Yes

ID sylw: 101602

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

Lovell supports the decision to bring forward a new Local Plan. Significant planning legislative changes have occurred since the two authorities adopted their current Local Plans, which predate the aspiration for a joint Local Plan. Given the context of the Government’s ambitions of 1.5m new homes and pro-growth business and employment policies it is critical that the Plan provides sufficient housing and economic growth. We support the idea of a longer plan-period, however it should be extended to a minimum of 30 years given the proposal for new settlements. If the Plan were adopted by late 2027, which is ambitious, it would cover only 23 full years. The Plan will likely require Modifications arising from Examination given the revisions to the NPPF. The timeframes should be shifted back to be more realistic.

No

ID sylw: 108347

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

The HEDNA housing requirement does not capture the latest changes to the planning system and the Government’s aspiration to boost housebuilding through recent changes to the Standard Method. This would also not meet need for affordable homes, as highlighted in the Further Advice on Housing & Employment Land Needs study (February 2024) which confirms need cannot be met without provision upwards of 2,000 homes a year.

Both Councils are experiencing a housing affordability crisis. Stratford-on-Avon is the most unaffordable area in the West Midlands.

There is a substantial 81% uplift in the local housing need for Stratford-on-Avon and Warwick (in combination) to deliver a minimum of 2,188 dwellings a year. This will approximately double the amount of the unmet housing need from 15,532 dwellings to 28,257 dwellings. This should be planned for to futureproof the plan and ensure compliance with the NPPF’s sustainability principle.

No

ID sylw: 108348

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are concerned about the lack of a robust delivery model for proposed new settlements or a robust trajectory for delivery of housing and infrastructure in the Infrastructure Delivery Plan and other supporting evidence. The PPG requires evidence there is a reasonable prospect that proposals can be delivered within the envisaged timescales. New settlements often require substantial lead-in times and have delays due to funding and infrastructure uncertainties. We urge the Councils to focus on developments that are sustainably located close to existing settlements with good accessibility, infrastructure, and employment opportunities. This is true for the promoted site, Land North and South of Welsh Road West, Southam.

Other

ID sylw: 108349

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We support this policy as we consider non-Green Belt locations the most sustainable for housing delivery, and most suitable to address the housing crisis that South Warwickshire is experiencing. We are concerned about the lack of detail and absence of relevant evidence work on the process for reviewing BUABs. The proposed settlement boundaries should include all the proposed Spatial Growth Locations to maximise opportunities for meeting housing needs in full over the next 25-year period given the acuteness of local and regional unmet housing needs. A review mechanism should also be incorporated into the policy to ensure that the boundaries are flexible and not unduly prescriptive.

Other

ID sylw: 108350

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We support the aspiration to meet the wider housing needs, especially the Coventry and Warwickshire HMA and the Greater Birmingham and Black Country HMA. We also support the decision to work closely with the Greater Birmingham and Black Country HMA to address any housing shortfalls. We are concerned that the HEDNA does not establish the extent of the wider unmet needs or the approach to addressing this to ensure the Duty to Cooperate is discharged.

Other authorities in the HMA such as Rugby, Birmingham, and the Black Country authorities, are facing significant increases in their housing need under the Standard Method. This will increase the acuteness of their housing shortfall.

We strongly urge the Councils to provide for a minimum of at least 2,188 dpa within the SWLP. In order to address the extent of the unmet housing needs, they should consider the opportunities of all potential sites in sustainable locations to existing settlements, including the Welsh Road West Site.

Other

ID sylw: 108352

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We support identification of Land North and South of Welsh Road West Southam as part of SG12. In the Interim Sustainability Appraisal SG12 is identified as one of the best performing options. However, the assessment of landscape impacts is not robust and further assessments should be undertaken. We have attached a Landscape and Visual Technical Note and Expert Opinion which demonstrates SG12 should score ‘Minor Adverse Impact” for the Landscape Sustainability Objective.

Land North and South of Welsh Road West Southam would support sustainable housing and economic growth in Southam and improve connectivity between the site and local communities. It would support sustainable commuting options and promote opportunities for modal shift. This accords with the SWLP’s ambition for a well-connected South Warwickshire and the wider Government Plan for Change which seeks to provide homes near businesses and employment opportunities.

Yes

ID sylw: 108353

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are supportive of the sequential approach that the Council pursue under Draft Policy Direction 7 when allocating strategic areas of growth.

Given the limited development capacity on potential brownfield sites as the Council’s Brownfield Land Registers show, we strongly urge the Council to prioritise the allocation of potential strategic growth locations, in particular those on non-Green Belt areas, including this Site, to minimise the extent of Green Belt land to be released while accommodating South Warwickshire’s housing needs.

With the Site’s sustainable location to an existing upper tier settlement, we consider that the Welsh Road West land to be the most suitable and deliverable option to provide sustainable levels of growth, deliver homes that meet the needs of all communities including existing residents, support the growth in employment opportunities in Southam, and contribute towards reducing carbon emissions through minimising distance of travel. These benefits arising from the allocation of the Site should be prioritised and duly considered prior to any release of other Green Belt land.

Yes

ID sylw: 108354

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We support the principle of supporting high quality densification of development under Draft Policy Direction 8 as this approach is imperative to achieve the Council’s Vision for a well-designed and beautiful South Warwickshire that respect and reflect the existing beauty of the area.

Given good accessibility to existing services, transport connections and employment opportunities as confirmed by the Interim Sustainability Assessment, we consider that both Southam and this Site have capacity to accommodate a higher density of development.

Other

ID sylw: 108355

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

In light of the extent of the substantial unmet needs for housing as shown in the above section, and the lack of sufficient capacity for development as confirmed by the Council’s Brownfield Land Registers, we consider that the Council should not be reliant upon the supply of brownfield land in addressing the need for growth.

It is significant that developments on brownfield land or previously developed land often experience financial viability issues due to high abnormal costs often associated with remediation activities, which would result in a reduction in the provision of affordable housing relative to the policy level set out in the Plan’s Vision and Objectives.

As such, and for the Plan to be robust and effective, we urge the Council to prioritise the allocation of potential strategic growth locations, in particular those on non-Green Belt areas, including this Site

Other

ID sylw: 108356

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are supportive of Draft Policy Direction 10 in providing a mix of types and densities that are appropriate to their location as it is imperative in order to delivery Strategic Objective 2 of “meeting the diverse needs of our residents.”

Notwithstanding this, to ensure the Plan meets the future housing needs as Strategic Objective 2 indicates, it is crucial that the wording of Draft Policy Direction 10 should maintain flexibility regarding affordable housing requirements and thresholds, as well as housing tenure and mix, which will allow housing provision to be based on the latest evidence of housing needs at the point of development.