Other

ID sylw: 105105

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Whilst St Philps strongly supports the SWAs moving towards Net Zero Carbon development, as set out in detail in St Philps’ response to Draft Policy Direction- 24 (Embodied carbon), if the SWAs wish to deviate from the Future Homes Standard and Building Regulations, sufficient evidence will need to be prepared to justify this – in accordance with NPPF paragraph 32, the PPG and the 2023 WMS.

In addition, the NPPF is clear that planning policies should have regard to the economic viability of sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). To this end, the SWLP will need to be supported by A Viability Assessment that cumulatively tests the impact of policy and infrastructure requirements on the viability of sites allocated in the SWLP. This should include any Net Zero Carbon requirements.

Other

ID sylw: 105115

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips support the SWA's goal of delivering high-quality, sustainable developments but believe policies need to be flexible and well-evidenced as per the NPPF. St Philips acknowledge the necessity to reduce embodied carbon; however, UK regulations primarily focus on operational energy use, lacking a national standard for embodied carbon assessments. St Philips am concerned that the SWAs are proposing policies that deviate from national requirements without adequate justification. Past proposals have been rejected for being inconsistent with national policy, highlighting the need for a robust evidence base to support any higher requirements.

Other

ID sylw: 105116

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips understand that Local Plans must address economic, social, and environmental objectives, including a 10% biodiversity net gain (BNG) as mandated by the Environment Act 2021. St Philips supports biodiversity offsetting but is concerned that the SWAs might propose a higher BNG percentage without adequate justification. The SWLP lacks sufficient evidence to support such an increase and must include a Viability Assessment considering BNG's impact on site viability. Additionally, duplicating the Environment Act's requirements in the SWLP seems unnecessary, as it would not serve a clear purpose.

Other

ID sylw: 105117

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips understand that the planning system aims to support sustainable development, which includes economic, social, and environmental objectives, and support the concept of Environmental Net Gain (ENG). However, St Philips believe that the draft policy lacks a clear purpose and may result in unnecessary duplication when considered alongside existing policies. Additionally, while St Philips acknowledge the SWAs are in the early stages of plan-making, St Philips are concerned that the policy may be aspirational but not deliverable due to the absence of a defined ENG framework.

No

ID sylw: 105118

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips recognise the importance of best and most versatile (BMV) agricultural land, in relation to economic and environmental benefits, but consider that the SWAs approach is not necessary.

The NPPF is clear that planning policies and decisions should contribute to and enhance the natural and local environment by “recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land…” (Para 187b). Notwithstanding this, the SWAs should have regard to paragraph 16(f) of the NPPF (i.e. serve a clear purpose and avoid ‘unnecessary duplication). St Philips believes a policy that largely duplicates the protections for BMV in the NPPF would not ‘serve a clear purpose’, nor avoid ‘unnecessary duplication’ as the decision taker would need to have regard to the requirements of the NPPF in any event.

Other

ID sylw: 108184

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

2.1 The National Planning Policy Framework (2024) [NPPF] sets out the Government’s
framework within which locally prepared plans can provide for sufficient housing and other
development in a sustainable manner (Para 1). It goes on to state that:
“The planning system should be genuinely plan-led. Succinct and up-to-date plans should
provide a positive vision for the future of each area; a framework for meeting housing
needs and addressing other economic, social and environmental priorities; and a
platform for local people to shape their surroundings.” (Para 15) (Emphasis Added)
2.2 In this regard, the PO sets out the SWA’s proposed Vision for South Warwickshire over the
plan period, alongside Strategic Objectives and how individual policies will contribute
towards addressing the Vision. In general, St Philips broadly support the SWA’s proposed
Vision and Strategic Objectives, as they align with the key tenets of sustainable
development in the NPPF.
2.3 However, St Philips is disappointed to see that the SWAs have omitted the previous
reference to addressing the unmet housing needs of neighbouring authorities from the
Vision, which was set out in the Issues and Options [IO] consultation. The NPPF is clear
that planning policies should as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring areas
(Para 11b) (i.e. meet their own needs in full, and any other unmet needs from neighbouring
authorities). Furthermore, paragraph 24 reemphasises that local planning authorities
[LPAs] continue to be under a duty to cooperate [DtC].
2.4 The NPPF is clear that for a Local Plan to be found sound, it must be ‘positively prepared’,
which means that it must provide a “strategy which, as a minimum, seeks to meet the
area’s objectively assessed needs; and is informed by agreements with other authorities,
so that unmet need from neighbouring areas is accommodated where it is practical to do
so and is consistent with achieving sustainable development” (Para 35a). Crucially, as the
Vision and Strategic Objectives inform the policies within the SWLP, for the SWLP to be
‘positively prepared’ both the Vision and Strategic Objectives should set out a positive
approach to addressing unmet housing needs.
2.5 In light of the above, and as discussed in detail below, there is a large quantum of unmet
housing needs arising in the Greater Birmingham and Black Country Housing Market Area
[GBBCHMA] – which the SWAs are part of – the SWLP will need to make provision for
these needs in part. At present, St Philips considers that the Vision does not place much
emphasis – or any at all – on contributing towards addressing the housing shortfall
challenges within GBBCHMA, despite a requirement under the NPPF to seek to address
them. To ensure the SWLP sets out a positive Vision, St Philips considers it should make
reference to the SWLP’s role in addressing this critical cross-boundary issue.
2.6 Equally, Strategic Objective 2 (Delivering homes that meet the needs of all our
communities) does not include any reference to addressing the unmet housing needs of
neighbouring authorities. Whilst it is noted that PO does, in Draft Policy Direction 4
(Accommodating Growth Needs Arising from Outside South Warwickshire), acknowledge
that the SWLP may need to assist in meeting these unmet housing needs, it fails to
recognise the acuteness and seriousness of this situation in Strategic Objective 2. Again,
Strategic Objective 2 should refer to the SWLP’s role in addressing these critical crossboundary issues, or as a Strategic Objective in its own right.

Other

ID sylw: 108185

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

The SWLP’s Housing Needs
2.7 Whilst the PO refers to the housing needs established in the ‘Coventry & Warwickshire
Housing & Economic Development Needs Assessment (HEDNA) (November 2022)’ (“the
HEDNA”), St Philips welcomes the PO acknowledging the SWA’s housing needs under the
revised Standard Method [SM] – see Table 4.
2.8 As the SWAs will be aware, the Government recently revised NPPF and SM for the
calculation of housing needs. The proposed new SM would significantly increase the
housing needs for the SWAs when compared to the HEDNA – as identified in the PO, with
the SWLP having to identify a further c.12,725 dwellings to meet these needs when
compared to the HEDNA’s objectively assessed housing needs [OAHN].
2.9 Notably, paragraphs 234 to 236 of the NPPF are clear that Local Plans that do not reach
Regulation 19 by the 12th of March 2025 and are planning to meet at least 80% of the local
housing need [LHN] figure generated by the revised SM would be required to take full
account of the revised NPPF policies, in addition to the updated LHN figures generated by
the revised SM.
2.10 When taken together, and given the SWA’s working timetable for the SWLP, it is clear that
the SWAs will need to plan for the revised SM figure through the SWLP. This is because the
NPPF is clear that the overall aim of Local Plans should be to meet an area’s identified
housing need in full (Para 61) generated by the revised SM (Para 62), as the SWLP will not
have reached Regulation 19 by the 12th of March 2025. To this end, St Philips considers that
the SWAs should seek to address the c.2,188 dwellings per annum [dpa] LHN generated by
the revised SM – or c.54,700 dwellings over the 2025 to 2050 plan period.
2.11 However, St Philips would also highlight to the SWAs that it is expected that Local Plans
should be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a
housing trajectory has sufficient land supply across the plan period so that it can adjust and
accommodate any unforeseen circumstances, such as a degree of flexibility in delivery rates
and densities. Critically, this means that to achieve a housing requirement a Local Plan
must release sufficient land or allow sufficient ‘headroom’ so that there is an appropriate
buffer within the overall planned supply.
2.12 As such, in due course, it will be necessary for the SWAs to identify suitable land supply in
excess of the SWLP’s LHN-based housing requirement to ensure that there is the flexibility to respond to failures to deliver the required dwellings in the allotted time frames and
across the whole plan period. Importantly, this ‘buffer’ should also be in excess of any
commitments to addressing unmet housing needs from neighbouring authorities –
discussed further below in St Philips’ response to Draft Policy Direction 4. This is because if
any single component of supply does not come forward or falls behind the timescales
implied by the SWAs, this would result in the unmet housing needs not being delivered,
rather than the SWLPs. Therefore, St Philips would recommend that a minimum of c.10-
20% headroom should be incorporated into the SWLP proposed housing supply.

Strategic Growth Locations
2.13 Given the scale of the SWA’s emerging housing needs under the new SM and the need to make a contribution towards the unmet housing needs of the GBBCHMA, St Philips strongly supports the proposed ‘Sustainable Travel and Economy’ Spatial Growth Strategy. This is because it will best promote sustainable patterns of development across the area and align with the sustainability aspirations that are set out in the NPPF and SWLP Vision and Objectives. 2.14 Ultimately, whilst greater levels of development may need to be focussed around the Main Urban Areas, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach, which includes Green Belt release, to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the SWAs to capitalise on opportunities presented by existing or planned infrastructure when considering options for large-scale new residential developments, in accordance with paragraph 77a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent with paragraph 148 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well served by public transport (Paragraph 147); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area in close proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions).

Approach to achieving net zero
2.33 As noted above, St Philips’ Vision for the Site ensures that the development could deliver on
the SWLP’s Vision and Strategic Policy Objectives in relation to delivering sustainable
growth and combating climate change. Further information on how St Philips proposes to
achieve this is set out in detail in the supporting Vision Document (Appendix 1).
2.34 However, in short, the Site could deliver a suite of ecological and green infrastructure
improvements throughout the proposed development, ensuring a 10% Biodiversity Net
Gain [BNG] alongside blue-infrastructure enhancements and a c.9 ha Country Park. When coupled with a fabric-first approach to the build specification that will ensure that new
homes will reduce heat waste and incorporate low-carbon energy generation technologies,
and electric vehicle charging points, the Site is well placed to assist the SWAs in achieving
Net Zero.

Mitigation of issues identified through the SA
2.35 Based on the SA conclusions, SG24 broadly ranks in the middle out of twenty-four SGLs in terms of best and worst-performing SGLs against the Sustainability Appraisal [SA] objectives, set out in the ‘Interim Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Preferred Options Stage’. However, it is considered that these matters are resolvable through appropriate mitigation – indeed, as stated within the SA: “Mitigation has not been considered when ranking the SGLs, given the options requiring less intervention are likely to be more sustainable choices.” However, St Philips have set out below how the Site could mitigate against any of the impacts identified within the SA: [See attachment]
Further technical work can be provided to the SWAs to demonstrate that the Site could mitigate any negative impacts arising from development.

Yes

ID sylw: 108186

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

2.15 It is noted that the PO has identified twenty-four areas as Strategic Growth Locations [SGL]
and that not all of those locations will be allocated. St Philips strongly supports the
identification of the Hockley Heath Group (SG24) as a Strategic Growth Location within the
PO. Whilst the settlement is located on the edge of WDC’s administrative boundary, its role
within South Warwickshire’s approach to meeting the GBBCHMA’s unmet housing needs
should also not be disregarded. Whilst there is no ‘unmet need’ in spatial planning terms to
be accommodated from this neighbouring local authority, Solihull is nevertheless a core
part of the GBBCHMA. There is a strong and cogent argument to meet the unmet housing
needs of neighbouring authorities in an area in close proximity to where these unmet needs
have arisen – and Hockley Heath lends itself well to this approach as an entirely logical
location to meet this challenge. Indeed, the NPPF is clear that planning policies should identify opportunities for villages to
grow and thrive, especially where this will support local services (Para 83). Directing
growth to rural settlements supports local services and also ensures development is located
sustainably in line with the NPPF (Para 11a). Existing settlements often have access to
education, healthcare, retail, jobs, and public transport, and should therefore be considered
as ideal locations for growth. Further growth in rural settlements can also broaden the
scope for these settlements to seek improvements to services and infrastructure, helping to
address imbalances between the rural and urban areas in terms of provision and access to
facilities.
2.17 To this end, the NPPF is clear that, in rural areas, planning policies and decisions should be
responsive to local circumstances and support housing developments that reflect local
needs (Para 82) and that small and medium-sized sites can make an important contribution
to meeting the housing requirement of an area and are often built-out relatively quickly
(Para 73). St Philips considers that the development on the edge of Hockley Heath (i.e.
SG24, and particularly St Philips’ Site) lends itself well to achieving these objectives,
particularly given the fact that the site is well-located in order for residents to access a range
of key local amenities and facilities within walking distance of the Site. As such, St Philips
strongly considers that the SWLP should direct growth to Hockley Heath and allocate SG24
in the SWLP.

[Specific comments on Site 178- Land off Stratford Road, Hockley Heath (within SG24)
2.18 As set out in Section 1.0 of these representations, St Philips is promoting land at Stratford Road, Hockley Heath, for residential-led development. Whilst part of the Site falls within SMBC’s administrative area, the majority of the Site lies within the administrative boundary of WDC. 2.19 The Site comprises c.33ha of land and is located directly to the northeast of Hockley Heath, in the Green Belt. Aylesbury Road (B4101) lies to the south of the Site and Stratford Road (A3400) to the west. Bus stops on Stratford and Aylesbury Road, provide regular bus services that provide connections to key regional destinations including Birmingham, Stratford upon Avon and Solihull. The settlement benefits from a range of key local amenities and facilities, including the Hockley Heath village centre convenience store, a Post Office, Dental Surgery and Primary School. 2.20 The Site has no physical constraints that would prevent development. There is limited vegetation on the site, with the exception of some trees and boundary vegetation. Design proposals would positively seek to retain and enhance any trees and hedgerows where possible within the Site as part of the placemaking strategy, subject to detailed studies and further technical work. 2.21 Crucially, the SWA’s own evidence base confirms that the Site is in a lower-performing area of Green Belt land which does not significantly contribute to the purposes of the Green Belt.
As set out in detail in St Philips’ response to Draft Policy Direction 7 (Green Belt), the Site should be considered ‘Grey Belt’ and in a location that would secure more sustainable patterns of development. To this end, St Philips consider that the release of the Site from the Green Belt would be suitable and would accord with the ‘sequential approach’ set out in the NPPF (Para 148). 2.22 In this regard, the Vision Document (Appendix 1), submitted in support of these representations, demonstrates how the Site could deliver a medium-sized sustainable development of up to 400 new market and affordable homes through the SWLP on the edge of Hockley Heath. It demonstrates how the Site could deliver a residential-led development that addresses the SWLP’s Vision and Strategic Policy Objectives in relation to delivering sustainable growth and combating climate change in South Warwickshire. 2.23 The Concept Plan within the Vision Document demonstrates how the Site could deliver up to 400 residential dwellings (Class C3) and a community building or facility (Class F2), a c.9 ha Country Park, and a network of supporting green and blue infrastructure. 2.24 The design’s scale and form can cater to a range of house types and living styles, including self-and custom-build plots, retirement housing and community-led housing projects. All homes would be integrated within an attractive and well-connected network of low-traffic streets and green corridors. 2.25 It is envisaged that the Site could come forward in two phases. Phase 1 could deliver c.150 dwellings, and the community facility, with primary vehicular access off Aylesbury Road and new pedestrian and cycle access points on Stratford Road, alongside public open space, supporting infrastructure and SuDS. Phase 2 could deliver a further 250 dwellings, with a second vehicular access from Stratford Road, alongside further public open space, supporting infrastructure and SuDS and the Country Park. 2.26 The design embraces high-quality placemaking principles and shows how the SWLP’s Vision and Strategic Policy Objectives can achieved on this site, with the result being a sensitive, valuable and logical new edge to Hockley Heath. The key components of the Concept Plan are: 1 Up to 400 new homes, delivered across two phases, including the flexibility for a range of different housing models to be integrated, which could begin delivering in the first five years of the SWLP plan period. 2 Provision of land for a community facility, positioned in a location that will bridge the existing and new communities. 3 A new c.9 ha Country Park, providing areas for formal and informal play, benefiting both the existing and proposed communities and supporting opportunities for improved health and wellbeing. 4 A mosaic of sustainable drainage solutions across the site will capture surface water runoff close to the source and enhance the visual amenity of the public realm. 5 A legible and accessible strategy, providing direct pedestrian and cycle links to local facilities and services, encouraging active modes of travel for local trips. 6 Outward-looking development ensuring an attractive public realm with strong natural surveillance.7 Retention and integration of existing landscape to protect and enhance biodiversity and secure a unique identity that responds to the natural environment. 8 A tree-lined boulevard and feature gateway, providing a new development edge that makes an attractive and logical new edge to the settlement. 9 Significant areas of accessible public green space close to each new home. 10 Provision of generous space for enhancements to biodiversity and ecology through the retention of existing trees and hedgerows (where possible) and the planting of new vegetation, that will deliver overall environmental net gain. 2.27 Crucially, the proposed development could respond sensitively to its surroundings through measures such as providing a visual buffer planting within the Country Park edge to create a strong and defensible long-term Green Belt boundary. Connectivity through the Site through Green Infrastructure corridors and to the village and surroundings would be emphasised to encourage sustainable travel. The delivery of environmental enhancements on-site, which would be achieved as part of the development, would also ensure that any harm arising as a result of the removal of the Site from the Green Belt could be offset.

Other

ID sylw: 108187

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Suitable, Available and Achievable
2.28 The land at Stratford Road Hockley Heath was assessed in the SWA’s ‘Housing and Economic Land Availability Assessment (2024)’ [HELAA] under Site Reference: 178. The Site was assessed through the Part A and Part B HELAA assessments and was recommended to remain in consideration for the SWLP – a conclusion that St Philips welcomes and supports. 2.29 The SWAs will be aware of the importance of demonstrating the deliverability of all sites that are proposed for allocation when SWLP is examined for soundness. If allocated, it is considered the Site could be developed in the short-medium term. In this regard, Annex 2 of the NPPF states that to be considered deliverable, “sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years.” 2.30 In this context, St Philips wishes to reaffirm the Site’s status as being ‘suitable, available and achievable’ and that St Philips’ Vision for the Site is predicated upon evidence which ensures that there are no environmental or technical constraints to the development of the Site. Importantly, St Philips have the capability and expertise to deliver this Vision for the Site and is committed to working constructively with the SWAs and local stakeholders through the plan-making process. St Philips is also willing to work with the wider SG24 landowners to bring forward a comprehensive and inclusive development on the edge of Hockley Heath.

Delivery Timescales
2.31 As noted above, it is envisaged that the Site could be developed in the short-medium term
in two phases:
• Phase 1 could provide approximately 150 homes and a community facility, with primary
vehicle access from Aylesbury Road and new pedestrian and cycle access points on
Stratford Road. This phase would also include public open spaces, supporting
infrastructure, and SuDS.
• Phase 2 could add an additional 250 homes, introducing a second vehicle access from
Stratford Road. It would also feature expanded public open spaces, further supporting
infrastructure, SuDS, and the Country Park.
2.32 It is envisaged that subject to the Site being allocated in a future Regulation 19 SWLP, St
Philips would seek to submit a planning application in advance of the Examination in
Public to assist the SWAs in demonstrating the deliverability of the allocation to Inspectors.
Assuming the SWLP is adopted in line with the SWA’s timetable (i.e. December 2027), and
the application is approved shortly thereafter, delivery on Phase 1 could begin within 3
years, meaning that the development could form part of the SWLP’s five-year housing land
supply. In respect of the delivery trajectory, St Philips envisages the Site could be delivered
broadly in line with the below trajectory and deliver well within the SWLP plan period: [See attachment]

Yes

ID sylw: 108188

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements? 2.37 Yes, St Philips considers that it is clear that the step-change in delivery required to meet the SWA’s SM LHN figures, and any unmet housing needs from the GBBCHMA, will require a suite of new sites to be allocated throughout the SWLP area – including New Settlements. Indeed, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 74), such as New Settlements. 2.38 Importantly, however, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b) and should set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). As such, the SWAs also need to robustly test reasonable alternatives for the spatial distribution of South Warwickshire’s housing needs through the SA process at an early stage. In addition to the above, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 67). 2.39 The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large-scale developments can come forward. In particular, this should include a realistic assessment of the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales.1 2.40 In this context, St Philips would not object to the option of exploring meeting some of the SWA’s needs through a New Settlement but wishes to highlight to the SWAs that sufficient evidence will need to be prepared in support of any future allocation. However, St Philips would note that such forms of development should not be viewed as the panacea for meeting all of the SWLP’s needs. These types of development can take some years to come onstream and begin delivering, and the SWAs will need a spatial strategy that allocates a supporting package of ‘suitable, available, and achievable’ sites at different scales throughout the SWLP area in sustainable locations to ensure that supply can come forward in the earlier parts of the plan period to meet housing needs in the interim.