Yes

ID sylw: 108503

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The site (ref. 486 Land off Billesley Road, Wilmcote)scores poorly in the Housing and Economic Land Availability Assessment (HELAA) as it located within the Green Belt.
The site at Wilmcote 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 village and will enhance its vitality in line with national planning policy.

No

ID sylw: 108504

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

It has not been adequately demonstrated that the Potential New Settlements will be supported by the necessary infrastructure and facilities, including a genuine choice of transport modes. Opportunities for rail links to these Potential New Settlements may be challenging and therefore further information is required to demonstrate how such development can help to meet identified needs in a sustainable way.
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. Clearly, there is a requirement for smaller allocations to meet the identified housing needs in the shorter term, in accordance with Paragraph 72 of the Framework.
The site at Wilmcote 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 village and will enhance its vitality in line with national planning policy.
The site at Wilmcote, should be allocated as a housing site. 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.

Yes

ID sylw: 108505

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

Yes, in principle. However, the Bird Group note that Draft Policy Direction 3 proposes support for “small scale” development within or adjacent built up area boundaries for settlements in South Warwickshire and that consideration will be given in the SWLP to identifying a number of “small sites” in order to ensure provision of a 5-year housing land supply. Instead the SWLP Part 1 should support “proportionate” development within and adjacent to existing settlements, in a comparable way to Policy CS.16 in the Stratford-on-Avon Core Strategy.
Unless an appropriate mix of sites of varying sizes are allocated in Part 1 of the SWLP, there is a real risk that an over reliance on Strategic Growth Locations and/or New Settlements will lead to identified housing needs for South Warwickshire in the shorter term not being met.

Yes

ID sylw: 108506

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group are generally supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Stratford on Avon Core Strategy was adopted in 2016.

Yes

ID sylw: 108509

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

In principle, the proposed sequential approach to allocating strategic growth locations and any new settlement within the SWLP is supported. A sequential approach is consistent with national planning policy which makes clear that the Green Belt should not be a barrier to development per se – so long as the land in question is edge of settlement, or in an otherwise sustainable location; provides suitable affordable housing and local infrastructure (in accordance with the new ‘Golden Rules’); is not subject to an existing environmental designation; and does not serve – or significantly undermine – purposes (a), (b) and (d) of the Green Belt.
4.30 The Bird Group do, however, wish to restate our view that if the SWLP is to be taken forward in two parts, some smaller sites should be allocated for development in Part 1 to help ensure the Councils can maintain a 5-year housing land supply. Consequently the proposed assessment of non-Green Belt locations to accommodate South Warwickshire's housing (and employment land needs) should not, for Part 1, be confined to strategic areas of growth and potential new settlement locations but should also be used to help identify those non-Green Belt sites which are well located.

Other

ID sylw: 108510

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group consider providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. The Bird Group support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.

No

ID sylw: 108511

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The approach laid out Draft Policy ‘A’ should help ensure new homes in South Warwickshire are of a sufficient size and layout to better meet the needs of future occupiers. This will be particularly important where high density development is proposed, which typically has less accessible outdoor space than detached and semi-detached houses. However, Government guidance says that LPAs cannot automatically use the nationally described space standard in a Local Plan. Planning Practice Guidance (Paragraph: 020 Reference ID: 56-020-20150327) requires that LPAs must first consider the following to be able to include NDSS in plan policies:
• whether there is a need for additional standards in the LPA area;
• the viability of imposing the standards; and
• their timing to allow a reasonable transitional period.
Presently the Regulation 18 SWLP acknowledges that further assessment needs to be undertaken on the extent of non-compliance with NDSS and whether this is more prevalent for certain types of residential development. In addition we are informed that further viability testing is required to ensure the NDSS will not have a material impact on the deliverability of housing schemes, including affordable housing, within the districts.
Within this context we consider that the evidence base is not sufficiently robust to justify the NDDS requirements currently set out in Draft Policy A

Other

ID sylw: 108512

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group agree with the general approach for the provision custom and self-build housing plots in order help to diversify the housing market and increase consumer choice in accordance with Paragraph 63 of the Framework.
A draft SWLP policy requirement for 5% of the developable area for large developments (100 or more dwellings) to be made available for the provision of self-build and custom-build homes, may lead to an over-supply of this housing tenure - far greater than the level of need identified on the Council’s Register for the past few years. Therefore, greater flexibility is required in the policy wording to enable a fall-back option if the Council’s Self-Build and Custom Housebuilding Position Statement indicates that there is already a sufficient supply of plots to meet the demand for this specific type of housing.
We agree with the inclusion of the fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (12 months).

Other

ID sylw: 108515

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 Wildmoor Fields land (Site Ref. 486 and part of 545) (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: 108516

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 Wildmoor Fields land (Site Ref. 486 and part of 545) (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.