Other

Representation ID: 107371

Received: 06/03/2025

Respondent: National Trust

Agricultural land – The National Trust cares for agricultural land in some of our historic estates. With South Warwickshire being very rural in places, the agricultural nature is also considered characteristic of the landscape in many places. Draft policy direction 49 sets out that best and most versatile agricultural land should be protected from development. The National Trust support this policy, however, would consider that such an assessment should be required to be balanced against the criteria of the LNRS and BNG, as set out elsewhere in this response.

Yes

Representation ID: 107872

Received: 05/03/2025

Respondent: Catesby Estates Ltd

Agent: Pegasus Group

NPPF Para 187 b) states "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 states the quality of farmland should inform choices about future use within the planning system. A policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising there may be circumstances where development on best and most versatile (BMV) land is appropriate, when the planning balance favours approval. The exemption from protection for the Strategic Growth Locations and New Settlement Sites is strongly supported. This will ensure the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both the sites which are allocated in the Pre-Submission plan and those which are not, since they have already been identified as suitable growth locations in the Preferred Options document. The SA does not suggest any negative impacts would arise from excepting sites from this policy.

Other

Representation ID: 107912

Received: 07/03/2025

Respondent: TERRA

Agent: Lichfields (Birmingham)

Whilst Terra recognises the importance of best and most versatile (“BMV) agricultural
land, in relation to economic and environmental benefits, Terra do not consider that the
SWAs approach is necessary.
2.119 The NPPF is clear that planning policies and decisions should contribute to and enhance
the natural and local environment by “recognising the intrinsic character and beauty of the
countryside, and the wider benefits from natural capital and ecosystem services –
including the economic and other benefits of the best and most versatile agricultural
land…” (Para 187b). Notwithstanding this, again, the SWAs should have regard to
paragraph 16(f) of the NPPF (i.e. serve a clear purpose and avoid ‘unnecessary duplication).
2.120 To this end, Terra considers that a policy that largely duplicates the protections afforded to
BMV in the NPPF would not ‘serve a clear purpose’ and would fail the test of compliance
with national policy.

Yes

Representation ID: 107992

Received: 07/03/2025

Respondent: Rainier Developments Ltd

Agent: Pegasus Group

NPPF Para 187 b) states "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 states the quality of farmland should inform choices about future use within the planning system. A policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising there may be circumstances where development on best and most versatile (BMV) land is appropriate, when the planning balance favours approval. The exemption from protection for the Strategic Growth Locations and New Settlement Sites is strongly supported. This will ensure the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both the sites which are allocated in the Pre-Submission plan and those which are not, since they have already been identified as suitable growth locations in the Preferred Options document. The SA does not suggest any negative impacts would arise from excepting sites from this policy.

Other

Representation ID: 108200

Received: 27/02/2025

Respondent: St Philips

Agent: Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy
Direction-49- Agricultural Land?
2.108 Whilst St Philips recognises the importance of best and most versatile (“BMV) agricultural
land, in relation to economic and environmental benefits, St Philips consider that the SWAs
approach is not necessary.
2.109 The NPPF is clear that planning policies and decisions should contribute to and enhance
the natural and local environment by “recognising the intrinsic character and beauty of the
countryside, and the wider benefits from natural capital and ecosystem services including the economic and other benefits of the best and most versatile agricultural
land…” (Para 187b). Notwithstanding this, again, the SWAs should have regard to
paragraph 16(f) of the NPPF (i.e. serve a clear purpose and avoid ‘unnecessary duplication).
2.110 To this end, St Philips considers that a policy that largely duplicates the protections
afforded to BMV in the NPPF would not ‘serve a clear purpose’, nor avoid ‘unnecessary
duplication’ as the decision taker would need to have regard to the requirements of the
NPPF in any event.

Yes

Representation ID: 108245

Received: 07/03/2025

Respondent: Persimmon Homes (South Midlands)

Agent: Pegasus Group

Para 187 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. As such, it is considered that a policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising that there may be circumstances in which development on best and most versatile (BMV) land is appropriate, and thus cases when the planning balance favours approval. In particular, the fact that an exception will be made for the Strategic Growth Locations and New Settlement Sites, with the protection of BMV land not being a consideration, is strongly supported. This will ensure that the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both sites which are allocated in the Pre-Submission plan, and those which are not, with them having already been identified as suitable locations for growth in the Preferred Options document. The SA does not suggest that any negative impacts would arise from excepting sites from this policy.

Other

Representation ID: 108378

Received: 07/03/2025

Respondent: Mackenzie Miller Homes

Agent: Lichfields (Birmingham)

16.1 Mackenzie Miller Homes recognises the economic and environmental advantages of best
and most versatile [BMV] agricultural land but considers the SWCs' approach to be
unnecessary.
16.2 The NPPF is clear that planning policies and decisions should contribute to and enhance
the natural and local environment by “recognising the intrinsic character and beauty of the
countryside, and the wider benefits from natural capital and ecosystem services –
including the economic and other benefits of the best and most versatile agricultural
land…” (Para 187b). Nevertheless, the SWCs should have regard to Paragraph 16(f) of the
NPPF which states that plans should “serve a clear purpose, avoiding unnecessary
duplication of policies that apply to a particular area (including policies in this
Framework, where relevant).”
16.3 It is therefore, Mackenzie Miller Homes’ view that that a policy that largely duplicates the
protections for BMV land already provided in the NPPF would neither ‘serve a clear
purpose’ nor would it avoid ‘unnecessary duplication’, since decision-taker must consider
the NPPF requirements regardless.

No

Representation ID: 108559

Received: 29/06/2025

Respondent: Hayfield Homes

Hayfield consider that a local policy relating to agricultural land is not necessary, as this is already provided for within the NPPF, and would result in repetition of national policy

Yes

Representation ID: 108607

Received: 07/03/2025

Respondent: Corbally Group (Harbury) Ltd

Agent: Pegasus Group

Para 187 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. As such, it is considered that a policy on agricultural land would be justified.

The policy direction as drafted is supported as it avoids taking a blanket approach, recognising that there may be circumstances in which development on best and most versatile (BMV) land is appropriate, and thus cases when the planning balance favours approval. In particular, the fact that an exception will be made for the Strategic Growth Locations and New Settlement Sites, with the protection of BMV land not being a consideration, is strongly supported. This will ensure that the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both sites which are allocated in the Pre-Submission plan, and those which are not, with them having already been identified as suitable locations for growth in the Preferred Options document. The SA does not suggest that any negative impacts would arise from excepting sites from this policy.

Other

Representation ID: 108651

Received: 07/03/2025

Respondent: Kiely Bros Holdings Ltd

Agent: Pegasus Group

Policy Direction 49 – Agricultural Land
10.27.
NPPF §187b) states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. As such, it is considered that a policy on agricultural land would be justified
10.28.
The policy direction as drafted is supported as it avoids taking a blanket approach, recognising that there may be circumstances in which development on best and most versatile (BMV) land is appropriate, and thus cases when the planning balance favours approval. In particular, the fact that an exception will be made for the Strategic Growth Locations and New Settlement Sites, with the protection of BMV land not being a consideration, is strongly supported. This will ensure that the most sustainably located sites for development can be brought forward without having to factor this in. The Councils are encouraged to apply this exception to both sites which are allocated in the Pre-Submission plan, and those which are not, with them having already been identified as suitable locations for growth in the Preferred Options document. The SA does not suggest that any negative impacts would arise from excepting sites from this policy.

Other

Representation ID: 108964

Received: 07/03/2025

Respondent: Warwickshire County Council

WCC supports this approach and is one that the LNRS will look to inform through its mapping elements

Development of large-scale renewable energy developments should be questioned on active farmland irrespective of the quality grade.

Fresh Food security must be a priority for South Warwickshire.

Thought to be give to re-provision of farmland to areas outside strategic sites/new settlements.