No

ID sylw: 101261

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : Marrons

The principle of Draft Chapter 11 is supported, although the current draft policy directions are at this moment vague, and specific issues are raised with Draft Policy Directions as set out above.

Yes

ID sylw: 101266

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : Marrons

Mac Mic suggest a number of changes in the wording of the definitions offered by the Glossary.

Yes

ID sylw: 101414

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : Marrons

The Site [RefID 169] is the most accessible side of the village to the rail station (unlike 53 and 761), is well contained without long distances views (unlike 514 & 649) and does not make a contribution to Green Belt purposes (unlike 88 & 205), does extend the village envelope north beyond Rising Lane (unlike 235).

Yes

ID sylw: 106610

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

We support the identified Strategic Objectives at Section 3.2 of the PO Consultation.
In particular, we support the identification of the delivery of homes to meet community needs at Strategic Objective 2. It is abundantly clear that housing delivery is of upmost importance to the Government, with the Deputy Prime Minister pointing to our being “in the middle of the most acute housing crisis in living memory”.

Other

ID sylw: 106614

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

As we set out in further detail at Section 3 of these Representations, we do not agree that all of the identified Strategic Growth Locations are supported by sufficient
infrastructure to enable their delivery. It is clear that the SWLP recognises at a high level that such provision is integral to the delivery of significant housing and employment sites.
It is noted as part of the consultation that an Infrastructure Delivery Plan (IDP) is being prepared alongside the Local Plan to help identify future infrastructure requirements,
costs and when and how infrastructure will be delivered. Part 1 of the IDP forms part of the technical evidence base for the PO Consultation draft of the SWLP.
Whilst we appreciate that further work is to be undertaken to determine details of the infrastructure needs for the preferred option, we are concerned at the lack of information contained within the Part 1 IDP. In our view, evidence regarding infrastructure requirements for the strategic growth areas or potential new settlements is a fundamental requirement for their promotion. Linked to this, we consider it a significant failing of the emerging Plan to prioritise or highlight areas which suffer from a lack of infrastructure, or conversely those areas which benefit from existing infrastructure.

Whilst we broadly support the identification of Priority Areas, we do not agree with the specific delineation of Priority Area boundaries insofar as they relate to Henley-in-Arden. Specifically, the draft SWLP does not evidence or justify the identification of land to the north of Henley-in-Arden, but outside of the existing urban area, as falling within Priority Area 1, while land to the south falls within Priority Area 2 / 3. It is apparent that the boundary of Priority Area 1 has been tightly drawn to reflect existing built development in the southern part of Henley-in-Arden but extends beyond existing built development to the north. The justification for this is not clear and we would argue that this amounts to an artificial manipulation of the boundary of the Priority Area, with the effect of rendering a greater proportion of parcels of land to the north of Henley-in-Arden which have been promoted for development and which are identified as falling with ‘SG23’ (as discussed in more detail later) as falling within the area.
We fully support the recognition set out above that the existing urban areas across South Warwickshire do not offer sufficient capacity to meet development needs. This reflects Government rhetoric that whilst the first port of call for development should be brownfield land, it is clear that the delivery of brownfield land for residential development will not be enough to meet our housing needs. In our view, it is critical that the SWLP makes clear at the outset that development will need to extend beyond existing urban limits.
This is further evidenced by the 2022 Urban Capacity Study, which sets out at Section 4.6 that greenfield land must be released to meet South Warwickshire’s housing needs and that “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development” (our emphasis). In short, it is in our view essential that the SWLP is clear from the outset that the only way to meet development needs will be to build on current greenfield sites including the Green Belt, in sustainable locations.
Figure 6 goes on to identify the Emerging Spatial Growth Strategy Options, comprising Strategic Growth Locations (24 no. in total) and Potential New Settlements (12 no. in total). Land to the north of Henley-in-Arden is identified as comprising Strategic Growth Location SG23. As set out in further detail later within these Representations(Section 3), we do not support the identification of land to the north of Henley-in-Arden as a Strategic Growth Location, particularly when the benefits and disbenefits of its allocation are weighed against those of land to the south of Henley-in-Arden. We also have concerns in respect of the identification of Potential New Settlements A1 and A2 to the north west of Henley-in-Arden.

Other

ID sylw: 106617

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

Section 4.1 of the PO Consultation Document sets out that “Sustainable Travel and Economy”, previously identified as Option 4 within the I&O Consultation, is identified as the chosen Spatial Growth Strategy for the SWLP.
The Respondent supports in particular the emphasis given to sustainable travel and to the provision of development in proximity to existing rail stations. Given the emphasis on mitigating the impacts of climate change (as per the first overarching principle set out within Section 3.1) and reducing the need to travel by private car in order to reduce carbon emissions, it is the Respondent’s view that in existing settlements in close proximity to existing railway stations – such as Henley-in-Arden – should be prioritised as locations for growth. More specifically, the Respondent’s Site at Henley-in-Arden is an ideal candidate for future housing development in this regard given it location within walking distance of Henley-in-Arden railway station.
The December 2024 iteration of the National Planning Policy Framework is clear at Paragraph 234 of Annex 1: Implementation that “for the purpose of preparing local plans, the policies in this version of the Framework will apply from 12 March 2025”. There are some exceptions, none of which apply to the SWLP. On this basis, it is fundamental that the SWLP sets out housing need in line with the new Standard Method.
As per the new Standard Method, housing need has increased in Stratford-on-Avon from 553 units per annum to 1,126 units per annum (+103%) and in Warwick DC from 653 units per annum to 1,062 units per annum (+62.6%). This significant increase in housing need further heightens the importance of the Council looking to suitable and sustainable greenfield sites to deliver housing, given the acceptance that urban land could not meet even the lower demand, which was assessed in 2022, as per the Urban Capacity Study.

Other

ID sylw: 106618

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

Table 3 (Housing calculation 2024 NPPF standard method) identifies a total housing need across the plan period of 54,700 for South Warwickshire, with assumed windfall allowance across the plan period contributing 9,375 to this figure, or 17.1% of the total need.
Such an overreliance on windfall provision is not justified and would render the SWLP unsound. This is a point explored in the recent Shropshire Local Plan examination, where the reliance on windfall sites was lower. Paragraph 15 of the NPPF requires the planning system to be ‘genuinely plan-led’. Leaving almost one quarter of housing land supply to chance is not plan-led. As such, additional allocations are required to respond to housing need.

Yes

ID sylw: 106619

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

The Respondent is generally supportive of the inclusion of new settlements as a potential growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery.
The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy.
Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period.
Given that only four of the identified potential new settlements are considered to be suitable, we consider it of fundamental importance that sustainable extension sites to existing urban settlements are prioritised over the development of new settlements. In short, we are of the view that the growth of existing settlements should be prioritised within the overall growth strategy for South Warwickshire, as opposed to the delivery of new settlements.

Yes

ID sylw: 106620

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

We fully support the need for the SWLP to contribute to meeting unmet housing need from neighbouring authorities. In our view, sustainable sites in the north west of the SWLP area, including the Site to the south of Henley-in-Arden, are likely to be very well placed to respond to such need, particularly where those sites are located in close proximity to key transport nodes.

Yes

ID sylw: 106622

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

As set out previously within these Representations, it is in our view imperative that the SWLP deals head on with the fact that the release of existing Green Belt land will be required to meet development needs over the Plan period. Such a case is not made clearly at section 4.9, and we strongly recommend that this is remedied in the forthcoming Regulation 19 Consultation draft of the Plan.
We support the recognition at Section 4.9 that “Some of South Warwickshire’s most sustainable locations fall within the Green Belt. For example, all of our train stations are either in or close to the Green Belt. This means that in order to deliver a truly sustainable pattern of growth, the SWLP needs to consider all options, including Green Belt options”. This was a point made in our previous representations and reflects the direction of travel contained within Government rhetoric regarding Green Belt land including the statement from the Deputy Prime Minister that: “a Green Belt designed for England in the middle of the twentieth century now must be updated for an England in the middle of the twenty first. The Green Belt today accounts for more land in England than land that is developed – around 13% compared to 10%. Yet as many assessments show, large areas of the Green Belt have little ecological value and are inaccessible to the public”