Issue and Options 2023

No

Q-B3: Please select the option which is most appropriate for South Warwickshire (Special Landscape Areas) Bellway support Option B3a: Introduce Special Landscape Areas across all of South Warwickshire Bellway considers that it would be beneficial to review existing SLAs and identify any additional SLAs in Warwick District to ensure consistency. Housing growth should then be directed to settlements that are not within a SLA, such as Long Itchington. Q-B5: Please select the option which is most appropriate for South Warwickshire (Environmental Net Gain) Bellway supports option B5c: None of these Bellway consider that Environmental Net Gain (ENG) should not be pursued and the SWLP should leave national policy to steer future development and environmental objectives. Should a policy be required then ‘Option B5a: Explore and pursue an integrated Environmental Net Gain Policy’ is the preferred option. However, significant work would be required by the Councils to demonstrate that ENG is achievable and will not impact on the efficient delivery of sites or their viability. ENG is something that should be agreed on a site by site basis. Policy should only ‘encourage’ ENG rather than require a specific percentage or for every site to comply. Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? No – there is no evidence of need for this additional requirement in the SWLP. Wildbelt” is not a recognised land use defined in the NPPF which Local Plans need to accommodate. Q-B7: Do you agree that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP? Agree – Bellway consider that detailed minerals requirements should be left to Minerals Plan but a policy in the SWLP should reference that a balance is required when it comes to safeguarding minerals and identifying enough land to build the significant number of homes that are needed. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? No – Bellway consider that a strong test is being proposed by the Councils if the loss of agricultural land needs to be ‘clearly outweighed by the benefit of development’. This is not the test in the NPPF (paragraph 174) or the PPG (Reference ID: 8-001-20190721). National policy states that policies only need to “take account of the economic and other benefits of the best and most versatile agricultural land” (NPPF paragraph 174) and try to direct growth to lower quality land (NPPF footnote 58). Most of SWLP area is grade 3 land or higher. The SWLP needs to balance directing growth to lower quality land but also making sure that the most sustainable and suitable sites / settlements are identified. Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. No – Bellway consider that this would duplicate national policy. Any policy drafted should allow developments to propose appropriate measures to mitigate any assessed impacts.

Yes

Agree that sites should be allocated in the Part 1 SWLP to meet both strategic and short term housing needs. It is unclear when the Councils intend to produce / adopt the Part 2 plans. Given the significant housing shortfall arising from the Greater Birmingham HMA, the SWLP needs to make sure there is a sufficient number of sites allocated in the SWLP to meet needs for the next 5 – 10 years. Waiting for the Part 2 plans to be adopted is likely to cause delays in meeting the significant housing needs of the District and wider HMAs.