No

ID sylw: 108242

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

A 3km buffer zone around the Cotswolds National Landscape is proposed. Two of South Warwickshire’s most sustainable locations for growth fall within this potential buffer - Shipston-on-Stour and land at Long Marston, which are identified as a Strategic Growth Location (SG17) and Potential New Settlement (E1) respectively.

The comment from the Cotswolds National Landscape Board as part of the Issues & Options consultation, which predictably advocated for the implementation of a buffer, appears to have strongly influenced the Councils in formulating this policy direction, but there is no basis for a National Landscape buffer in national policy, nor has any evidence been provided to suggest that this is needed. Notably, the Cotswolds National Landscape Management Plan 2023 – 2025 does not refer to a buffer nor suggest that one should be established by local authorities. The Management Plan already serves as a material consideration in the determination of planning applications within the National Landscape and its setting in South Warwickshire, and it is contended that the current policy approach with regards to the National Landscape in the Stratford Core Strategy, which referred to the Management Plan, should be carried over. There is no evidence or justification for the SWLP Part 1 to go beyond the provisions of the Management Plan in implementing a buffer, and development should certainly not be precluded in sustainable locations where schemes can be designed in a manner which does not adversely impact on the National Landscape and its setting.

No

ID sylw: 108243

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Evidence still needs to be prepared on which parts of South Warwickshire merit a Special Landscape Area designation.

It is important to emphasise that such a designation would be inconsistent with national guidance and policy, within which it has no basis. It is also noteworthy that Special Landscape Areas are not included in Natural England's approach.

Paragraph 187 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes’. It is considered that the special landscape character across South Warwickshire can be suitably conserved and enhanced through a generic landscape policy, without the need to create an additional landscape designation, which would require yet another study to be undertaken to form part of the evidence base.

If the Councils do wish to proceed with Special Landscape Areas regardless of the above, it is imperative that these do not restrict development in what may be sustainable locations for growth. The policy direction currently recognises this; thus, this aspect is supported.

No

ID sylw: 108244

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This policy direction is broadly supported, with it generally aligning with the aspirations in the NPPF with regards to the protection and enhancement of landscapes, set out in, for example, Paragraph 187. However, it should be noted that Paragraph 135(c) does state that whilst development should be sympathetic to the surrounding landscape, this should not prevent or discourage appropriate innovation or change, such as increased densities. This should be acknowledged within the policy. It is affirmed that it is unnecessary for all major developments to provide Landscape and Visual Impact Assessments (LVIA) as currently suggested. This will need to be fully justified, and such justification has not been provided within the Preferred Options document. The need for an LVIA should be considered on a case-by-case basis, and/or specific criteria for when one is required should be prepared by the Councils.

Yes

ID sylw: 108245

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Para 187 b) of the NPPF states 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 … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. As such, it is considered that a policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising that there may be circumstances in which development on best and most versatile (BMV) land is appropriate, and thus cases when the planning balance favours approval. In particular, the fact that an exception will be made for the Strategic Growth Locations and New Settlement Sites, with the protection of BMV land not being a consideration, is strongly supported. This will ensure that the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both sites which are allocated in the Pre-Submission plan, and those which are not, with them having already been identified as suitable locations for growth in the Preferred Options document. The SA does not suggest that any negative impacts would arise from excepting sites from this policy.

Yes

ID sylw: 108246

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Land east of Loxley Road, Wellesbourne forms part of the ‘South of Wellesbourne Group’ Strategic Growth Location and is split across Priority Areas 1 and 2. It has been assessed positively in both Parts A and B in the HELAA. Furthermore, it is sustainable location for further housing, as suggested by the Strategic Growth Location’s relatively favourable assessment in the Sustainability Appraisal. It is deliverable, being suitable, achievable, and available, meaning that it is able to be brought forward to meet the South Warwickshire’s housing need, including for affordable homes, in the early part of the plan period. The appended Vision Document illustrates how the Site could be brought forward to deliver a high-quality residential development consisting of approximately 300 dwellings, along with play areas, open space, and sustainable drainage, which supports and aligns with the draft vision and strategic objectives.

Yes

ID sylw: 108247

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Land north of the A46, Stratford-upon-Avon forms part of the ‘West of Stratford-upon Avon Group’ Strategic Growth Location and it is entirely within Priority Area 1, highlighting that growth here would accord with the spatial strategy in the most preferential of locations in this respect. It has been assessed positively in both Parts A and B in the HELAA. Furthermore, it is sustainable location for further housing, particularly when considered in isolation against the SA Framework, rather than as part of the wider Strategic Growth Location. The conclusions of the Green Belt Review mean that the Site can be considered grey belt, and is thus sequentially preferable for release and allocation, in line with Paragraph 148 of the Framework. The Site can comply with the requirements of Paragraph 155 of the NPPF as the ‘Golden Rules’ can be met, through the provision of a high proportion of affordable housing, infrastructure improvements as necessary, and new, or improved, green spaces. It is deliverable, being suitable, achievable, and available, meaning that it is able to be brought forward to meet South Warwickshire’s housing need, including for affordable homes, in the early part of the plan period. The Site could be brought forward to deliver a high-quality residential development consisting of approximately 135 dwellings, which supports and aligns with the draft vision and strategic objectives.

Yes

ID sylw: 108248

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Persimmon have land interests south west of Studley. The northwestern half of the Site forms part of the ‘West of Studley Group’ Strategic Growth Location and parcels within the site boundary have been assessed positively in both Parts A and B in the HELAA. This is a sustainable location for further housing, as confirmed by the Strategic Growth Location’s highly favourable assessment in the Sustainability Appraisal, and the fact that it falls within Priority Areas 1, 2, and 3. We contend that the south eastern half of the Site, which was not included largely as was not submitted in the earlier Call for Sites exercise, would perform in a similarly exceptional manner against the SA Objectives. A wider area of adjoining land is also available that would allow for additional development to the south west of Studley. This is also within the Strategic Growth Location and Priority Areas 1, 2, and 3, and was likewise positively assessed in the HELAA. This should be taken into account as part of the SWLP preparation going forward, and an updated Development Framework Plan, Vision Document, and technical work incorporating the wider site can be provided.

The Green Belt Review highlights that the Site is grey belt by definition, and is thus sequentially preferable for release and allocation, in line with Paragraph 148 of the Framework. The Site can comply with the requirements of Paragraph 155 of the NPPF as the ‘Golden Rules’ can be met, through the provision of a high proportion of affordable housing, infrastructure improvements, and green spaces. The Site is deliverable, being suitable, achievable, and available, meaning that it is able to be brought forward to meet the South Warwickshire’s housing need, including for affordable homes, in the early part of the plan period. The appended Vision Document illustrates how the Site could be brought forward to deliver a high-quality residential development, plus an array of benefits including infrastructure and junction improvements, new open spaces, playing pitches, and a primary school, which supports and aligns with the draft vision and strategic objectives of the SWLP Part 1, and can comprehensively resolve a range of problems facing Studley at the present time.