No

ID sylw: 108457

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

This submission is made on behalf of the Bird Group, in relation to their interests at Land East of Birmingham Road (Site Ref. 482 and part of 408) (hereafter referred to as ‘the Site’).
The Site is located in potential Strategic Growth Locations (SGL) in the emerging plan (ref. SGL 18).
It is considered that the site is deliverable, available and suitable (as previously recognised by Stratford-on-Avon District Council in its emerging Site Allocations Plan) to deliver a high-development that will significantly assist in meeting South Warwickshire’s identified housing and employment need as well as any unmet needs arising from Coventry and from Greater Birmingham and the Black Country.
Draft Policy Direction 1 sets out that the South Warwickshire Local Plan will make provision for the delivery of at least 1,679 dwellings per annum, in line with the HEDNA; with sufficient flexibility to accommodate up to 2,188 dwellings per annum, in line with the 2024 NPPF Standard Method. This is not consistent with the Framework which states at Paragraph 62.
The HEDNA is over two years old (November 2022) and therefore provides outdated evidence, with a housing need figure that is significantly lower than the minimum number of homes set out in the Standard Method. Indeed, the Sustainability Appraisal (December 2024) states at paragraph 4.2.5 that:
‘It is recommended that the HEDNA calculation is updated to reflect the latest population information and trends to determine whether this figure remains fit for purpose.’
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method. The Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (April 2023) identifies a shortfall of some 106,654 dwellings. Whilst this Position Statement is out of date on account of the Local Plan preparation and revisions to calculating housing need through the new Standard Method, it is anticipated that the updated position (which is currently being prepared) will conclude that there is a significant shortfall.
Given the pressing need for additional housing within the Stratford-on-Avon District, the site is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a mixed-use site within the South Warwickshire Local Plan as part of SG18.

Yes

ID sylw: 108458

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

This submission is made on behalf of the Bird Group, in relation to their interests at Land East of Birmingham Road (Site Ref. 482 and part of 408) (hereafter referred to as ‘the Site’).
Given the pressing need for additional housing within the Stratford-on-Avon District, the site is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a mixed-use site within the South Warwickshire Local Plan as part of SG18.

Other

ID sylw: 108459

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

There is no detail to comment on at this stage. The pre-amble to Draft Policy Direction 4 -Accommodating Growth Needs Arising from Outside South Warwickshire states: ‘It is yet to be established to what extent and what uses (e.g. housing and/or employment) there will be any unmet need from elsewhere within these housing market areas [Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA]. Some of this need will be met by other constituent Local Planning Authorities within both HMA’s; however, through Duty to Co-operate discussions; the Councils will commit to continually consider this need and work with those authorities on how this can be achieved.’
A number of West Midlands authorities have seen a significant increase in their Local Housing Need figure under the new Standard Method (save for Birmingham, Sandwell and Coventry). The West Midlands would be expected to deliver 29,940 dwellings per annum, a 21% increase compared to the previous method.
There will undoubtedly be challenges for neighbouring authorities to meet their own needs and hence the South Warwickshire authorities may well need to increase their housing need figure by reason of the requirement to accommodate any unmet needs.

Yes

ID sylw: 108460

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group agree that the SWLP will apply national planning policy to proposals within the Green Belt.
It is agreed that the SWLP will take a sequential approach to allocating strategic areas of growth and new settlements.
It is agreed that the SWLP will also consider whether the Spatial Growth Strategy's patterns of development result in a justification for any new Green Belt.
The land so identified relates well to the existing settlement pattern and is relatively close to the Stratford-upon-Avon Park and ride. A compact extension to the urban form of Stratford -Upon-Avon would be created.

Yes

ID sylw: 108461

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

It is agreed that the Core Opportunity Area (as detailed in Figure 10), which includes the subject site will be the focus for new employment development in the South Warwickshire area. The COA will build on existing employment hubs, harness the potential offered by co-locating businesses and research facilities and support the strategy for attracting significant inward investment to the area.

No

ID sylw: 108462

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group would question the requirement in Draft Policy-F that all “major development” in South Warwickshire will be required to demonstrate a thermal master planning approach to maximise energy efficiency opportunities.
No information is provided in the draft policy, or supporting justification, as to what constitutes “major development” in this context, in fact the justification merely refers to “new developments”. If “major development” represents residential developments of 10 or more dwellings, the Bird Group consider the requirement to be unnecessarily burdensome for many developments.
The policy should also acknowledge that there might occasions where an existing system might be available but does not have enough capacity to accommodate the energy needs of planned new development. Furthermore, if the draft policy is to be taken forward into the Pre-Submission SWLP, to avoid any unnecessary ambiguity the policy should, as per the supporting justification, make clear that that detailed energy statements will be required, to include potential for connection to decentralised energy systems.

No

ID sylw: 108463

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group disagree that this needs to be undertaken through the local plan given that there is already a national approach being taken forward to achieve the same goal, the Future Homes Standard (FHS).
Currently if the Councils choose to go beyond current or future standards the following stated requirements must be subject to viability testing as part of the Pre-Submission SWLP:
• The requirement under Part A that residential buildings must be designed and built to be Net Zero Carbon in operation and that they must generate renewable energy on-site to at least match annual energy use; and
• The requirement under Criterion 2 for heat pumps to be the primary heating system for houses unless in areas with low-carbon district heating networks.
• Under Criterion 4, it is suggested that battery storage may be required for future residential development schemes. This should be viability tested and the implications for battery storage investigated in terms of space requirements and maintenance.
Regarding the requirement under Criterion 4 for roof orientation that maximises PV generation options where possible. The Bird Group consider it is important that the Councils first establish what impact this could potentially have on scheme density, and how this requirement if applied would align with the SWLP’s design policies. Similarly, Criterion 5 relates to compact building forms and will have direct implications for scheme layouts. This requirement also needs to be considered alongside the SWLP’s design policies.

Other

ID sylw: 108464

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

Whilst Bird Group are supportive of the Councils taking steps to reduce carbon emissions in new development, we question the focus placed solely on embodied carbon solely associated with buildings/ building materials. If embodied carbon is to be assessed, we believe that the overall impact of proposed a development should be considered at the planning stage e.g. the embodied carbon in any offsite supporting infrastructure that might be specifically required to make the development acceptable in planning terms such as new highways infrastructure. In such cases the embodied carbon impact would clearly be much greater than would be the case for a development which is well located to take advantage of existing infrastructure capacity and requires little of no supporting new infrastructure.

No

ID sylw: 108465

Derbyniwyd: 26/06/2025

Ymatebydd: The Bird Group

Asiant : Framptons

As currently worded Bird Group do not support the stated requirement that all development proposals will need to “Minimise the need for new water supply infrastructure by directing development to areas where there is a guaranteed and adequate supply of water, having due regard to Severn Trent Water's Resources Management Plan and Strategic Business Plan as well as findings of the Water Cycle Study”.
While Bird Group acknowledge that is preferable to direct new developments to areas where there is a guaranteed and adequate supply of water, it is common for water supplies to be reinforced and new services extended to serve new developments.

Yes

ID sylw: 108466

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group are supportive of the proposed use of design codes, this being consistent with Paragraph 133 of the NPPF. Once a Design Code is in place it is accepted that planning applications should be prepared to be inconformity with its guidance. It should not, however, be necessary for developers to wait for Design Codes to be put in place before submitting planning applications or prior to their determination; this approach could cause significant delays to the delivery of housing. This is an important consideration given the fact that there remains a degree of uncertainty as to when the proposed series of design codes will be available, and that site-specific design codes will not likely be adopted until after adoption of the SWLP.
At Paragraph 134 makes clear that while landowners and developers may contribute to the preparation of Design Codes prepared by local planning authorities, they may also choose to prepare design codes in support of a planning application for sites they wish to develop.