Yes

ID sylw: 108020

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”.
SG13 is considered to the most appropriate location for economic growth in the short, medium and long term by concentrating commercial investment in an area that requires minimal infrastructure investment. Both the 100ha JLR site, which is expected to be released to the wider market, and CEG’s site east of Gaydon (30ha) (also part of SG13) have the capacity to meet the Council’s strategic employment need in full. However, CEG also request that the triangular parcel of land south of the B4100 is also included SG13.
The accompanying zoning masterplan demonstrates how sites within SG13 can come forward for a mix of employment uses that can satisfy the need identified within the Alignment Paper. For reasons set out below, SG13 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 (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 and in particular CEG’s land interests 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.
Land within CEG’s control has the capacity to deliver circa 125 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 Junction 15 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 both junctions 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 Junction 14, the grounds of which are also within the boundary of the Warwick Conservation Area. Areas of land to the west and south of Junction 14 and east of Junction 15 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, SG13 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.
SG13 (Gaydon Lighthorne Heath) is considered as a mixed use site across 836 hectares. CEG controls around 130 ha of SG13 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 (including SG13) have been identified as potential locations for employment growth, the others being SG07 and SG09.
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 SG13 which lies entirely outside of the Green Belt.
In considering the scoring of SG13 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 SG13 contains the JLR allocation of a 100ha which has been identified within the SWLP as an employment site and Land East of Gaydon which is approximately 30ha and capable of providing up to 80,000sqm, 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. Development can be designed with the appropriate buffers in place.

No

ID sylw: 108021

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 highways capacity at this site 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 on the basis that it is released to the wider market. It is important to draw to your attention the response of JLR to the South Warwickshire Issues and Options (reference
78209) who confirmed that they still require additional space in this location and would only be willing to remove the user-specific nature of the allocation if further land within their control was allocated through the SWLP.
Furthermore, the inclusion of a restriction on B8 unit size should be removed. There is strong evidence that larger B8 units are essential to support the manufacturing sector, and specifically the automotive supply chain, and such a policy restriction would therefore suppress appropriate investment and economic benefits. A restriction on use will impact upon delivery/take up rates as the B2 sector historically makes up only 20-30% of total demand and the inclusion of the proposed restriction as drafted therefore risks the ability for this site to be delivered within the first 5-10 years. This is particularly important as alternative sites cannot accommodate this easily, as outlined previously. A more appropriate policy position would be that a mixture of unit sizes should be provided on the site to meet market demand.
Furthermore, it is considered that the triangular parcel south of the identified employment site boundary should also be included within the allocation, being suitable for a range of uses. It is strategically placed and capable of accommodating small scale development with appropriate buffers to Gaydon. The SWLP through Draft Policy Direction 19 acknowledges the issue of providing affordable residential units at an appropriate scale. It is considered that this specific part of the site can assist in meeting this identified need and therefore should be allocated and included as part of this employment location. Date
07-03

Yes

ID sylw: 108022

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG support Draft Policy Direction 13. The JLR 100ha site is located 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. In this context, CEG consider even more important that the B8 unit size restriction should be removed.

Other

ID sylw: 108023

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG support the suggested retention of the allocation of land to the north/rear of the AML’s HQ to enable small scale expansion of their existing facility.
CEG are also pleased to see that the Gaydon Area/M40 Junction 12 has been identified as a Major Investment Site and support its inclusion. However, CEG do have serious concerns about restricting the uses that could be accommodated on site. The subtext for the Draft Policy Direction states that “Whilst well-located to the M40, this location is not seen as appropriate for strategic logistic uses (i.e. Use Class B8).” This statement in itself is considered contradictory and fails to take into consideration market demand and the importance of logistics on manufacturing, in particular the automotive sector.
It is also considered that restrictions proposed are counter to that of paragraph 86 b) of the National Planning Policy Framework (NPPF) which states that planning policies should “pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics”
Furthermore, paragraph 87 of the NPPF is clear that planning policies and decisions should recognise and address the specific locational requirements of different sectors. In particular provisions should be made for storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially where this is needed to support the supply chain, transport innovation and decarbonisation. Junction 12 by virtue of its location is considered an appropriate location for strategic B8 use.
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.
In view of the above, it is considered that the strategic B8 restriction should be removed from Policy Direction 14.

Other

ID sylw: 108025

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG Land Promotion (UK) Limited (hereafter “CEG”) and Dr D Brightman, control land at Junction 12 of the M40, Gaydon (“the site”). The site has been previously promoted and submitted to the Call for Sites exercise and is known as Site 380. 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 29.5 hectares and is located off Junction 12 of the M40. The site is considered to be an appropriate location for a major employment development. The site is currently subject to a hybrid planning application (ref: 23/01054/OUT) for up to 79,841 sqm of commercial floorspace submitted to Stratford-on-Avon District Council. This is a flexible proposal, comprising B2, B8 and class E(g)(ii & iii) use classes. As set out in 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 development proposed under application 23/01054/OUT (‘the J12 Proposals’), 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’s interest in land identified by the draft 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. 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. These representations make reference to the documentation submitted in support of the planning application in order to demonstrate the suitability of SG13 for commercial/employment generating development.
Accompanying this representation are the following plans:
•
Illustrative Masterplan;
•
Illustrative Site Context Plan; and
•
Illustrative Landscape Masterplan.
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: 108038

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 Gaydon 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 J12 Proposals will 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. As set out within the Sustainability Statement that accompanied the planning application, development of the site will seek to ensure:
•
Buildings will be designed to reduce carbon emissions in accordance with anticipated changes to the Building Regulations through the use of energy hierarchy, using a fabric first approach to design to reduce energy demand, helping mitigate the effects of climate change;
•
The development will achieve a minimum BREEAM standard of 'Very Good', and exceed this where viable; and
•
Buildings designed to take into account increasing annual temperatures set out in the UKCP18 climate projections to minimise the risk of overheating.
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, as evidenced by the planning application documentation, could provide a mix of commercial units all designed to the highest standard. Moreover, the J12 Proposals could include a publicly accessible parkland and 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 an accessible parkland 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.
A biodiverse and environmentally resilient South Warwickshire – As demonstrated through the planning application for the site, a 10% Biodiversity net gain can be achieved on site. The accompanying illustrative landscape masterplan for the site will retain 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 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.
SG13 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 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 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.
The application for the J12 Proposals sets out that the proposed development will introduce an integrated transport network including the provision of DRT, which would be funded through Section 106 contributions. Whilst this is specific for the planning application it demonstrates that commercial development in this location can support innovative sustainable transportation initiatives.
DRT can provide a modern, user-orientated form of public transport, with flexible routing, pick-up and drop-off locations, and timetabling matched to passenger needs. DRT is typically app based and can provide a convenient, flexible service. DRT vehicles are typically executive minibus services with air conditioning, WiFi, and table seats within a wide area, providing timely and convenient services connecting the site to local employment areas and public transport hubs.
Based on experience of large employment sites, DRT proposals 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. For example, DRT works well with shift patterns starting / finishing at unsociable hours of the day when traditional
public transport services would be infrequent as in the case with this site. DRT would provide future employees with an alternative transport option in the region compared to the fixed time, fixed route buses and has the potential for wider benefits locally with DRT schemes typically operating within a 15-20 km radius.
A DRT 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. DRT is also well suited to shift patterns specifically related to the proposed development. The site masterplan includes an area for a bus to turn within the site and this provides a central pickup location without any blocking of the internal roads. Developer funding is proposed to support the operation of the DRT service. Transport initiatives such as DRT 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. Economic modelling undertaken in support of the planning application for the J12 Proposals has confirmed that the development of the site could generate in the region of 1,786 full-time equivalent (FTE) jobs on site. The approximate operational economic output (GVA) is estimated at £394 million. This 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 of the Proposed Development 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 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.
It is anticipated that the site will provide approximately 1,786 direct full-time equivalent jobs based on the use classes proposed in the submitted planning application. 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;
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Distribution network design and management; and
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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.