Land East of Gaydon (included within SG13) and CEG’s site Land East of the M40, Junction 12 (included within SG14), are identified as a location for employment as an extension to the JLR allocation as, jointly, the key economic ‘hub’ within the Local Plan area. The sites extend to approximately 30 ha and 20ha in size respectively and has capacity to deliver significant commercial floorspace at an established employment hub.
Junction 12 has the capacity now and would not require such significant additional highway works to accommodate the full potential growth in the area.(unlike Red House Farm and Wedgnock Park Farm) and would concentrate commercial investment in an area that requires minimal infrastructure investment. The site therefore can come forward early within the plan period. It is clear from the HEDNA (2022) that there is a substantial need for employment floorspace in the District and an acute short term need for floorspace to be available now to satisfy the increasing end-user demand in the District. The ability of CEGs sites to provide readily available floorspace to assist with meeting the overall needs and the short-term user specific demand, is considered to be a significant economic benefit and when assessed against other identified employment options within the SWLP.
The site is also relatively unconstrained, There are no ecologically important sites within or adjacent to the site and it lies entirely within Flood Zone 1. Furthermore, in accordance with the paragraph 147 of the NPPF in relation to taking a sequential approach, it reduced the requirement for Green Belt release.
Therefore, in light of the above, CEG’s land interests should be included as extension to the 100ha JLR allocation which would take the total employment land supply in this location to 150ha covering the strategic needs of the plan period. Moreover, this is currently being assessed but it is anticipated that some 2 million sqft (60ha) of land could come forward before any further major highway infrastructure is required. With CEG controlling all these sites there would be no legal constraints and they can come forward in the short, medium and long term ensuring the SWLP has a continual supply of employment land.

Yes

ID sylw: 108001

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG support the Draft Policy Direction 13. CEG’s site at Land East of the M40, Junction 12 within a Core Opportunity Area would support the role of the automotive cluster, recognised as a key sector within the South Warwickshire economy, through providing space for businesses to expand or co-locate, facilitating wider agglomeration benefits and providing space for the supply chain.

No

ID sylw: 108002

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG have serious concerns regarding the implementation of Draft Policy Direction 19 on the delivery of large scale employment sites. Whilst well-intended, the requirement to provide affordable units, which are below the market rate, has no basis in national policy. The Council justifies this by referencing paragraph 85 the NPPF which states that “Policies… should create the conditions in which businesses can invest, expand and adapt.”
This is considered a misguided interpretation of policy. Whilst CEG support the need for provision of smaller units to address demand from SME’s, it is considered that this would be best be addressed by allocating specific sites with the required mixes to address this demand. Expecting larger sites to accommodate such uses needlessly risks the delivery and viability of site. Moreover, there is a high degree of uncertainty of how effective this policy mechanism would be in creating more affordable space. CEG consider that the lack of affordable units is partly a result of a significant undersupply of modern, well located, sustainable employment space. Therefore, in the first instance the SWLP should be looking to boost employment land supply to satisfy this need. It is therefore requested that the Council revisit and remove this policy and instead allocate specific sites to meet the identified need.

No

ID sylw: 108004

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG strongly encourage the SWLP to avoid seeking a higher percentage of BNG than the statutory 10% requirement required by the Environment Act 2021.
Any higher percentage required is likely to have implications on the viability of delivering jobs across South Warwickshire as where BNG cannot be met on site, this would lead to substantial costs to purchase habitat units from off-site providers or statutory biodiversity credits from the Government.
There are serious concerns with any policies which seek to increase the level of BNG to be provided given the likely impact this would have on the deliverability of the full extent of allocations, and/or the ability of residential allocations to viably deliver the required level of affordable housing and key infrastructure.
Planning Practice Guidance1 confirms that:
“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”
Given the national microscope on the delivery of biodiversity net gain, there should be no requirement for any additional local policy requirements over and above that set out statutorily and therefore CEG recommend that the SWLP does not seek to require any greater than 10% BNG to be achieved.

Other

ID sylw: 108017

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG Land Promotion (UK) Limited (hereafter “CEG”), on behalf of the landowners, control the following, hereafter referred to as (‘the site’);
•
the majority of the existing JLR allocation (as referred to in the draft plan and allocated as such in the adopted Development Plan);
•
land to the rear/north of the Aston Martin Lagonda (AML) Headquarters (current safeguarded for the expansion of AML within the adopted Development Plan); and
•
and a triangular parcel south of the B4100 at Gaydon / Lighthorne Heath (“the sites”).
Collectively, these sites have been previously promoted and submitted to the Call for Sites exercise and is known as Site 505. Representations were also made to:
•
South Warwickshire Local Plan Scoping and Call for Sites consultation in June 2021; and
•
South Warwickshire Local Plan Issues and Options consultation in March 2023.
The site comprises approximately 95 hectares (ha). CEG control approximately 83 ha of the existing JLR allocation, around 5ha of the existing AML safeguard allocation and a further 6ha when the triangular parcel south is included. The site is located off Junction 12 of the M40 and is considered to be an appropriate location for a major employment development. As demonstrated on the supporting Zoning Masterplan, the site has the potential to deliver a wide range of commercial floorspace, including large strategic warehouses, medium to large units, medium size local business park, small enterprise park and ancillary amenities.
As set out these representations, CEG are pleased to see that the existing JLR allocation has been identified for employment by Draft Policy Direction 12. CEG are also pleased to see reference within Draft Policy Direction 14 that the existing AML allocation in the adopted SDC Core Strategy is earmarked for retention, albeit CEG believe it would be logical to lift the occupier specific restriction on this for consistency and flexibility. Both these sites, which form part of site SG13 should be allocated accordingly within the Local Plan.
CEG do however consider that the triangular parcel south of the B4100 should also be included within this employment location and also within SG13. There is significant demand and immediate need for B2 and B8 floorspace within South Warwickshire and the potential development of the site in terms of scale and location, will help to meet this demand as well as supporting the 3,000 dwelling Upper Lighthorne community, improving sustainability within the area by providing a range of local employment opportunities. Development of the site will build on both the strengths of the existing automotive cluster in the District related to Jaguar Land Rover and Aston Martin Lagonda by providing flexible space for related activities and business start-ups (Class E(g)(ii & iii) and B2
uses) whilst also providing space for B8 logistics required by both the automotive manufacturers and additional supply chain business’, helping to realise the economic potential of the M40 corridor.
These representations are made specifically in the context of CEG’s interest in land identified by the Plan as SG13 which is listed in Chapter 4 of the SWLP as a Strategic Growth Location and is therefore considered within the Interim Sustainability Appraisal supporting the SWLP Preferred Options Consultation and also the triangular parcel south of the B4100 which is currently not within SG13. Therefore this representation focuses on matters that are relevant to the spatial strategy of the Plan and the options proposed for the future growth of South Warwickshire.
The representations follow the structure of the Regulation 18 Preferred Options consultation document, providing responses under the topics and questions identified, as relevant.

Yes

ID sylw: 108018

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG supports the Plan’s Vision and objectives, which determine how development will be delivered. CEG’s proposals for the JLR allocation are considered against each of these principles to demonstrate how the site’s development can help to achieve the vision.
A climate resilient and Net Zero Carbon South Warwickshire – The proposed development at the site could contribute to a low carbon and climate resilient development from construction to occupation through sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems within a comprehensive blue-green infrastructure network and mobility strategy.
Moreover, the site is situated in a sustainable location being strategically placed next to the new settlement Lighthorne Heath, Jaguar Land Rover (JLR) and Aston Martin Lagonda (AML). Furthermore, the site provides the opportunity to introduce an integrated transport network. This will influence and change travel behaviour of commuters to and from the site and neighbouring sites such as that of JLR, and to benefit from new and existing residents in the vicinity of the site i.e., within Gaydon and Lighthorne Heath.
To summarise, the site can improve existing infrastructure and generally promote a culture of change towards active travel which in turn aids the climate resilience of South Warwickshire.
A well-designed and beautiful South Warwickshire – Development at the site, will provide a mix of commercial units all designed to the highest standard. Moreover, proposals would look to incorporate the existing woodland buffer in the north west part of the site and also provide substantial landscape areas, enhancing visual and physical connections.
A healthy, safe and inclusive South Warwickshire – The site provides the opportunity to incorporate the existing woodland buffer and could make this accessible which will provide health and wellbeing benefits through the provision of more recreational space for the surrounding area including the residents of Gaydon and employees of the surrounding employment. This will help to foster a cohesive working environment which will support health and wellbeing.
A well-connected South Warwickshire - The site is located in an inherently sustainable location for commercial development. The M40 provides a direct route to Banbury to the south-east and Warwick to the north-west. Banbury benefits from a railway station as does Warwick. There are two bus stops along the B4100 adjacent to the Site that provide services to Temple Herdewyke, Avon Dassett, Leamington Spa, Milverton and Banbury Town Centre.
The site will take advantage of the existing facilities for travel choice into Stratford-upon-Avon by active travel and public transport modes and enhance these routes where needed through careful design and investment in
sustainable infrastructure which will promote longevity. This means that the site can place walking and cycling at the highest priority, followed by travel by public transport, and develop a community where there is “little” reliance on the private car.
A biodiverse and environmentally resilient South Warwickshire – Biodiversity net gain will be incorporated into the proposals for the site. The conceptual framework for the site will feature and cohesive ecological network that retains existing landscape features including hedgerows and tree belts and, in addition, shows a considerable biodiversity parkland, public parkland, and a network of swales.
SWLP Strategic Objectives
The Plan includes 12 strategic objectives which reflect the area’s social, environmental and economic issues. Where relevant, CEG provide comment below on how development at the JLR allocation and SG13 can help to meet the Plan’s objectives:
SO1: Providing sustainable levels of growth in the area
The Core Strategy recognises the importance of the area, specifically stating that:
“The Gaydon Site is a key economic asset within the District and the wider region, employing several thousand people, together with indirect employment in relation to logistics and suppliers. The site is located adjacent to an established highway network, including the M40 which is an important transport gateway into Coventry and Warwickshire.”
The importance of this location is further reflected in both the emerging SWLP and the December 2023 and South Warwickshire Economic Strategy. The SWLP Preferred Options document identifies the Gaydon Area/M40 Junction 12 as a Major Investment Site which sits within a wider ‘Economic Core Opportunity Area’. This area includes Gaydon and the M40 corridor and comprises the main towns of Stratford-upon-Avon, Warwick, Whitnash, Leamington Spa and Kenilworth, the A46 corridor, the University of Warwick’s two campuses, Long Marston Garden Village and Rail Innovation Centre and Stoneleigh Park.
Draft Policy Direction 13 of the SWLP also confirms the area will be the focus for new employment development in the South Warwickshire Area, building on existing employment hubs, harnessing the potential offered by co-locating businesses and research facilities and support the strategy for attracting significant inward investment to the area. The South Warwickshire Economic Strategy identifies the same area as ‘Core Investment Opportunity Area’. The focus for the area is attracting inward investment to drive the South Warwickshire economy as well as encouraging inward investment in the most accessible parts of South Warwickshire. Indeed, the emerging South Warwickshire Economic Strategy confirms this area is likely to provide “the focus for attracting strategically significant inward investment to drive forward the South Warwickshire economy, whilst acknowledging national and local planning policies (e.g. Green Belt)”.
The SWLP preferred options also identifies the M40/A46 corridor as a Road Opportunity Area based on the West Midlands Strategic Employment Sites Study (WMSESS) which recommends the identification of 1-2 mixed/B8 sites (50-100ha each) and 1 B2 site (25ha) to deliver 125 ha of strategic employment i.e. sites of over 25 ha and largely dedicated to units of over 9,300sqm. This clearly recognises the potential of this corridor to play an enhanced role in delivering strategic economic growth in South Warwickshire.
SG13 is located close to the principal design and engineering centre for Jaguar Land Rover (JLR) and Aston Martin Lagonda (AML). Within SG13 is 100ha of land specifically allocated for the expansion JLR and 5ha of land for the expansion of AML in the Stratford-on-Avon Core Strategy under Policy CS.22 and policy GLH (Gaydon/Lighthorne Heath now known as “Upper Lighthorne Heath”).
To the north-east, beyond the existing JLR/AML sites, is Lighthorne Heath, a historically small village built to originally support RAF Gaydon which now comprises a mixture of private and social housing together with a 3000 dwelling new settlement.
731 homes are now occupied within the new settlement (December 2024) and therefore with a community quickly becoming established. Indeed, completions are taking place at a pace beyond that envisaged within the Core Strategy. This strong delivery accelerates the need to provide a wider range of jobs within the immediate locality to support the sustainable growth of the area.
The Core Strategy recognises the eventual sustainability and significance of Lighthorne Heath through the supporting text to policy CS.15, which confirms that;
“In terms of the settlement pattern across the District, the new settlements will become the equivalents of a Main Rural Centre and complement their role.”
The settlement hierarchy for Stratford-on-Avon District clearly recognises the transformative nature of this new settlement to the local area. It is therefore considered that given the existing and anticipated future rate of completions and the services and facilities now being delivered on the at the allocation, Lighthorne Heath should be considered as a Main Rural Centre within the settlement hierarchy, alongside Alcester, Bidford-on-Avon, Henley-in-Arden, Kineton, Shipston-on-Stour, Southam, Studley and Wellesbourne.
AML’s headquarters within Gaydon provide the main production facility together with research and development. Further to Aston Martin Lagonda’s presence, JLR operate their advanced design and engineering centre at Gaydon. The design and research centre and extensive test track facilities have been established over the last 30 years
The Site is therefore strategically positioned to drive significant inward investment within this ‘Core Economic Area’, supporting the automotive cluster whilst also increasing the provision of jobs, complimenting the role of Upper Lighthorne in the settlement hierarchy.
SO3: Providing infrastructure in the right place at the right time & S011: Connecting people to places
Significant investment has been made to highway infrastructure around J12 of the M40. Development at Junction 12 is there an appropriate location for employment development to come forward now as there is existing capacity on the highway network and delivery is not reliant on significant upgrades to the Junction. The SWLP recognises that significant upgrades would be required to facilitate the strategic employment growth options identified at Junction 13 (Land at Red House Farm) and 15 (Wedgnock Park Farm). This is not the case at J12 where the only major new investment in the medium / long term would be a new northern slip road onto the M40 that can be delivered on land within the full control of CEG and National Highways.
Proposals for the site could include a viable integrated transport network. Based on experience of large employment sites, these upgrades to existing transport connections are usually well received as they provide benefits over fixed time, fixed route buses in terms of convenience and linking bus journeys to specific destinations.
An improved service will have wider benefits beyond the proposed development itself in terms of providing additional public transport opportunities that are arguably more convenient than fixed route / fixed time buses, for a wider population in this area of Warwickshire. Transport initiatives are much more viable within the context of a concentrated critical mass of employment such as at Junction 12, Gaydon.
SO4: Developing opportunities for jobs
The site would generate significant local employment of significant benefit to the local economy. The jobs created would make a significant contribution to the Stratford-on-Avon economy, provide a number of employment opportunities and help the economy to diversify. Securing these employment opportunities is critical, particularly following the impacts of the Covid-19 pandemic. Indeed, Stratford-on-Avon District Council have suggested that the District has been the fourth most adversely affected authority from COVID. The jobs created as a result will help the economy to recover. It should also be stated that the Government, since being elected in July 2024, have placed an important new emphasis on growth and economic development with this being their number 1 mission for the next parliamentary term.
It is evident from the HEDNA that there has been a shortfall in the supply of B8 floorspace within the District. The provision of further flexible space that is capable of providing space for storage and distribution (B8 use) alongside General Industrial (B2) will help to provide jobs that will help to diversify and strengthen the local economy.
At a national level the logistics sector has played an important role in providing jobs and underpinning economic growth, it has seen job growth at a higher rate than across the economy as a whole. Furthermore, as technological advancements have continued there has been a greater focus on the use of innovative, cutting-edge technology which has resulted in considerably higher skilled jobs than may have been the case previously. This has been confirmed through the Department for Transport “Future of Freight” report published in June 2022 which states:
“Since 2010, the number of jobs in transport and storage has grown by 26% compared to only 14% across the whole economy. There is increasing sophistication of roles in the sector with Professional and Associate Professional and Technical roles increasing by 331,000 since 2010. Meanwhile in 2021, the number of UK businesses classified as transport and storage was 88% higher than in 2011, with fastest growth in the Midlands, East of England, Yorkshire and The Humber”
Further to the above, in terms of skills, The British Property Federation’s (BPF) “Levelling up - The Logic of Logistics” report published in 2022 reports substantial growth in technical and professional roles (+331,000) in the sector over the last decade.
In terms of B8 uses, examples of the type of jobs that will be provided on Site are set out below which are in addition to the jobs associated with class B2 and class e (g) (ii) and (iii):
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Supply chain design and planning;
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Procurement and supply management;
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Warehouse design and management;
•
Distribution network design and management; and
•
Inventory management and control.
The importance of logistics to the automotive sector should not be understated. The automotive industry heavily relies on automotive logistics to manage the complex supply chain involved in the production and delivery of vehicles. In this regard, they are considered synonymous and provision of B8 in this location would support existing sectors, particularly the automotive cluster at Gaydon which is identified as a core opportunity sector within the SWES.
SO8: Protecting and enhancing our heritage and cultural assets and SO12: Protecting and enhancing our environmental assets
The SWLP ensures that appropriate environmental considerations have been made when considering and assessing the options to accommodate future development. The site can also be delivered without causing significant impact on environmental assets. There are no ecologically important sites within or adjacent to the site, it lies entirely within Flood Zone 1; although there is a small area of the site to the north which is susceptible to surface water flooding. This can be satisfactorily mitigated through design, layout and specific drainage design. Development can be delivered to secure the mandatory levels of biodiversity net gain (BNG), and mitigation for any protected species, should any be discovered, can be secured in any future planning application.