Other

ID sylw: 108308

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG Land Promotion III (UK) Limited (hereafter “CEG”) and Mixed Farms, control land on the south-eastern edge
of Stratford-upon-Avon (“the site”). The site has been previously promoted and submitted to the Call for Sites
exercise and is identified within the South Warwickshire Local Plan Preferred Options Consultation (“SWLP”)
within Strategic Growth Location SG19 – East of Stratford-upon-Avon. Representations were also made to:
 South Warwickshire Local Plan Scoping and Call for Sites consultation in June 2021; and
 South Warwickshire Local Plan Issues and Options consultation in March 2023.
The site comprises 102 hectares of land on the south-eastern edge of Stratford-upon-Avon. It is an appropriate
location for a major residential-led mixed use development, with potential for an initial short-term phase
(included as a Reserve Site in the Revised Preferred Options Consultation of the Stratford-upon-Avon Site
Allocations Plan – ref: STR.D (SAP)) that could be delivered early within the Plan period, without prejudicing wider
growth of this strategic opportunity. CEG and Mixed Farms’ element of SG19 can deliver development
comprising:
 Circa 1,200 market and affordable dwellings;
 Significant community infrastructure provision including a neighbourhood centre, primary school, sports
pitches, public parkland and biodiversity parkland;
 A genuinely landscape-led approach that mitigates any impact on the Alverston Hill vantage point and
important views;
 A substantial network of green infrastructure with green corridors that will provide opportunities for
sustainable travel and recreation. This will build upon a local neighbourhood concept;
 New movement corridors to help address existing traffic and associated environmental issues within
Stratford-upon-Avon itself and create strong, direct links with the economic growth aspirations at
Wellesbourne as identified within the SWLP and demonstrated through the recently submitted planning
applications as detailed above;
 Avoiding residential development within the safeguarded zone of the high-pressure gas pipeline; and
 Strong connectivity to Stratford-Upon-Avon through improved linkages along Banbury Road.
These representations are made specifically in the context of CEG and Mixed Farms’ interest in land identified by
the Plan as SG19, which is listed in Chapter 4 of the SWLP as a Strategic Growth Location and is therefore
considered within the Interim Sustainability Appraisal (the “Interim SA”) supporting the SWLP Preferred Options
Consultation. CEG and Mixed Farms’ representations concentrate on matters that are relevant to the spatial
strategy of the Plan and the options proposed for future growth of South Warwickshire.
The representations follow the structure of the Regulation 18 Preferred Options consultation document, providing
responses under the topics and questions identified, as relevant.

Yes

ID sylw: 108309

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms support the Plan’s Vision and objectives, which determine how development will be
delivered. The CEG and Mixed Farms proposals for East of Stratford-upon-Avon are considered against each of
these principles to demonstrate how the site’s development can help to achieve the vision.
A climate resilient and Net Zero Carbon South Warwickshire – The proposed development at the site will
contribute to a low carbon and climate resilient development from construction to occupation through
sustainable materials and construction techniques, renewable energy measures, sustainable drainage systems
within a comprehensive blue-green infrastructure network and mobility strategy. Furthermore, in taking
advantage of two key attributes, size (strategic growth) and location (on the edge of one of the largest and most
sustainable settlements in South Warwickshire), the site off Banbury Road will include numerous measures and
strategies to encourage local living and support the initiative of 15-minute neighbourhoods.
A Transport Note prepared by Vectos and appended to these representations at Appendix 1 outlines how the site
can contribute to climate resilience through:
 Creation of critical mass to allow good levels of internal living and enhancing existing communities;
 Making use of the excellent existing facilities for travel choice into Stratford-upon-Avon by active travel
modes;
 Placing cycling and walking at the highest priority, followed by public transport;
 Placing development in an area close to existing and emerging employment options accessible by walking,
cycling and public transport;
 Proposing improvements to public transport infrastructure;
 Providing future proofed development which is adaptable to meet the demands of electric and/or
hydrogen vehicles;
 Promoting local living and 15-minute neighbourhoods where people can meet their everyday needs
within a short walk or cycle;
 Creation of mobility hubs with facilities to encourage use for charging of electric vehicles, cycle parking,
remote working, carpooling and leisure.
The site can improve existing infrastructure and generally promote a culture of change towards active travel
which in turn aids the climate resilience of South Warwickshire.
A well-designed and beautiful South Warwickshire – Development at the site will provide for a mix of housing
types and tenures to encourage diverse and intergenerational communities; it will deliver both physical and social
infrastructure to benefit existing and future residents and support the growth of the town as a whole; create
homes with gardens that combine the best of town and country to create healthy communities; and, where
possible, retain and enhance existing landscape features including hedgerows and tree belts.
A healthy, safe and inclusive South Warwickshire - The site will create a development premised on a walkable
garden community, providing both a range of housing to meet identified needs, and community facilities, focused
around a mixed use centre with primary school, convenience and community facilities, mobility hub and potential
for live/work community hubs supporting both the development and surrounding villages. This will be set within a
substantial green infrastructure network which will allow enjoyment of the opportunities created and lead to
increased physical and mental health.
The sustainable travel initiatives set out within the Transport Note will help to foster a sense of community,
activating streets through cycling and walking creating a safe environment of active residents. Through the
proposals to create a substantial green infrastructure network, the community will be attractive for residents and
visitors to pursue active travel opportunities in a pleasant and safe environment.
A well-connected South Warwickshire - The site will take advantage of the excellent existing facilities for travel
choice into Stratford-upon-Avon by active travel and public transport modes and enhance these routes where
needed through careful design and investment in sustainable infrastructure which will promote longevity. This
means that the site can place walking and cycling at the highest priority, followed by travel by public transport,
and develop a community where there is little reliance on the private car and increased reliance on active and
public transport modes.
A biodiverse and environmentally resilient South Warwickshire – The conceptual framework for the site,
attached at Appendix 2 shows the retention of existing landscape features including hedgerows and tree belts
and, in addition, shows a considerable biodiversity parkland, public parkland, and a network of swales. The site
can be developed whilst delivering a 10% net gain of biodiversity in accordance with the requirements of the
Environment Act.
The 12 Strategic Objectives
In addition, the Plan includes 12 strategic objectives which reflect the area’s social, environmental and economic
issues. Where relevant, CEG and Mixed Farms provide comment below on how development at South East
Stratford-upon-Avon can help to meet the Plan’s objectives:
• SO1: Providing sustainable levels of growth in the area; and
• SO6: Contributing towards Net Zero Carbon targets.
The site is located on the edge of one of the principal and most sustainable settlements in South Warwickshire,
and one of the Urban Areas of the Plan area as shown on Figure 5 of the SWLP. It benefits from easy access to a
range of services and facilities. Critically, the entirety of the site lies outside of the Green Belt, is not subject to any
landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets.
The NPPF sets out at paragraph 145 that ‘…Green Belt boundaries should only be altered where exceptional
circumstances are fully evidenced through the preparation or updating of plans.’
For plan-makers to reach a point where exceptional circumstances can be demonstrated, paragraph 146 confirms
that this can include ‘…instances where an authority cannot meet its identified need for homes, commercial or
other development through other means’
And at paragraph 147 ‘Before concluding that exceptional circumstances exist to justify changes to Green Belt
boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all
other reasonable options for meeting its identified need for development.’
This assessment of whether all other reasonable options have been examined will take account, according to
paragraph 147, of whether the strategy:
“a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including
whether policies promote a significant uplift in minimum density standards in town and city centres and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some
of the identified need for development, as demonstrated through the statement of common ground.”
The NPPF clearly sets out a sequential approach to allocating land for development within the Green Belt –
essentially dictating that utilising Green Belt land should be a ‘last resort’, where there are no other options to
accommodate the required growth, or that non-Green Belt land including land classified as Grey Belt, is not
abundant enough to meet growth requirements – as set by the Standard Method – in full. CEG consider the
sequential approach to be particularly relevant in relation to Stratford-upon-Avon, given the availability of
sustainably located land (SG19) outside of the Green Belt.
The site is located adjacent to and north of the A422 Banbury Road and would form a natural extension to the
existing residential area to the east of Stratford-upon-Avon. It benefits from having direct frontage along the A422
thus enabling a new junction to be accommodated to access the development which links into existing footways.
A number of local facilities including Bridgetown Primary School, recreational pitches, convenience food stores,
pharmacies are in the immediate vicinity of the site. The town centre of Stratford-upon-Avon offering a range of
high street retailers, restaurants and leisure facilities is within 2km of the site. Local buses travel along A422
Banbury Road as well as A4390 Trinity Way. Local bus stops are within an acceptable walking distance from the
site along Banbury Road making public transport a genuine option for travel.
Further, given the scale of potential growth a viable public transport strategy can be delivered as set out by the
Transport Note, which outlines the potential for Demand Responsive Transport (DRT), a flexible service which
allows residents to book a journey using an on-demand bus service, diversion of an existing bus service (15) into
the site; or providing a new bus service to serve the site and local area to further enhance the site’s sustainability
and provide wider public benefits.
The site benefits from excellent pedestrian infrastructure with continuous footways on both sides of A422
Banbury Road into Stratford-upon-Avon. Similarly, both A422 Banbury Road and the A4390 Trinity Way provide
cycle infrastructure in the form of on-carriageway cycle lanes (A422) and a shared traffic-free cycleway/footway
on the norther side of the A4390. The shared route extends from the roundabout junction with A422 Banbury
Road to the immediate west of the site to the roundabout of the A4300/Severn Meadows Rd roundabout further
west. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages.
The site’s location outside the Green Belt, adjacent to a principal urban area and with a lack of constraints ensures
that it lies in a geographical location where the SWLP objective to promote sustainable growth can be met.
• SO2: Delivering homes that meet the needs of all our communities; and
• SO10: Improving the health, safety and quality of life of our communities.
Development at SG19 – East of Stratford-upon-Avon would deliver approximately 1,200 new market and
affordable homes in a variety of types and tenures to assist the area in meeting its housing needs.
• SO3: Providing infrastructure in the right place at the right time; and
• SO11: Connecting people to places.
Development would help facilitate the delivery and provide financial contributions towards the Eastern Relief
Road (ERR) around Stratford-upon-Avon, as required. This would deliver significant social and economic benefits
locally and at the sub-regional level.
The Infrastructure Delivery Plan (IDP) published within the evidence base of the SWLP draws upon The Stratfordupon-
Avon Transport Strategy confirming at page 34 that ‘Stratford-upon-Avon frequently suffers from traffic
congestion, particularly during the morning and evening weekday peaks, as well as congestion associated with
tourist traffic, predominantly on summer weekends, bank holidays and during major events.’
Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider
the substantial benefits that can be delivered through large scale growth to the south east of Stratford-upon-
Avon, in particular supporting the delivery of the ERR, a strategic piece of infrastructure which would connect
Banbury Road to Wellesbourne Road, noting that paragraph 11a of the NPPF states that plans should positively
seek opportunities to meet the development needs of the area. As set out within the Transport Note, this
proposed ‘Movement Corridor’ will simplify journeys of all modes towards Wellesbourne, where major economic
growth is planned without adding further pressure to routes in Stratford-upon-Avon town centre.
At Wellesbourne, only approximately 5km from the site, the University of Warwick propose an ‘innovation
campus’, the outline planning application was submitted in December 2024 supported by an adopted SPD for the
site If approved, this development will generate:
 4,113 full time operational jobs
 1,748 part time operational jobs
 314 temporary jobs during the construction phase
 £1.34 billion of operational gross value added
In addition, at Wellesbourne Mountford Airfield, Gladman Developments Ltd have submitted an application for
aviation led development which would deliver general industrial, storage and distribution, commercial, research
and development and light industrial floorspace in addition to accommodation for airfield tenants. Overall,
165,000 sqm of employment floorspace is proposed and this would generate:
 Between 1,228 and 1,625 operational jobs
 217 temporary jobs during the construction phase
 Between £68.8 million and £91.1 million per year to the local economy
The opportunity to improve connections between the largest settlement in Stratford-on-Avon and the significant
economic investment and associated benefits at Wellesbourne can only be capitalised on through the allocation
of land East of Stratford-upon-Avon for development and subsequent delivery of the ‘Movement Corridor’
between Banbury Road and Wellesbourne Road, alongside the delivery of homes to meet the demand for
sustainable co-located employment and housing.
Development at SG19 – East of Stratford-upon-Avon could, if necessary, contribute towards expansion and
improvement to schools, healthcare, sports and community facilities and waste management. Improvements to
local utility facilities and infrastructure would also be required to facilitate development, benefitting both existing
and new residents.
 SO5: Making effective use of land and natural resources
The NPPF is clear that the priority is to make effective use of land in meeting the need for homes and other uses
in a way that prioritises previously developed land. However, the SWLP is clear at Section 4.1 (Spatial Growth
Strategy) that there is insufficient brownfield land available to meet the South Warwickshire’s growth
requirements and so it is important that the SWLP looks to accommodate growth on sustainable sites which are
capable of delivering housing growth in effective ways, minimising impacts on natural resources. One way of
achieving this is to allocate land in sustainable locations adjacent to well-located settlements offering an array of
services to future residents, such as Stratford-upon-Avon.
As set out earlier in the response to this question, the NPPF clearly sets out a sequential approach for plan-making
when selecting land for allocation. As the SWLP accepts, there is insufficient brownfield land available to meet
development needs (and CEG and Mixed Farms acknowledge it is likely that some Green Belt land will need to be
considered for allocation) it is important that before assessing and allocating Green Belt land, sustainably located
non-Green Belt options should be considered first.
Therefore, the site’s location outside the Green Belt, adjacent to a principal urban area and with a lack of
constraints ensures that it lies in a geographical location where the SWLP objective to make effective use of land
can be met.
 SO7: Creating attractive places
Development at East of Stratford-upon-Avon would be delivered in accordance with national and local planning
policies and guidance which seek to create attractive places. CEG and Mixed Farms are confident that a
sustainable and well-designed extension to Stratford-upon-Avon could be delivered through allocating a
comprehensive parcel of land to the South East of Stratford-upon-Avon, which would allow for placemaking
principles such as walkable neighbourhoods, designed character areas and green infrastructure to be fully
explored, as per NPPF paragraph 77 which states:
“The supply of large numbers of new homes can often be best achieved through planning for larger scale
development, such as new settlements or significant extensions to existing villages and towns, provided they are
well located and designed…”
CEG and Mixed Farms control the largest element of SG19 and this is beneficial for both placemaking and ease of
delivery, with no complex delivery agreements required to ensure that at least 1,200 dwellings can be delivered
on the site within a single ownership.
 SO8: Protecting and enhancing our heritage and cultural assets; and SO12: Protecting and enhancing our
environmental assets.
The SWLP ensures that appropriate environmental considerations have been made when considering and
assessing the options to accommodate future development. East of Stratford-upon-Avon, if allocated, can be
delivered alongside mitigation to ensure that heritage and cultural assets are sufficiently protected in line with
SO8. This is explored further in the response regarding the Interim SA.
CEG and Mixed Farms’ element of SG19 can be delivered without causing impact on environmental assets – there
are no ecologically important sites within or adjacent to the site, it lies entirely within Flood Zone 1; although
there is a small area of the site to the south which is susceptible to surface water flooding. This can be
satisfactorily mitigated through design, layout and specific drainage design. Development can be delivered to
secure the mandatory levels of biodiversity net gain (BNG), and mitigation for any protected species, should any
be discovered, can be secured via planning application in the future.
The detailed masterplanning of the layout, design and landscaping of a scheme on land controlled by CEG and
Mixed Farms in isolation ensure that any remaining impacts are suitably mitigated.

Yes

ID sylw: 108310

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

Yes – Stratford-upon-Avon lies within the Spatial Growth Priority Area as set out in Figure 5 and therefore as an
extension to it, SG19 would contribute to growth in a priority area.
One of the main benefits of this option is that it co-locates jobs and homes in sustainable locations, giving more
people the option of living close to their place of work. This reduces commute times and makes active travel
options more appealing, which can contribute to a more sustainable community.
In addition, the provision of housing in close proximity to and with good accessibility to Stratford-upon-Avon
town centre and the strategic growth proposed at Wellesbourne, through the opportunity to connect Banbury
Road to Wellesbourne Road, providing enhanced connectivity between the two routes would assist in capitalising
on the economic growth potential at Stratford-upon-Avon and Wellesbourne.
As set out within the Transport Note, the proposed ‘Movement Corridor’ will simplify journeys of all modes
towards Wellesbourne, where major growth is planned without adding further pressure to routes in Stratfordupon-
Avon town centre.
At Wellesbourne, only approximately 5km from the site, the University of Warwick propose an ‘innovation
campus’, comprising up to 280,000 sqm of laboratory, office and light industrial floorspace with ancillary
development, the outline planning application for the site was submitted in December 2024 and is supported by
an adopted Masterplan SPD. If approved, this development will generate:
 4,113 full time operational jobs
 1,748 part time operational jobs
 314 temporary jobs during the construction phase
 £1.34 billion of operational gross value added
In addition, at Wellesbourne Mountford Airfield, Gladman Developments Ltd have submitted an application for
aviation led development which would deliver general industrial, storage and distribution, commercial, research
and development and light industrial floorspace in addition to accommodation for airfield tenants. Overall,
165,000 sqm of employment floorspace is proposed and this would generate:
 Between 1,228 and 1,625 operational jobs
 217 temporary jobs during the construction phase
 Between £68.8 million and £91.1 million per year to the local economy
CEG and Mixed Farms’ proposed development for East of Stratford-upon-Avon would co-locate employment and
housing and would include a neighbourhood centre providing a school, convenience and community facilities,
mobility hub and potential for live/work community hubs supporting both the development and surrounding
villages.
At a local level, SG19 is located on the edge of the principal and most sustainable settlement in Stratford-on-Avon
District and benefits from easy access to a range of services and facilities. It is not subject to any landscape
designations, is located within Flood Zone 1 and does not contain any designated heritage assets.
The site is located adjacent to and north of the A422 Banbury Road and would form a natural extension to the
existing residential area to the east of Stratford-upon-Avon. It benefits from having direct frontage along the
A422 thus enabling a new junction to be accommodated to access the development which links into existing
footways.
A number of local facilities including Bridgetown Primary School, recreational pitches, convenience food stores
and pharmacies are in the immediate vicinity of the site. The town centre of Stratford-upon-Avon offering a
range of high street retailers, restaurants and leisure facilities is within 2km of the site. Local buses travel along
A422 Banbury Road as well as A4390 Trinity Way and local bus stops are within a comfortable walking distance
from the site along Banbury Road making public transport a genuine option for travel.
The site benefits from excellent pedestrian infrastructure with continuous footways on both sides of A422
Banbury Road into Stratford-upon-Avon. Similarly, both A422 Banbury Road and the A4390 Trinity Way provide
cycle infrastructure in the form of on-carriageway cycle lanes (A422) and a shared traffic-free cycleway/footway
on the norther side of the A4390. The shared route extends from the roundabout junction with A422 Banbury
Road to the immediate west of the site to the roundabout of the A4300/Severn Meadows Rd roundabout further
west. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages.
Development at East of Stratford-upon-Avon would provide a significant level of market and affordable housing
and supporting community infrastructure. It would also help facilitate the delivery and provide financial
contributions towards the ERR. This would, in its own right, deliver significant social and economic benefits locally
and at the sub-regional level.
Given that the SWLP now has a remit of exploring strategic growth opportunities, it should comprehensively
consider the substantial benefits that can be delivered through large scale growth south east of Stratford-upon-
Avon, in particular supporting the delivery of an eastern relief road, a strategic piece of infrastructure, noting that
paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs
of their area.
Having regard to the above, CEG and Mixed Farms proposes to prepare a detailed Vision Document for the site,
which will be supported by a range of technical work to demonstrate how the site could successfully deliver a
residential-led mixed use development on the edge of the largest and most sustainable settlement in Stratfordon-
Avon District. At this stage, a ‘Site Constraints and Opportunities Plan and Conceptual Framework’ prepared
by Define is provided (see Appendix 2 to these representations) to outline how development of the site could
sustainably be delivered. This demonstrates that the site in CEG and Mixed Farms’ control can address site
specific considerations, comprising the following:
 Circa 1,200 market and affordable dwellings;
 Significant community infrastructure provision including a neighbourhood centre, primary school, sports
pitches, public parkland and biodiversity parkland;
 A genuinely landscape-led approach that mitigates any impact on the Alverston Hill vantage point and
important views;
 A substantial network of green infrastructure with green corridors that will provide opportunities for
sustainable travel and recreation. This will build upon a local neighbourhood concept;
 New movement corridors to help address existing traffic and associated environmental issues within
Stratford-upon-Avon itself and create strong, direct links with the economic growth aspirations at
Wellesbourne as identified within the SWLP and demonstrated through the recently submitted planning
applications as detailed above;
 Avoiding residential development within the safeguarded zone of the high-pressure gas pipeline; and
 Strong connectivity to Stratford-Upon-Avon through improved linkages along Banbury Road.
CEG and Mixed Farms would welcome the opportunity to discuss our proposals for the site in more detail, once
the Vision Document and associated technical work has been completed.
Interim Sustainability Appraisal
The site is assessed in the Interim Sustainability Appraisal of the South Warwickshire Local Plan (the “interim SA”)
alongside 23 other potential Strategic Growth Locations (“SGL”) considered as Reasonable Alternatives.
According to paragraph 5.1.1 of the Interim SA the SGLs are expected to meet a proportion of the identified
housing and employment needs for the SWLP period 2025-2050.
SG19 (East of Stratford-upon-Avon) is considered as a mixed-use site across 229.19 hectares (ha) and with an
estimated housing capacity of 5,469 dwellings. CEG and Mixed Farms represents the largest portion of SG19 and
is in single ownership with no legal restrictions which could affect development. To ensure that future
development is unencumbered by legal issues relating to equalisation and/or complex collaboration agreements
between landowners, the various ownership parcels of SG19 should be allocated individually for development,
rather than collectively under one allocation.
Of the 24 SGLs considered within the Interim SA, two (including SG19) are within Stratford-upon-Avon with the
other being SG18 (West of Stratford-upon-Avon). In addition, the Interim SA also considers a series of potential
New Settlement Locations (NSL), including ‘E1: Long Marston Airfield’ located approximately 2.3km south west of
the southern extent of SG19.
Section 4.2 of the SWLP outlines that a new settlement aims to deliver a new community capable of fulfilling
‘most of its day-to-day needs within the settlement itself, limiting the need to travel.’ Whilst CEG and Mixed
Farms acknowledge the potential benefits of a new settlement, which provides many of the services residents,
employees and visitors require, provision of a new settlement at Long Marston Airfield would not eliminate the
need for road connections to and from the settlement from the A46/M40 via Stratford-upon-Avon.
Indeed, the existing development at Long Marston Airfield, notwithstanding the proposal within the SWLP to
create a new settlement, requires additional highways infrastructure to be provided which is still not
forthcoming. Long Marston Airfield as allocated within the Stratford-on-Avon Core Strategy must deliver ‘a
connection to the strategic highway network (A46) at Wildmoor through the construction of a south-western
relief road between A3400 Shipston Road and B439 Evesham Road together with a road between B439 and A46
Alcester Road to be provided by others’.
Allocation of land at SG19, along with increasing the allocation at Long Marston Airfield to new settlement scale
would secure the land and funding to create a cohesive extension to the road network around the west, south
and east of Stratford-upon-Avon.
The Interim SA does not consider the Green Belt, outlining at paragraph 2.7.3 that a ‘policy off’ position is
adopted. Of the two SGL options within Stratford-upon-Avon, SG19 scored more favourably in the Interim SA,
outperforming SG18 in two categories (Flood Risk and Landscape), whilst it performed comparatively less
strongly with regard to Cultural Heritage. The two SGLs scored equally in ten of the objectives.
CEG and Mixed Farms consider that in further comparing the SGLs following the work of the Interim SA,
reference must be made back to the NPPF which sets out a sequential approach to the use of land for
development. As the SWLP accepts that there is insufficient brownfield land available to meet development
needs (and CEG and Mixed Farms acknowledge it is likely that some Green Belt land will need to be considered
for allocation) it is important that before assessing and allocating Green Belt land, sustainably located non-Green
Belt options should be considered first in line with the sequence as set out at paragraphs 145 to 147.
A significant part of SG18 to the north of Alcester Road / A46 lies within the Green Belt and is therefore
sequentially less preferable to accommodate development than SG19 which lies entirely outside of the Green
Belt.
Therefore, the site’s location outside the Green Belt, adjacent to a principal urban area, with the ability to
connect homes in Stratford-upon-Avon to jobs in Wellesbourne ensures that the benefits of delivering
development at SG19 outweigh those of SG18.
Looking more broadly, Table 5.2 of the Interim SA demonstrates that SG19 performs strongly in relation to Flood
Risk and Landscape in relation to many of the other SGLs. SG19 compares less strongly with other SGLs in relation
to Cultural Heritage and Biodiversity and is also considered likely to raise minor negative effects (although no
more so than many other SGLs) in relation to Landscape and Pollution. The detailed masterplanning of the layout,
design and landscaping of a scheme on land controlled by CEG and Mixed Farms in isolation ensure that impacts
can be suitably mitigated.
In considering the scoring of SG19 in regard to Biodiversity, it is noted that major negative effects are envisaged
on Local Wildlife Sites and Appendix B of the Interim SA at paragraph 4.6.3 outlines that this is generally the case
where substantial loss or degradation of the LWS is envisaged.
However, CEG and Mixed Farms’ land interest does not directly coincide with a LWS and it appears the major
negative effects are likely to be associated with the parcel of SG19 lying to the west of Banbury Road. CEG and
Mixed Farms’ parcel of SG19 can therefore come forward without negative effects on Biodiversity and nor is it
reliant on the parcel of SG19 to the west of Banbury Road – it can be delivered with or without this land.
The Site Constraints and Opportunities Plan and Conceptual Framework at Appendix 2 demonstrate how such
impacts could be mitigated against.
Based on the findings of the Interim SA, SG19 is the least constrained option for growth at Stratford-upon-Avon
and this is supported by CEG and Mixed Farms.

No

ID sylw: 108311

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms support the policy direction in so far as it relates to the plan period of 25 years. The
approach to planning for a longer period than the minimum required by the NPPF will enable a more cohesive
growth strategy to be prepared ensuring that large scale development has a better chance of delivering the
housing and employment growth required for South Warwickshire as set out within paragraph 77 of the NPPF
which states:
“The supply of large numbers of new homes can often be best achieved through planning for larger scale
development, such as new settlements or significant extensions to existing villages and towns, provided they are
well located and designed…”
Draft Policy Direction 1 looks to the Coventry & Warwickshire Housing and Economic Development Needs
Assessment 2022 (the ‘HEDNA’) to set its ‘minimum’ housing requirement whilst considering flexibility for up to
2,188 dwellings per annum in line with the 2024 Standard Method. Paragraph 62 of the NPPF states:
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing
need assessment, conducted using the standard method in national planning practice guidance. In addition to the
local housing need figure, any needs which cannot be met within neighbouring areas should also be taken into
account in establishing the amount of housing to be planned for.”
Therefore, CEG and Mixed Farms are unequivocal that the SWLP should plan to meet at least the Standard
Method figure of 2,188 dwellings per annum in order avoid any issues of soundness regarding the minimum
figure selected. In addition, and of more relevance to ‘Draft Policy Direction 4 – Accommodating Growth Needs
Arising from Outside South Warwickshire’, the housing requirement must also take into consideration any unmet
needs which cannot be met within neighbouring areas, such as Birmingham and other areas within the Greater
Birmingham and Black Country Housing Market Area (GBBCHMA) and the Coventry and Warwickshire HMA.
Whilst it is acknowledged that at this time it is difficult to identify the exact levels of unmet need from
neighbouring areas, it is important that Draft Policy Direction 1 accounts for the potential unmet needs which
may arise in future. For example, Birmingham’s unmet need of circa 37,900 dwellings as identified by the
Birmingham Development Plan (BDP, adopted 2017) is unlikely to have reduced as a result of the 2024 Standard
Method figure for Birmingham which now stands at 4,448 dwellings per annum versus the BDP housing
requirement of 4,450 dwellings per annum.
The Greater Birmingham HMA Strategic Growth Study (February 2018) identified potential locations which could
be suitable to meet the unmet need from the GBBCHMA – with land to ‘South of Stratford-upon-Avon town’
considered as one of 10 non-Green Belt options. Although the Study concluded that four other urban extension
options should be taken forward for detailed consideration, one of these (South of Dudley) is located within the
Green Belt and therefore ‘South of Stratford-upon-Avon town’ is sequentially preferable in terms of the approach
encouraged by national planning policy. Furthermore, of the new settlement options considered by the study, all
four new settlement locations taken forward are located within the Green Belt. Whilst the Study considered land
to the south of Stratford-upon-Avon, CEG and Mixed Farms consider that land to the east has similar
characteristics and can also deliver significant infrastructure to capitalise on the economic growth proposed at
Wellesbourne.
Through the identification of the site as a Reserve Site in the Revised Preferred Options Consultation of the
Stratford-upon-Avon Site Allocations Plan – ref: STR.D (SAP)); it is accepted that land in the south east of
Stratford-upon-Avon is suitable to meet unmet need arising from the GBBCHMA; and this approach should be
carried forward into the SWLP.
Draft Policy Direction 1 sets out that against the 2024 Standard Method figure, the SWLP must still find land for
28,257 dwellings in addition to existing commitments of 17,068 dwellings and a windfall allowance of 9,375
dwellings (375 dwellings per annum, 274 from Stratford-on-Avon and 101 from Warwick). CEG and Mixed Farms
encourage the SWLP to ensure that the figure to be derived from existing commitments is robust to ensure that
the SWLP allocates sufficient land to deliver the necessary housing to accommodate growth.
Stratford-upon-Avon and specifically SG19 are excellently placed to accommodate housing need arising from
both within and outside of Stratford-on-Avon district as set out within these representations.

Other

ID sylw: 108312

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

Whilst CEG and Mixed Farms does not oppose planning to deliver new settlements, per se, the SWLP is urged to
proceed with caution in terms of relying upon the delivery of new settlements to meet housing requirements
within the plan period.
It is well evidenced that large strategic sites such as new settlements are costly and complex in terms of land
assembly and therefore take much longer to deliver housing than allocations in locations which are already
sustainable.
The Lichfields document ‘From Start to Finish’ (March 2024) is an industry-wide accepted document which
considers housing delivery, lead-in times for planning application of different scales and average build-out rates
for development sites. The SWLP confirms that any new settlement will be a minimum of 6,000 dwellings, and
whilst Start to Finish considers developments of 2,000 + within one category, it outlines that:
 Planning approval for these sites averages at 5.1 years from validation;
 First delivery for these sites averages 6.7 years from validation;
 Build out rates average between 100 and 188 dpa.
The above data, which suggests that the first dwelling is not occupied over 10 years after submission of a
planning application, should be treated as an absolute minimum for a new settlement. In reality, given the
significantly uplifted number of dwellings in a South Warwickshire new settlement, it can be expected that
planning permissions, delivery and build out rates for a site of 6,000 dwellings will be substantially increased
above the evidence set out within Start to Finish.
The SWLP will therefore need to ensure that market and affordable housing and associated necessary
infrastructure is also delivered early in the plan period and should therefore allocate sites at a variety of scales to
ensure the spread of housing delivery across the trajectory. Whilst the infrastructure to be delivered alongside a
new settlement can be selected to meet the needs of future residents, urban extensions, such as at East of
Stratford-upon-Avon can rely initially on existing infrastructure to deliver development earlier within the plan
period whilst also unlocking additional land to be developed later in the plan period. This approach is critical to
the Council demonstrating a five year housing land supply upon adoption of the plan and maintaining sufficient
supply and meeting delivery rates throughout the plan period.
CEG and Mixed Farms’ land at East of South East Stratford-upon-Avon can deliver approximately 1,200 dwellings
across the plan-period, however CEG and Mixed Farms expect that a first phase of 300 - 450 dwellings can deliver
housing within the first five years of the plan period.
In terms of the specific new settlement options put forward within the SWLP, CEG and Mixed Farms note that
‘Land at Hatton (B1)’, ‘Long Marston Airfield (E1)’, ‘Land south of Leamington Spa/Whitnash and west of B4455
Fosse Way (X2)’ and ‘Land at Bearley and Wilmcote (BW)’ are all considered to be ‘More Suitable’ of the New
Settlement options. Two of these options (‘Land at Hatton’ and ‘Land at Bearley and Wilmcote’) are located
entirely within the Green Belt and therefore, again, are sequentially less preferable than SG19 in terms of the
NPPF’s direction to allocate non-Green Belt land first, before considering review and allocation of Green Belt
land. SG19 is a sustainable non-Green Belt option which can accommodate significant levels of growth and unlock
land required to deliver vital infrastructure for Stratford-upon-Avon and Wellesbourne in the form of the Eastern
Relief Road.
In summary, whilst new settlements might be appropriate as part of a strategy to accommodate the longer term
housing needs of the Local Plan area, CEG and Mixed Farms consider non-Green Belt urban extensions such as
East of Stratford-upon-Avon, which can deliver market and affordable housing earlier in the plan period, should
be allocated for development.

Other

ID sylw: 108313

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

As set out elsewhere in CEG and Mixed Farms’ representations, it is important that the SWLP at this stage
considers the potential for unmet needs from outside South Warwickshire being met as the plan-making process
progresses.
For example, Birmingham’s unmet need of circa 37,900 dwellings as identified by the Birmingham Development
Plan (BDP, adopted 2017) is unlikely to have reduced as a result of the 2024 Standard Method figure for
Birmingham which now stands at 4,448 dwellings per annum versus the BDP housing requirement of 4,450
dwellings per annum.
CEG and Mixed Farms acknowledge that due to the new Standard Method being released only shortly before this
consultation commenced, there has not been sufficient time for evidence base studies to be undertaken to
establish the exact level of unmet need which may arise either from the Coventry and Warwickshire Housing
Market Area or from the Greater Birmingham and Black Country Housing Market Area.
At Regulation 19 stage however, CEG and Mixed Farms expect that this information will be available or better
understood, providing the opportunity for the SWLP to identify a quantum of development necessary to
accommodate unmet needs from neighbouring areas.

Other

ID sylw: 108314

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms agree that new development should contribute, where necessary, to the implementation
of transport strategies and acknowledges the role that development can play in delivering significant
infrastructure projects.
The Stratford-upon-Avon Transport Strategy sets out the difficulties the town experiences with regard to traffic
congestion, outlining that low average speeds are recorded throughout Stratford-upon-Avon on roads
approaching the town centre. The Transport Strategy attributes much of the traffic involved in this congestion to
through traffic to/from Shipston Road to/from Warwick Road; Birmingham Road to/from Shipston Road and
Banbury Road to/from Warwick Road, with traffic concentrated on two river crossings.
The Transport Strategy refers to historic work carried out to identify schemes to address existing transport
problems and accommodate future demands arising from new development. A series of Strategic Transport
Assessments were undertaken which identified where route improvements could be made, including growth to
the south east of Stratford-upon-Avon where a relief road on the eastern side of the town would be required.
Page 17 of the Transport Strategy outlines that an Eastern Relief Road connecting Warwick Road to Banbury Road
alongside a significant housing allocation in Southeast Stratford would ‘not only accommodate this scale of
development but would also improve overall network conditions and present opportunities to make further
advantageous changes to the transport infrastructure in central areas.’
Further investigations into this solution found that delivery of relief roads to both the east and west of Stratfordupon-
Avon would present the most effective reduction in journey times and alleviate pressure on junctions.
Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider
the substantial benefits that can be delivered through large scale growth south east of Stratford-upon-Avon, in
particular supporting the delivery of an eastern relief road, a strategic piece of infrastructure, noting that
paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs
of the area. More specifically, the opportunity to connect Banbury Road to Wellesbourne Road, providing
enhanced connectivity between the two routes should be explored. As set out within the Transport Note and
referenced elsewhere in these representations, this proposed ‘Movement Corridor’ will simplify journeys of all
modes towards Wellesbourne, where major economic growth is planned, without adding significant pressure on
routes in Stratford-upon-Avon town centre.
CEG and Mixed Farms therefore consider that development at SG19 would create significant improvements to
local infrastructure by delivering a phase of the Eastern Relief Road within the development site in accordance
with Draft Policy Direction 5.

Other

ID sylw: 108315

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms acknowledge the importance of safeguarding land for transport proposals to ensure that
sufficient land is available to deliver vital infrastructure to help meet growth requirements. Policy Direction 6
refers to Figure 9 of the SWLP which shows the broad locations of several transport infrastructure projects
including the “South Western Relief Road and alternative routes” however the plan at Figure 9 is very high-level
and at this stage does not allow for true consideration as to whether “development within the areas safeguarded
for the transport infrastructure” …”could inhibit the effective delivery of the infrastructure”.
It is essential that future policies are refined with accurate plans identifying allocations and transport
infrastructure including how the two interact. Safeguarding should take a balanced approach without impacting
the Plans’ objectives by unnecessarily delaying or complicating the delivery of critical housing and infrastructure.
Whilst it is acknowledged that the LPA and LHA will be involved in the process, CEG and Mixed Farms consider
that SG19 – East of Stratford-upon-Avon is capable of delivering the ERR and the preferred routing should be led
by the parties in control of land within SG19, rather than by specific policies, the LPA or the LHA.
CEG and Mixed Farms outline the importance of policy relating to safeguarding for transport proposals not
limiting the potential of SG19, or other similarly identified SGLs, to deliver sustainable development.

No

ID sylw: 108316

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms consider that whilst a variety of new homes are supported, to meet the needs of different
groups of the community in accordance with paragraph 62 of the NPPF, further evidence around need and
viability should be presented at future plan-making stages should South Warwickshire wish to implement a policy
requirement for self and custom build housing on allocated sites. Draft Policy B sets out that 5% of the
developable area of the site should be made available to self and custom build housing, however this is not
grounded in evidence at this time and it is unlikely that 5% of all large sites to be allocated will be supported by
the demand when considering the Council’s self-build register from 2015/15 and committed supply.

No

ID sylw: 108317

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

Whilst CEG and Mixed Farms understand the importance of planning for net zero carbon development as part of
the broader objective to address climate change. However there is significant concern regarding the approach set
out by Policy Direction 22, which outlines the potential for the SWLP to go beyond the requirements of Building
Regulations.
The Government’s approach to this is clear, and as set out in a Written Ministerial Statement (WMS) dated 13th
December 2023, confirming that planning policies should not impose standards for energy performance that
exceed the Code for Sustainable Homes Level 4, noting the Future Homes Standard (FHS) to be implemented in
2025.
The WMS outlined:
“the Government does not expect plan-makers to set local energy efficiency standards for buildings that go
beyond current or planned building regulations. The proliferation of multiple, local standards by local authority
areas can add further costs to building new homes by adding complexity and undermining economies of scale.
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.”
Requiring development to exceed the requirements of Building Regulations is likely to result in unnecessary
complexity and additional costs for developers, threatening the viability of schemes and slowing down the ability
of the industry to respond to and meet the housing and economic needs of the SWLP.
CEG and Mixed Farms therefore strongly urge the reconsideration of the approach set out in Draft Policy
Direction 22 and avoid divergence from the FHS as per the recommendations of the WMS. Any policy which goes
beyond the FHS must be demonstrated to be viable and not hamper the delivery of development required to
meet the SWLP’s requirements.