Yes

ID sylw: 102768

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

Asiant : Stansgate Planning

The current Core Strategy recognises that Alcester is the largest of the main rural settlements in
the District and supports a wide range of shops, services and jobs. For that reason, the town is a
suitable location for further housing and employment. Necessary development and sustainable,
organic growth in Alcester have been held back by the constraint of Green Belt, which surrounds
the town.

No

ID sylw: 102773

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

Asiant : Stansgate Planning

The SWLP Preferred Options does not currently conform to national planning policy and must be redrafted to reflect the latest version of the National Planning Policy Framework, currently that published in December 2024 (with February 2025 amendments).
Taking this into account, 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 to provide sufficient employment land to meet the Districts’ needs. The Policy must NOT set maximum provision figures as this would unnecessarily restrict the ability of the area to meet the key aims.
In respect of housing provision, all reference to the 2022 HEDNA should be removed. Instead the policy should set out the minimum number of homes needed assessed using the Standard Method (in accordance with Framework paragraph 62). Adequate flexibility must be built in to meet changing circumstances, and to accommodate housing needs arising from beyond the Districts’ boundaries.
The Plan proposes to meet much of the housing requirement though the allocation of new settlements and significant extensions to existing settlements. This is supported as an appropriate response to meeting housing needs within the Districts. Particular attention should be given to accommodating development in locations which are already supported by necessary infrastructure and facilities, as well as those where they can be provided.
In accordance with Framework paragraph 22 the plan period should be extended from 25 years to at least 30 years, and the housing and employment requirements increased accordingly.

No

ID sylw: 102778

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

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.

Other

ID sylw: 102782

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

Asiant : Stansgate Planning

This approach, and the allocation of sustainable sites within the Green Belt in Stratford and Warwick Districts to meet future development needs, is strongly supported.
That notwithstanding, the SWLP Preferred Options does not currently conform to national planning policy and must be redrafted to reflect the guidance in the PPG on Green Belt, published on 27 February 2025. In particular this requires Councils not only to assess Green Belt but also to identify what land within the Green Belt is grey belt, and to prioritise the allocation of grey belt sites ahead of other Green Belt land.

No

ID sylw: 102788

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

Asiant : Stansgate Planning

The Policy Direction indicates that the Local Plan will require the provision of pitches and plots on large scale development sites, being sites providing over 500 homes. The proposed policy direction is unjustified and therefore does not comply with the requirements of Framework paragraph 36b).
Provision of gypsy, traveller and show peoples accommodation is an essential part of meeting housing needs across the District area and it is important that the SWLP includes a policy to consider the matter, and more particularly to meet the needs identified by the Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Assessment (August 2024) or any subsequent update. The current need, identified in the August report, is for up to 89 gypsy and traveller pitches, and 18 additional travelling showpeople plots, and provision for this level of accommodation is required.
The Councils consulted on the best location for these sites as part of the Issues and Options, suggesting three options – part of large development sites, on sites identified in the Plan, or assessed on a site by site basis against an agreed list of criteria. As the Preferred Options confirms, allocation within large development sites was the least favoured option. It is therefore surprising
that this is now the preferred option.
The August report confirms that ‘there is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security’. Thus to comply, small sites will be required. Provision, even of relatively small sites, as part of large developments, would not seem to conform with this requirement, and are unlikely to sit comfortably within large development areas.
The policy should revert to either specific allocation or a criteria based approach on a site by site basis.

No

ID sylw: 102793

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

Asiant : Stansgate Planning

The final paragraph of Draft Policy Direction 32 indicates there will be a robust policy for the provision of EV charging infrastructure in new developments. Framework paragraph 16 f) states that Development Plans should serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area. Electric Vehicle Charging Points, with associated infrastructure, are required under Building Regulations Approved Document S for all new dwellings and commercial developments. As such, there is no need for the duplication within planning policy and the references should be removed.

No

ID sylw: 102799

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

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 Council’s will explore evidence to adopt a higher percentage to
achieve greater biodiversity benefits. 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: 102802

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

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: 102809

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

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 over shading could harm residential amenity. This Policy Direction should be deleted from the Plan.

Other

ID sylw: 102811

Derbyniwyd: 07/03/2025

Ymatebydd: The Ragley Estate

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.