Yes

ID sylw: 108107

Derbyniwyd: 20/06/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

We support the identified Strategic Objectives at Section 3.2 of the PO Consultation. In particular, we support the identification of the delivery of homes to meet community needs at Strategic Objective 2. It is abundantly clear that housing delivery is of upmost importance to the Government, with the Deputy Prime Minister pointing to our being “in the middle of the most acute housing crisis in living memory”.

No

ID sylw: 108108

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

We do not agree that all of the identified Strategic Growth Locations or Potential New Settlements are supported by sufficient infrastructure to enable their delivery. It is clear that the SWLP recognises at a high level that such provision is integral to the delivery of significant housing and employment sites.
It is noted as part of the consultation that an Infrastructure Delivery Plan (IDP) is being prepared alongside the Local Plan to help identify future infrastructure requirements, costs and when and how infrastructure will be delivered. It is noted that the IDP will also help to coordinate planning and investment in new infrastructure by the two districts and other infrastructure providers and key stakeholders. Part 1 of the IDP forms part of the technical evidence base for the PO Consultation draft of the SWLP. Whilst we appreciate that further work is to be undertaken to determine details of the infrastructure needs for the preferred option, we are concerned at the lack of information contained within the Part 1 IDP. In our view, evidence regarding infrastructure requirements for the strategic growth areas or potential new settlements is a fundamental requirement for their promotion. The absence thereof essentially renders the promotion of certain sites or locations for development over others unsound.
In our view, this amounts to a failure to accord with paragraph 16 of the NPPF, which sets out at part b) that plans should be prepared positively, in a way that is aspirational but deliverable.
Linked to this, we consider it to be a significant failing of the emerging Plan that it appears to prioritise or highlight areas which suffer from a lack of infrastructure, over those which could be seen to offer better opportunities in terms of existing infrastructure.
There is insufficient urban brownfield land to accommodate South Warwickshire’s housing and employment land needs. The majority of the SWLP’s strategic growth needs will be met within priority areas 1 – 3”. We fully support this assessment and consider that robust priorities and strategies need to be developed to respond to this. It is clear that Priority Areas 2 and 3 will need to a significant amount of ‘heavy lifting’ in housing delivery, particularly in light of increased housing as a result of the new standard method (see below).
Critically, we fully support the recognition set out above that the existing urban areas across South Warwickshire do not offer sufficient capacity to meet development needs. This reflects Government rhetoric that whilst the first port of call for development should be brownfield land, it is clear that the delivery of brownfield land for residential development will not be enough to meet our housing needs. In our view, it is critical that the SWLP makes clear at the outset that development will need to extend beyond existing urban limits.

4.1 – Spatial Growth Strategy
• Spatial Growth Strategy

Clearly, whilst the emphasis on urban land chimes with national priorities for the reuse of brownfield land and should be supported, it is imperative that the SWLP is clear about the need to release greenfield land to meet development needs.
The Respondent particularly supports emphasis given to sustainable travel and to the provision of development in proximity to existing rail stations. Given the emphasis on mitigating the impacts of climate change (as per the first overarching principle set out within Section 3.1) and reducing the need to travel by private car in order to reduce carbon emissions, it is the Respondent’s view that in existing settlements in close proximity to existing railway stations – such as Hampton Magna, which lies immediately to the south of Warwick Parkway station – should be prioritised as locations for growth. More specifically, the Respondent’s Site off Old Budbrooke Road is an ideal candidate for future housing development in this regard given is location within walking distance of Warwick Parkway station.
The allocation of land off Old Budbrooke Road would, in our view, respond to national planning priorities as per paragraph 110 of the NPPF, which sets out that “The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”.
• Housing Need
Section 4.1 goes on to set out that “The Spatial Growth Strategy will accommodate South Warwickshire’s housing and employment needs for the period to 2050. T
The December 2024 iteration of the National Planning Policy Framework is clear at Paragraph 234 of Annex 1: Implementation that “for the purpose of preparing local plans, the policies in this version of the Framework will apply from 12 March 2025”. There are some exceptions, none of which apply to the SWLP. On this basis, it is fundamental that the SWLP sets out housing need in line with the new Standard Method.
As per the new Standard Method, housing need has increased in Stratford-on-Avon from 553 units per annum to 1,126 units per annum (+103%) and in Warwick DC from 653 units per annum to 1,062 units per annum (+62.6%). This significant increase in housing need further heightens the importance of the Council looking to suitable and sustainable greenfield sites to deliver housing, given the acceptance that urban land could not meet even the lower demand, which was assessed in 2022, as per the Urban Capacity Study.

No

ID sylw: 108109

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

As per the December 2024 NPPF, there is no validity in the SWLP responding to the HEDNA derived housing need figure. It must take as a baseline the new Standard Method derived figure of 2,188 units per annum (combining the figures for Stratford on Avon and Warwick DC). Accordingly, we do not support the inclusion of Table 2 within the draft SWLP, given that this sets out the housing calculation using the HEDNA method.
• Windfall Development
Table 3 (Housing calculation 2024 NPPF standard method) identifies a total housing need across the plan period of 54,700 for South Warwickshire, with assumed windfall allowance across the plan period contributing 9,375 to this figure, or 17.1% of the total need.
Such an overreliance on windfall provision is simply unacceptable and would render the SWLP unsound. Leaving almost one fifth of housing land supply to chance is not plan-led. As such, additional allocations are required to respond to housing need. Furthermore, the identified quantum of windfall housing fails to incorporate a lapse rate and is taken from 2025 rather than from the anticipated Plan commencement date, effectively resulting in double counting. In our view, the inevitable consequence of these matters is to further compound the need for the identification of additional site allocations in the face of likely shortfall of provision.

Other

ID sylw: 108110

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

We are of the view that the growth of existing settlements should be prioritised within the overall growth strategy for South Warwickshire, as opposed to the delivery of new settlements. This is on the basis that sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter timeframe.
In this context, the Respondent’s Site represents a sustainable and logical extension capable of being developed without technical impediment, and which would assist in supporting existing facilities and services within the town. Such matters are discussed further within the site-specific representations at Section 3 of this document.

Yes

ID sylw: 108111

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

We fully support the need for the SWLP to contribute to meeting unmet housing need from neighbouring authorities. In our view, sustainable sites, including the Site off Old Budbrooke Road, are likely to be very well placed to respond to such need, particularly where those sites are located in close proximity to key transport nodes.

Other

ID sylw: 108112

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

It is in our view imperative that the SWLP deals head on with the fact that the release of existing Green Belt land will be required to meet development needs over the Plan period. Such a case is not made clearly at section 4.9, and we strongly recommend that this is remedied in the forthcoming Regulation 19 Consultation draft of the Plan.
We support the recognition at Section 4.9 that “Some of South Warwickshire’s most sustainable locations fall within the Green Belt. For example, all of our train stations are either in or close to the Green Belt. This means that in order to deliver a truly sustainable pattern of growth, the SWLP needs to consider all options, including Green Belt options”. This was a point made in our previous representations and reflects the direction of travel contained within Government rhetoric regarding Green Belt land.
Chapter 13 of the NPPF refers to ‘Protecting Green Belt land’, with paragraph 146 clearly setting out that an authority’s inability to meet its identified need for homes would be considered to constitute ‘exceptional circumstances’ justifying the alteration of Green Belt boundaries. We recommend that due regard is given to national policy in the drafting of the SWLP, given the relevance of this particular element of the NPPF to the situation in South Warwickshire.
Paragraph 148 of the NPPF goes on to set out that where it is necessary to release Green Belt land for development, “plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations”. As previously set out and accepted by the Councils in their evidence base and emerging SWLP, there is insufficient previously developed land to meet development needs. Attention must therefore turn to greenfield and inevitably to land currently located within the Green Belt where this offers the most sustainable opportunities for development.

Other

ID sylw: 108113

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

Whilst we support the principle of the above, the Respondent would caution that the delivery of accessible units should be considered on a case by case basis, given the potential implications for the density of development and development viability.

Other

ID sylw: 108114

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

Whilst we support the thrust of this section of the draft Local Plan and the identification of Strategic Objective 6 – Contributing towards Net Zero Carbon targets, we would flag that all policy requirements should accord with national requirements. This is as per the 13th December 2023 Written Ministerial Statement which sets out at paragraph 2.43 that “the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned building regulations” because “the proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexities and undermining economies of scale.” The WMS confirmed that “any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly costed rationale”.

Other

ID sylw: 108115

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

Land off Old Budbrooke Road, Hampton Magna
We can confirm that the land which comprises the Site is under the unified control of William Davis Homes and is available for residential development.
The Site is located at to the west of the village of Hampton Magna at land off Old Budbrooke Road. Hampton Magna is located approximately 3 miles to the west of Warwick and lies within the Parish of Budbrooke within Warwick District.
The village is relatively small, and its appearance is of its time, but it has a good range of services.
The Site itself comprises approximately 21.1 hectares of predominantly arable land, with some pasture and horticulture activity. As above, of note is its proximity to Warwick Parkway Rail Station, which is situated on the north-western side of Warwick and within a 10-minute walk of the site, along a footway that runs the entire length of Old Budbrooke Road.
There are no technical impediments to the development of the Site for residential use.

Hampton Magna is one of only a small number of settlements that benefit from an existing rail station with frequent services to a major urban centre (in this case Warwick, Birmingham and London) and, aside from the Green Belt, is relatively unconstrainted.

We are firmly of the view that the Site presents the most logical, accessible and sustainable opportunity for a strategic extension to Hampton Magna, consistent with the historic evolution of the settlement and benefiting from close proximity to the range of facilities located within the village, and therefore should be released from the Green Belt for residential development. The following points are key to our justification of the above:
- The Site is within a 10-minute walking distance of Warwick Parkway Station, demonstrably allowing the use of existing infrastructure without significant investment being required.
- The site is of a sufficient scale and character to enable the delivery of biodiversity net gain in line with local and national requirements.
- In line with its release from the Green Belt (see further discussion and assessment below), development of the site would be expected under the NPPF to deliver a higher rate of affordable housing (currently 50% as per NPPF paragraph 67 part b), unless this would make development unviable. This would make an important contribution to meeting the strategic objective of the SWLP to deliver affordable housing;
- As a housebuilder, William Davis are committed to energy efficiency. All homes are designed with this as a priority, and this would be carried forward to development on the site;
-It is noted that any LWS would be retained, and development offset to ensure no impact.
Conversely, other emerging allocations in proximity to Hampton Magna would not reap the same benefits in terms of efficient access to Warwick Parkway Station, or indeed to existing services and facilities. Other sites are also noted as being significantly impacted by areas at a high risk of flooding with the potential for development therefore necessarily being viewed through the lens of the NPPF which seeks to steer new development to areas with the lowest risk of flooding from any source. We are also concerned that the development of other identified sites could result in the coalescence of settlements and the loss of important separation spaces.
Green Belt Assessment
The Stage 1 Green Belt Review which forms part of the evidence base underpinning the SWLP provides an assessment of selected parcels of land surrounding Hampton Magna (HMG1 – HMG5) and Warwick (WWK1 – WWK6). For the purposes of the assessment, the Respondent’s site falls within Parcel HMG4, which comprises land north and west of Old Budbrooke Road, west of church lane, adjacent to Hampton Magna. The assessment notes that: “The parcel makes a moderate contribution to two purposes, and no contribution to three purposes. Overall, the parcel makes a weak contribution to Green Belt purposes”.
As per the above, the parcel of land within which the Respondent’s site falls has been assessed as making no contribution to Green Belt purposes A, B and D. National planning policy contained within the National Planning Policy Framework sets out that “for the purposes of plan-making and decision-making, ‘grey-belt’ is defined as land in the Green Belt comprising previously developed land and / or any other land that, in either case, does not strongly contribute to any of purposes (a), (b) or (c) in paragraph 143. ‘Grey Belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development”.
Paragraph 148 of the NPPF is clear that “Where is it necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed land, and then other Green Belt locations”. On this basis, the Respondent’s Site represents a clear opportunity for development which should be prioritised over other Green Belt sites.
Additional Planning Practice Guidance published on 27 February 2025 sets out further guidance as to the identification of grey belt land in relation to the contribution that assessment areas make to Green Belt Purposes A, B and D. Critically, it is noted that all of these purposes relate to the consideration of towns rather than villages and would therefore not be considered applicable in the case of Hampton Magna as per the latest PPG
. In terms of the second part of the Grey Belt definition and the reference to footnote 7, the site is not restricted by any of the identified designations. On this basis, we would therefore consider that the Site could be identified as comprising as Grey Belt. It follows therefore that, subject to development of the Site not being found to fundamentally undermine the purposes of the remaining Green Belt across the plan area, development on the Site would be considered acceptable dependent on further considerations including the sustainability of its location (which has been rehearsed above) and accordance with the ‘Golden Rules’ as per the NPPF.
This section of the representations has sought to promote the site at Old Budbrooke Road for residential development, in line with the increasing housing need faced by the Councils and the critical requirement to find sustainable and accessible sites.
Importantly, the Site is considered to comprise potential Grey Belt land and a clear opportunity for Green Belt release in light of national planning policy and guidance.