No

ID sylw: 107504

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Vision

Five overarching principles for the plan which are pursuant to the vision are listed. Notably, these do not fully align with the draft vision, and this must be addressed. Indeed, none of the principles refer to the delivery of “homes and įobs”, despite the provision of new housing and economic growth being key to the achievement of sustainable development, as highlighted in Paragraph 8 of the NPPF. In order to ensure that the vision and its five principles are positively prepared and consistent with national policy, which emphasises the importance of planning to meet an area’s objectively assessed needs, it is imperative for reference to be made to this, to then feed into the Strategic Objectives which follow. These do reference housing and employment (SO 1, 2, and 4), but have no direct link to the five principles as drafted.

The selected spatial growth strategy, ‘Sustainable Travel and Economy’, should also be referred to, and woven into the other principles, as this strategy is now a fundamental part of the SWLP and the vision for South Warwickshire, which will shape the strategic objectives and policies in the plan.

The vision and first of the five principles place a significant emphasis on responding to the climate emergency. Although this is supported in general, it is important that this does not dominate the Vision and Strategic Objectives of the SWLP to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs.
The second principle refers to creating a “beautiful” South Warwickshire. Whilst this aspiration is supported, and there is some reference to “beauty” within national policy, including in Paragraph 131 of the NPPF, there is concern that this is poorly defined and will need to be supported by more detailed guidance on what beauty means in practice.

Strategic Objectives

The twelve Strategic Objectives are comprehensive, covering the social, economic, and environmental dimensions of sustainable development set out in Paragraph 8 of the NPPF. It is thus considered that they are consistent with national policy.

No

ID sylw: 107505

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

a) Housing Numbers

It is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire, and opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

b) Housing Land Supply

The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase). The latest analysis from Landstack indicates that using the new Standard Method results in a housing supply of just 2.96 years.

In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.62-year housing land supply at the present time.

c) Spatial Growth Strategy

There is insufficient previously developed land within South Warwickshire to accommodate the level of housing required.

The Councils clearly have an opportunity to allocate additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher- growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.

It is contended that the SA undervalues the positive contribution that residential development in South Warwickshire can make towards biodiversity, particularly if sites are currently in arable use, as such land generally has a low ecological value.

The Site forms part of the ‘South of Wellesbourne Group’ Strategic Growth Location (SG16) and is split across Priority Areas 1 and 2. Its inclusion and Priority Area designation is strongly supported. This highlights that the Site is a sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. Development would also assist with sustaining facilities and services in Wellesbourne, which is a smaller settlement. SG16 has been assessed against the SA Framework and generally performs favourably.

Other

ID sylw: 107529

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

New settlements can make an important contribution towards meeting South Warwickshire’s housing requirement. Indeed, Paragraph 77 states that the supply of large numbers of new homes can often be best achieved through planning for new settlements, thus this approach would be consistent with national policy, and the provision of one or more new settlements is supported in principle. The Councils are reminded that where such large-scale residential development is proposed, Paragraph 22 of the NPPF stipulates that strategic policies should be set within a vision that looks at least 30 years ahead (taking into account the timescales likely to deliver a new settlement). The vision in the SWLP Part 1 is currently restricted to its 25-year plan period, thus, if the Councils were to pursue a new settlement, this would need to be amended/addressed accordingly within the plan.

New settlements have long lead-in times, which means that their contribution towards South Warwickshire’s housing supply would likely be in the latter part of the plan period, and possibly into the next. If too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations, and these should form the majority of South Warwickshire’s housing supply, in addition to any new settlement(s).

The Emerging Spatial Growth Strategy Topic Paper recognises that new settlements will have a harmful impact due to the amount of land they would occupy in existing countryside locations. The SA suggests that the Strategic Growth Locations are therefore generally more sustainable, in terms of having lesser adverse impacts on the SA Objectives.

New settlements have long lead-in times, which means that their contribution towards South Warwickshire’s housing supply would likely be in the latter part of the plan period, and possibly into the next. If too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations, and these should form the majority of South Warwickshire’s housing supply, in addition to any new settlement(s). This aligns with Paragraph 61 of the NPPF, which states that a variety of land should be brought forward for housing, i.e. sites of different scales, ranging from minor development through to new settlements.

The SA assesses the potential new settlement locations. Whilst they would all make a major positive contribution to housing (SA Objective 9), all options will generally result in minor adverse to major adverse impacts across most of the other SA objectives. The Emerging Spatial Growth Strategy Topic Paper recognises that new settlements will have a harmful impact due to the amount of land they would occupy in existing countryside locations. The SA suggests that the Strategic Growth Locations are therefore generally more sustainable, in terms of having lesser adverse impacts on the SA Objectives. However, it is important to note that this is only a high-level exercise, which has not taken potential mitigation, which could include ecological and landscape enhancements which would give rise to major positive impacts, into account. As with the Strategic Growth Locations, the positive impacts on transport and accessibility (SA Objective 11) and, as a result, Climate Change (SA Objective 1) have also not been recognised.

Yes

ID sylw: 108205

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This Policy Direction, in encouraging small-scale development, is generally supported; Paragraph 73 of the NPPF is clear that small-to-medium sized sites can make an important contribution towards an area’s housing supply, and opportunities should be sought to support small sites being brought forward. It is stated that the existing settlement boundaries will be reviewed, and this is encouraged by Persimmon.

The fact that the Councils will support small-scale development adįacent to settlement boundaries is welcomed, since these can be amongst the most sustainable locations for housing. Going forward, it will be important to define “small-scale”.
Villages should be afforded more growth where this would not have adverse sustainability implications.

The Policy Direction suggests that very limited development will be allowed within and adjacent to settlements in the Green Belt. In order to be consistent with the latest national policy, it is recommended that reference should be made to ‘grey belt’ land.

Other

ID sylw: 108206

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Paragraph 24 of the NPPF sets out the duty to cooperate, and Paragraph 36 is clear that for a plan to be positively prepared, unmet need from neighbouring areas must be accommodated where possible. Stratford forms part of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and both Stratford and Warwick are in the Coventry and Warwickshire Housing Market Area. The latest position on housing need in the GBBCHMA is dated July 2020; this identified an unmet need of 40,325 dwellings, and a shortfall of 29,260 dwellings post-2031 in the Black Country alone. More recently, in the Birmingham Local Plan Review Preferred Options consultation document (July 2024), a shortfall of 46,153 dwellings over the period 2020 – 2042 was identified, with paragraph 3.5 stating that “the city will continue to be reliant on other local authorities to assist in meeting Birmingham's housing shortfall”. The evidence on shortfalls in the HMAs is out-of-date and should be refreshed as a matter of priority. To deliver the housing the HMAs require will necessitate a clear delineation of responsibility under the duty to cooperate to address any shortfalls, including through the SWLP Part 1.

In anticipation of there being significant shortfalls, in light of the scale of the previously evidenced shortfalls and the fact that various authorities in the HMAs have experienced significant increases in their housing requirements arising from the revised Standard Method, the Councils are encouraged to plan appropriately and allocate (reserve) sites for this purpose. It is considered that there is sufficient developable land in the large area of South Warwickshire to do so, as identified in the Strategic Growth Locations and potential new settlements, which can accommodate a significantly greater number of units than is required to meet Stratford and Warwick’s own needs. The Councils have a legal duty to cooperate and a responsibility to help address unmet needs, and for the SWLP Part 1 to be found sound, it is expected that it will need to do so.

Yes

ID sylw: 108207

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The provision of appropriate infrastructure is supported in principle. In Stratford and Warwick, developer contributions can be secured via the Community Infrastructure Levy and Section 106 Agreements. The SWLP Part 1 should clearly define and distinguish between the two; developers should not be required to contribute towards the same items through each. In addition, the SWLP Part 1 should make it explicitly clear, including in relation to education contributions, that only proportionate infrastructure can be sought in line with the needs generated by a development – contributions must not extend beyond this to remedy any existing deficiencies which may exist in South Warwickshire. Indeed,

The emerging Policy Direction makes no reference to viability considerations. It suggests that “all development must provide appropriate on- and off-site infrastructure” (emphasis added), despite the fact that this may render a scheme unviable. The SA has not recognised the adverse impacts this omission could have on SA Objectives 9 (Housing) and 11 (Economy). Paragraph 35 of the NPPF is clear that whilst plans should set out the contributions and infrastructure expected from development, such policies should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure that contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may demonstrate whether particular circumstances justify the need for a viability assessment at the application stage.

Other

ID sylw: 108208

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The Councils are proposing to carry forward the existing safeguarding measures for schemes which are yet to be completed. Paragraph 111(c) of the NPPF does state that planning policies should identify and protect sites and routes which could be critical in developing infrastructure to widen transport choice. However, the NPPF is also clear, in the same paragraph, that policies should only seek to do this where there is robust evidence to justify it, and the Councils acknowledge, in the supporting justification for the policy direction, that such evidence is still emerging, and further work is required in this respect. It will be necessary for the policy and safeguarding of land to be underpinned by appropriate evidence, to ensure that this is justified and sound, as per Paragraph 36 of the NPPF.

Yes

ID sylw: 108209

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Persimmon are supportive of a Green Belt review in to support the South Warwickshire Local Plan. Exceptional circumstances would exist here, due to the significant number of homes which need to be provided, in the context of there being limited capacity within settlements to deliver new housing

The South Warwickshire Green Belt Review Stage 1 (October 2024) does not consider grey belt. However, it does conclude that only 9 out of 113 Green Belt parcels were assessed as making a strong contribution to the Green Belt purposes.

The definition of grey belt refers to previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in Paragraph 143 of the NPPF. Thus, with over 100 parcels not strongly contributing towards these purposes, Persimmon would expect there to be a significant number of grey belt sites within South Warwickshire that can suitably accommodate development.

The Green Belt policy in the SWLP Part 1 will need to make reference to grey belt to ensure that it is consistent with the NPPF, as required by Paragraph 36.

The draft Policy Direction suggests that areas of land may also be safeguarded to meet longer-term needs. This is supported, and would align with Paragraph 149(c) of the NPPF, which encourages this where necessary.

Yes

ID sylw: 108210

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

There are a range of densities throughout South Warwickshire, as highlighted in the Guide to Existing Housing Densities Topic Paper (January 2023), ranging from 6 dph in Alveston to 113 dph in central Leamington Spa. The Policy Direction is broadly supported as it recognises that a flexible approach to density should be taken. The NPPF emphasises the importance of achieving densities which are appropriate to the character of the area within which sites are located, with Paragraph 130 stating that a range of densities should be set out in policy to reflect the accessibility and potential of different areas. Such an approach would be consistent with national policy and justified, since the evidence base highlights the existing varying densities, and the need to consider the unique character of areas, some of which will be better suited to densification.

Other

ID sylw: 108211

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

In encouraging the use of previously developed land, this Policy Direction aligns with national policy, with Paragraph 124 emphasing that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the Urban Capacity Study is still clear that “significant greenfield development” (including Green Belt) will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.