Yes

ID sylw: 108467

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group agree that a high-level strategic policy that seeks to protect and enhance existing heritage assets should be included within the Part 1 plan, in accordance with Paragraph 203 of the Framework. Detailed heritage policies should be deferred to Part 2.

No

ID sylw: 108468

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

It is a statutory requirement to achieve a net gain in biodiversity of 10% and therefore we are generally supportive of the policy approach. However, the draft policy direction goes on to state that a higher percentage of BNG above the statutory 10% requirement is being explored.
Such an approach may unnecessarily burden development sites as the provision of net gains in biodiversity can impact on the viability of proposals and the capacity of sites. It is hence requested that the South Warwickshire authorities explore including viability evidence on how a higher BNG would affect the capacity of sites when balancing other technical and environmental considerations and planning obligations. Draft Policy Direction 38 has the potential to add additional development costs that must be factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 108469

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

We are concerned that this subject area needs to mature further before it forms a part of local planning policy.
Quantifying the value of natural assets and ecosystem services is widely recognised as being both complex and subjective, where different methodologies can yield varying results, making it difficult to establish a consistent valuation framework. Furthermore, accurate and comprehensive data on natural capital is often lacking, which can hinder the ability to make informed decisions and effectively integrate natural capital into planning. While also we believe that trying to simplify complex natural processes into models can lead to an oversimplification and misrepresentation of the true value and function of natural assets.
Instead of looking to introduce a policy requirement on Environmental Net Gain through the SWLP, the Councils should focus on successfully implementing other policies which seek to protect and enhance the natural and local environment, and for which a proven policy framework exists.

Other

ID sylw: 108470

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

In principle, we support the approach laid out in Draft Policy Direction – 40 and the use of the Greening Factor planning tool to ensure that existing and new GBI is considered and integrated into the scheme design from the outset. The Bird Group do, however, have several concerns:
• Presently it is not clear what is actually required in terms of a “baseline assessment of existing GBI” to demonstrate that high value assets have been retained and enhanced where appropriate; no specific guidance is provided or referred to.
• There is also ambiguity over when the submission of a long-term maintenance plan for major developments is required; we would not support any requirement for such information to be provided at the Outline Planning Application stage.
• In order for this Policy to be included in the Plan, the Councils must have an understanding of the impact of this Policy on the net to gross development ratio of schemes and by default scheme densities.
• Draft Policy Direction 40 also has the potential to add additional development costs that must be factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 108477

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

Whilst we acknowledge that integrating carbon sinks and sequestration into planning policy can be beneficial for mitigating climate change, it also presents several challenges. For example, accurately measuring and verifying the amount of carbon sequestered can be complex and resource-intensive, which can lead to uncertainties and inconsistencies in reporting. Furthermore, ensuring that carbon sinks, such as forests and wetlands, are maintained and managed effectively over the long term can also be challenging, especially when climate change can affect their ability to sequester carbon. We therefore consider that this policy requirement should not, at this time be taken forward in the SWLP.
If, however, the Councils do decide to pursue Draft Policy Direction 41, before any requirement is introduced that requires a net gain in carbon sequestration, the viability of doing so should be undertaken taking into account and factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 108478

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

While we support the general intent of Draft Policy Direction 42, we do not support the Councils intention that developers will be “expected” to increase tree canopy cover on sites that are the subject of a planning application. We consider that this will be unnecessarily burdensome for developers, especially when considered alongside other policy requirements in the emerging SWLP and consequently could impact on viability. Furthermore, this requirement would have negative implications in terms of a developers ability to increase densities on many sites and would not support an effective use of land in meeting the need for homes and other uses.
We note that the justification provided in support of the Draft Policy Direction simply refers to the Local Authorities having a statutory duty to consider the protection and planting of trees when granting planning permission for proposed development, as set out section 197 of the Town and Country Planning Act 1990, and paragraphs 136, 187, and 193 of the NPPF. No similar justification is provided for developers being required to increase tree canopy cover on sites.
Consequently, instead of an increase in tree canopy cover on sites being “expected” , we feel it would be more appropriate if the SWLP simply stated that this would be “encouraged” by the Councils.

No

ID sylw: 108479

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

It is, of course, recognised that new development should ensure adequate provision of open spaces – which need to be provided on site in the first instance and then off-site, when it can be adequately demonstrated that on-site provision is not feasible. However, the requirement to provide an off-site contribution to enhance or provide new open space within 400 metres of the development is impractical and unreasonable. It is reasonable to request that the off-site open space is provided in an area that is well served by the residents of the site and any surrounding dwellings or neighbourhoods.

No

ID sylw: 108480

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

Given other proposed policies, such as those aimed at protecting valued landscapes, designated areas of restraint or areas of open space, we believe this policy represents a duplication of effort and is not justified.
The Policy also advises that the Council will “explore” the need for major development applications to require a full Landscape and Visual Impact Assessment. Given that a planning application for 10 dwellings would constitute a “major development”, we consider that it would be entirely disproportionate for a full LIVA to be submitted in the majority of cases for schemes of this or a similar size.
Given that the majority the development requirement in the SWLP will be provided on greenfield sites, any development is likely to have a degree of landscape harm as it will result in development taking place in an area where there is currently no built development. This does not, however, mean that the starting point for determination of an application is a presumption it should be refused. Landscape impact is just one of several matters that will need to be considered as part of the determination process. The draft wording of the policy Direction 48 therefore elevates the importance of landscape harm beyond other considerations, which is not an appropriate policy position the Councils should pursue.

No

ID sylw: 108501

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group are not supportive of the proposals for a two-part Plan in which only strategic sites (i.e. strategic allocations for new settlements and large-scale urban extensions) are to be included in the Part 1 Plan. No timescales are provided for the preparation of the Part 2 Plan, other than it will be prepared following the adoption of the Part 1 Plan.
2 The need for significant new infrastructure and facilities to support the Potential New Settlements will mean that these growth locations are unlikely to be delivered until towards the end of the Plan Period to 2050.
It is submitted that the Part 1 Plan should include smaller allocations in sustainable locations adjacent to existing settlements as part of a mix of sites within the Spatial Growth Strategy to assist in meeting South Warwickshire’s identified housing need.
The subject site is considered to be suitable for this purpose as it is geographically sustainable by reason of its relationship with Wilmcote and due to the scale of development (10 dwellings) which means it is able to be delivered quickly.

No

ID sylw: 108502

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

No, by reason of the revisions to the National Planning Policy Framework in December 2024(NPPF) and to the Standard Method - in an attempt to boost housing delivery.
The HEDNA figure is significantly lower than the minimum number of homes set out in the Standard Method and should therefore not be taken into account when assessing local housing need.
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.
It is hence considered that the Site is in a sustainable location and should be included as part of the Spatial Growth Strategy within the Plan.