No

ID sylw: 101300

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Draft Policy 1 must be redrafted to reflect the amended NPPF, and confirm the key NPPF priorities of significantly boosting housing supply in a sustainable manner and providing sufficient employment land to meet District needs. Maximum provision figures unnecessarily restrict capacity to meet these key aims and shouldn't be included. All references to the 2022 HEDNA should be removed and a minimum housing need assessed in accordance with the Standard Method as per NPPF Paragraph 62, with sufficient flexibility to meet changing circumstances and housing needs arising beyond the Districts' boundaries.

New settlements and significant extensions to existing settlements are appropriate ways to meet housing needs. Development should be accommodated in locations which already have necessary infrastructure and facilities and areas where they can be provided. The plan period should be extended to at least 30 years as per NPPF Paragraph 22 and requirements for housing and employment increased accordingly

No

ID sylw: 101306

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

This policy does not go far enough towards meeting the needs of the Greater Birmingham and Coventry Areas and the requirements of NPPF paragraphs 11b) and 36a). There should be allocations to meet those needs included from the outset, based on the latest available information. The SWLP should also allocate additional sites which can be released in case of shortfall against the Districts' own requirements or needs from adjacent areas. This must be set out in the SWLP and not a separate document to be adopted later.

No

ID sylw: 101316

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

While the policy’s reference to the 20-minute neighbourhood concept aligns with the NPPF’s sustainable travel aims, the NPPF does not mention this approach, and its application within South Warwickshire needs further consideration. The SWLP technical evidence “Guide to existing housing densities in South Warwickshire” defines a 20-minute neighbourhood as achieving access to everyday services within a 10-minute walk or cycle each way. These aims are unrealistic for larger strategic residential developments located adjacent to larger settlements, as well as developments within smaller settlements, where infrastructure constraints and service provision limitations make such proximity difficult to achieve.

Greater flexibility should be applied to acknowledge the challenges of implementing the 20-minute neighbourhoods’ model in areas where everyday services are not available within such a short distance.

No

ID sylw: 101328

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Meeting the statutory 10% BNG requirement is challenging and causes delays and viability concerns to many developments but is unavoidable as a national validation requirement. Draft
Policy Direction 38 indicates the Councils will explore evidence to adopt a higher percentage to achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.

NPPF Paragraph 006 states that a higher figure can only be adopted if their is evidence of local need and local opportunities for a higher percentage and assessment of impacts on viability. Based on knowledge of the industry it's highly unlikely such justification could be provided. This proposal should therefore be dropped. If progressed there will need to be detailed consideration on how it could be implemented without undue pressure on applicants to undertake lengthy and complicated viability assessments.

No

ID sylw: 101332

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to and enhance the natural and local environment there is currently no requirement, or indeed reference, to Environmental Net Gain at a national level.

The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any information about how such a policy would function in practice. There are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty could delay the deliverability of sites. As such this policy direction should be removed from the emerging Plan

No

ID sylw: 101335

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

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

Other

ID sylw: 101341

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Additional Special Landscape Areas should only be designated, and existing SLAs retained, if there is sufficient evidence to justify why normal landscape policies are inadequate.

Yes

ID sylw: 101357

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Shipston on Stour is an important centre for the surrounding villages with good linkages to larger towns. It is recognised as having a wide hinterland and continued growth will support and reinforce its sustainability by supporting local services and businesses.

Yes

ID sylw: 101367

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

INTRODUCTION
Yes
1.1 The inclusion of SG17 and specifically site 465 is supported. This site is in a highly sustainable and well-connected location.
1.2 The score for Viability and Deliverability is considered to be incorrect; the score for Employment Land is illogical and should be deleted. The scores for Greenfield Land and Land Quality are common to most sites, whilst applying planning judgements to the scores for SW Flooding, Landscape Sensitivity, Connectivity and Access to Local Services will show that it is extremely well located, particularly when compared to other sites, and should be supported.