No

ID sylw: 106504

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We object to Draft Policy Direction 1.
As drafted, the policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient
flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have
some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the
NPPF, and associated update to the Standard Method, were in draft form only and subject to change.
However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to
the Standard Method requirement and make no reference to the HEDNA.
As such, the SWLP should be taken forward having regard to Table 3, which we support. We also support
the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a
ceiling.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62,
whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF
paragraph 69

Yes

ID sylw: 106505

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

In terms of the strategic growth options, we support the inclusion of Gaydon Lighthorne Heath Group SG13
in the draft SWLP and in particular HELAA site reference 718.
Development at Gaydon Lighthorne Heath is consistent with the overarching plan strategy and settlement
hierarchy.
Its inclusion will assist in meeting strategic growth requirements as set out at Policy Direction 1,
development can achieve the requirements of Policy Directions 5, 8, 10, 26, 31 and 38; and positively
contribute to Policy Directions 6, 13, 21 and 43c.
Strategic growth location SG13 is supported by the Spatial Growth Strategy Options Paper, Strategic
Transport Assessment, and HELAA. As such, its inclusion is consistent with key parts of the evidence base
underpinning the SWLP, which is an approach required by the NPPF.
Strategic Growth Location SG13 would deliver housing and associated infrastructure at one of the SWLP
plan area’s largest urban areas, and thus would - in plan strategy and locational terms - be the most
sustainable location for delivering growth.
Notwithstanding, we consider it essential that the SWLP is taken forward with a smaller parcel assessment
rather than the more macro scale parcels currently shown in proposed strategic growth location SG13. In
and of itself, HELAA site reference 718 is a strategic scale site capable of delivering significant housing
numbers and associated blue and green infrastructure as well as social and community infrastructure.

Smaller areas of the site fronting Banbury Road B4100, with urban influences, are likely to exhibit a lower
(and thus superior) site scoring than the scoring for the wider site 718 – notwithstanding that site 718
performs well (46.70 in the HELAA Part B assessment). As a result, smaller micro scale site assessment
should be carried out to refine the scoring for strategic growth location SG13.

Yes

ID sylw: 106506

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We support the approach set out in Policy Direction 3. Built Up Area Boundaries should be reviewed to take
account of committed development which has occurred since the adoption of the Core Strategy, and also
to take account of new allocations proposed through the SWLP to ensure that ‘countryside’ policies do not
apply to allocation sites.

Other

ID sylw: 106507

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We support that the SWLP will be underpinned by a housing need and availability evidence base that
considers the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and
Black Country Housing Market Area.
The latest Housing and Economic Development Needs Assessment (HEDNA) for Coventry and Warwickshire
(C&W) underscores the urgent need for a regional approach to addressing unmet housing demand. With an
annual housing requirement of 4,906 dwellings per annum (dpa) and a substantial shortfall in affordable
housing—3,833 rented affordable homes annually—Coventry faces the most significant pressure within the
sub-region. Given that 96% of Coventry’s affordable housing need remains unmet, it is imperative that South
Warwickshire plays an active role in accommodating this demand. Previous commitments, such as the
Memorandum of Understanding (MoU) between Coventry and Warwickshire authorities, have resulted in
Stratford-on-Avon and North Warwickshire allocating 2,880 dwellings to assist Coventry. However, these
allocations must be revisited within the South Warwickshire Local Plan (SWLP) to ensure a continued and
strategic approach to housing provision that aligns with the latest evidence base.
The SWLP must also recognise its strategic position within both the Coventry and Warwickshire Housing
Market Area (HMA) and the Greater Birmingham and Black Country HMA. Stratford-on-Avon has historically
contributed to both HMAs, with allocations of 2,720 dwellings for Greater Birmingham and Black Country
and 2,880 dwellings for Coventry and Warwickshire. As the plan extends to 2050, it must acknowledge the
ongoing cross-boundary pressures and proactively accommodate a proportionate share of the unmet
housing need. Deferring this responsibility to development management decisions or reserve sites would
undermine the plan-led approach required by the National Planning Policy Framework (NPPF). Instead, a
forward-looking policy framework should be established, ensuring that housing allocations
comprehensively address regional demands while balancing infrastructure capacity and sustainability
objectives.
Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic,
economic, and migration trends influencing South Warwickshire’s housing market. By proactively planning
for these needs now, the SWLP can provide certainty for local authorities, developers, and communities,
ensuring that housing growth aligns with economic and social sustainability. A clear strategy for
accommodating unmet housing need must be embedded within the plan to avoid the risks associated with
reactive policymaking, uncoordinated site releases, and an insufficient five-year housing land supply.

On this basis the clear indication now is that the SWLP will need to make a contribution by way of a duty to
co-operate and accommodate unmet housing needs arising from outside the SWLP plan area. It is
imperative that this is planned for now, having regard to NPPF paragraph 69. It is not appropriate to defer
the duty to co operate to reserve sites – which infers that a commitment to the duty to co-operate will be
deferred by stealth. The approach to deferring the duty to co-operate to the development management
function as a result of a deficiency against the 5-year housing land supply position is worse still. The
planning system is plan-led and the plan-led system should accommodate all of the housing needs arising
from both within the plan area and within the wider HMA’s. To do otherwise would be a serious failing of the
SWLP, a matter which would go to the heart of the plan and not able to be rectified through any
examination process or main modifications.

Other

ID sylw: 106508

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We recognise that all development proposals should provide appropriate on and off site infrastructure
requirements.
This is subject to those requirements meeting the CIL tests.
Where infrastructure goes beyond that necessary to mitigate the impacts arising from development, this
should be offset against other development management requirements, and/or put in the planning balance
as a matter of significant weighting.
We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to
be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at
this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations. This is
not a matter to be deferred to the Publication Consultation (this being the final consultation prior to the
SWLP being submitted for examination).
We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any
work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site
promoters so as to bring forward genuinely deliverable site options. The process should be workshop
based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each
subsequent workshop – to get to an agreed position by way of an iterative process. In so doing, the SWLP
can be progressed and put to examination with a suite of completed SoCG’s underpinning each chosen
site within the spatial growth locations, such that the Councils can be confident about the deliverability of
each site and thus the soundness of the SWLP as a whole.

Other

ID sylw: 106509

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to
the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban
quality, some of the Councils highest valued urban areas deliver densities at what might be considered to
be very high. By way of worked example, a maisonette doubles the density of a building over a traditional
house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to
the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish whateach spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to
robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means
that site viability, and thus deliverability, cannot be established with promoters since the infrastructure
requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Yes

ID sylw: 106510

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We broadly support the requirements to make efficient use of brownfield land. Recycling previously
developed land can (though not always) achieve a series of sustainability objectives.
However, the scale of housing required in the plan area – even by the HEDNA evidence, which is
significantly below the Standard Method and before adding in the duty to co-operate – is such that
brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in
the plan area.
Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward
brownfield sites ahead of green field opportunities. Setting aside that broader sustainability objectives
should be applied (for example, a green field site on the edge of a town or extended village performs
significantly better than an isolated brownfield site in National Landscape) the NPPF contains no such
sequential approach to previously developed land. The sequential approach to brownfield development
was founded in PPS3 and PPG3 before it, and was expressly removed from the NPPF in 2012 and has not
been re-introduced in any of the revisions to the NPPF since

Yes

ID sylw: 106511

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We broadly support the principle that the SWLP should deliver a range of housing of differing sizes, types
and tenures.
However, housing mix policies are oft drafted in a rigid manner, with little opportunity for flexibility of
application to reflect site specific circumstances.
For example, a town centre site is rarely able to deliver family housing, and nor need it given that town
centre living is a housing market in and of itself. Conversely, with town centre sites delivering smaller
housing types those sites in edge of settlement locations should deliver larger family type housing. Put
simply, the policy should be drafted to allow for a range of housing types and tenures across the plan area,
rather than across individual sites. The Councils could keep an up to date annual monitor to establish in
each reporting year how the delivery is performing against the objectives of Policy Direction 10.
Insofar as housing tenures, the NPPF sets out what is now considered to be affordable tenures in meeting
affordable housing need. We strongly support first homes and other forms of discount from open market
level, which provides for ‘second tier’ affordable provision delivered by the private sector without the need
for any public intervention.

Other

ID sylw: 106512

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We recognise that the SWLP is to meet a range of needs across different sectors. Gypsies, travellers,
travelling show people and boat dwellers are an important components to overall needs.

The Councils should consider the strategy for delivering such needs. Specific sites could be identified for
these needs, as an alternative or in combination with delivery such needs on spatial growth sites. If spatial
growth sites are intended to assist in delivering these needs, site size thresholds require careful
consideration, we question whether the as drafted site size threshold of 500 units is appropriate and
whether a higher threshold is justified.

Yes

ID sylw: 106513

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We broadly support the application of Design Codes, in varying degrees of detail, consistent with the
nature of the code itself - be it area wide or site specific.
Design Codes should however be prepared in consultation with promoters as key stakeholders, to ensure
the code is proportionate and appropriate. Codes should support promoters objectives, where one site
might be being delivered with a focus on GI and lower density development whereas another site might be
being delivered at a higher density and seeking to support an off site cultural asset.
A skeletal Design Code could form part of a Statement of Common ground prepared between the Councils
and site promoters, applying the approach we have set out in responding to Policy Direction 5.
In all cases Design Codes should have regard to NDMP’s introduced through the Levelling Up and
Regeneration Act 2023