No

ID sylw: 101578

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes Ltd

Asiant : Stansgate Planning

The document does not conform to national planning policy and must be redrafted to reflect the latest National Planning Policy Framework version.

Draft Policy 1 must confirm the key priorities of the SWLP as required by the Framework - to significantly boost the supply of homes in a sustainable manner, and provide sufficient employment land to meet the Districts’ needs. It must NOT set maximum provision figures. These would unnecessarily restrict the ability of the area to meet the key aims.

For housing provision, references to the 2022 HEDNA should be removed. The policy should set out the minimum number of homes needed assessed using the Standard Method (see NPPF paragraph 62). Adequate flexibility must be incorporated for changing circumstances, and to accommodate housing needs arising from beyond the Districts’ boundaries.

We support meeting much of the housing requirement though new settlements and significant extensions to existing settlements. Particular attention should be given to accommodating development in locations already supported by necessary infrastructure and facilities, and those where they can be provided. In accordance with NPPF paragraph 22 the plan period should be extended from 25 years to at least 30 years, and housing and employment requirements increased accordingly.

No

ID sylw: 101585

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes Ltd

Asiant : Stansgate Planning

The National Planning Policy Framework states, at paragraph 11b), that strategic policies should provide for the objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas. This need for cross boundary provision is reiterated in Framework paragraph 36 a). As drafted, Policy Direction 4 does not go far enough towards meeting the needs of the Greater Birmingham and Coventry areas. Some cross boundary requirements are already acknowledged yet the SWLP does not currently propose to make any allocations to meet those needs from the outset and should be amended to do so, reflecting the latest information available.

That notwithstanding it remains appropriate for the SWLP to allocate additional sites which can be released if there is a shortfall against the Districts’ own requirements or needs arising from adjacent areas. A policy of reserve sites must be clearly set out in the SWLP and not left to a separate document, to be adopted at a later date.

No

ID sylw: 101593

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes 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: 101600

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes Ltd

Asiant : Stansgate Planning

The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006 Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of knowledge of the industry it seems highly unlikely such justification could be provided. The policy proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as to how any such policy could be implemented – particularly in respect of viability, without undue pressure on applicants to undertake lengthy and complicated viability assessments

No

ID sylw: 101608

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes 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: 101618

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes 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 the uncertainty could delay the deliverability of sites. Sites with many existing trees (and canopies) will be treated different to sites with few or no trees. Sites with native trees will be treated differently to sites with non-native trees. More tree canopy is not necessarily beneficial or necessary. More overshading could harm residential amenity. This Policy Direction should be deleted from the Plan.

Other

ID sylw: 101625

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes 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: 101638

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes 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: 101647

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes Ltd

Asiant : Stansgate Planning

Inclusion of SG17 and specifically site 507 is supported. The location is highly-sustainable and well-connected. The scores for Greenfield Land and Land Quality are common to most sites. Applying planning judgement to scores for SW Flooding, Landscape Sensitivity, Connectivity and Access to Local Services shows it is extremely well-located.

The site should be scored 0 for surface water flooding. The 4% subject to surface water flooding could be used for public open space or biodiversity. This is not significant to the whole site's development potential so the weighting is excessive.

The site should be scored 0 for landscape sensitivity. A Landscape Summary Note has been prepared showing a landscape-led approach could assimilate the site into its local setting.

The Connectivity Grade (D) is misleading. Access to Darlingscote Rd and Tileman’s Lane is convenient for town centre access, and settlements north and south can be accessed to the west via the A429. There is access to the town centre and out of town employment and services destinations. This is superior to sites south of Shipston with a higher need to travel through the town. The edge-of-town location is well-located for drivers; it is alsoy well-connected by public transport and pedestrian routes.

The nearest existing bus stops are on Tilemans Lane approximately 370m from the centre of the site. The eastbound stop is served by bus services 50, 51 and 75A. The westbound stop is served by bus services 51, 75A and 75C. The nearest railway station is in Moreton-in-Marsh, approximately 11km south of the site on existing roads and footways. This provides services to Worcester Shrub Hill and Oxford. The number 51 bus service from Stratford-upon-Avon stops adjacent to Moreton-in-Marsh Station enabling access to numerous destinations without car usage. Stratford-upon-Avon Railway Station is approximately 18km north of the site. This provides services to Solihull and Birmingham. National Cycle Route (NCR) 5 is located south of the site on Darlingscote Road and routes northwest towards Birmingham and east to Banbury. In Shipston-on-Stour the route is traffic free. To the east of Shipton-on-Stour NCR 5 connects to NCR 48 on Fell Mill Lane. NCR 48 is open in section and routes north towards Southam and south to Moreton-in-Marsh. The score for connectivity should be 0.

The site is connected to a variety of existing local amenities and facilities less than 2km from the site, including bus stops, primary and secondary schools, a nursery, doctors surgery, pharmacy, food retail, post office, library, leisure facility, and Shipston Business Village.

The site is located within the geographic middle super output area (MSOA) of Stratford-upon-Avon 015. The modal split for this area is summarised below:

Train 2%
Bus, Minibus or Coach 2%
Taxi 0%
Motorcycle, Scooter or Moped 0%
Driving a Car or Van 77%
Passenger in a Car or Van 5%
Bicycle 1%
On Foot 11%
Other Method of Travel to Work 1%

Shipston, Stratford-upon Avon, Warwick and JLR at Gaydon all offer vast employment areas covering all sectors which can be readily accessed by cycling, bus or car.

Residential development would likely increase demand for education with resulting trips to access local schools. These will overlap with the network AM peak hour. As shown by the 2023 National Travel Survey, pupils are over three times more likely to travel to primary school by car if their journey is 1.6 to 3.2 km compared to those whose journey is under 1.6 km. Nationally, the average journey length for education trip purpose is 3.0 km. A similar relationship is apparent for secondary school pupils although they are more likely to take the bus than be driven for long journey lengths.

The nearest primary school is Shipston Primary School, approximately 520m away on Station Road. The door-to-door walking distance is well within the national average. The nearest secondary school is Shipston High School which is located approximately 830m away on Tudor Road. The distance to the secondary school is within the national average. A large proportion of primary and secondary pupils are therefore likely to walk.

The Shipston Town Centre is approximately 1km south, with numerous shops offering a range of goods. There is a Co-operative Food, Morrisons Daily, Tesco Express and Shipton-on-Stour Post Office in the town centre.

Shipston Medical Centre is approximately 700m southeast on Donnington Road. The nearest pharmacy is Pharmacy To My Door, approximately 650m south of the site. Boots Pharmacy is located in the town centre. The score for Healthcare should be 0.

A Preliminary Ecological Appraisal has been prepared which establishes the existing ecological and biodiversity value on the site and indicates the proposal is unlikely to have significant effects on priority habitats. The PEA concludes any protected species habitats will be of site level importance only. The existence of, and potential impacts on species habitats will be assessed through further survey work when the season commences. The Baseline Habitat Value score should be 0.

An Agricultural Land Quality Assessment is being carried out and will be submitted before the end of March 2025, to confirm that this relatively small land parcel does not fall within land considered to be Best and Most Versatile. The score for Agricultural Land Quality should be 0.