Preferred Options 2025

Yes

Representation ID: 103178

Received: 07/03/2025

Respondent: Barwood Land

Agent: Savills (UK) Ltd

Daventry Road, Southam (RefID 135) is one of the most suitable and sustainable locations for growth. It is the second best-performing site in the HELAA B Assessment. It performs well compared to the new settlement locations. It scores 34.38. The second-ranked new settlement option B1 scores 56.37.

The score for RefID 135 is lower with mitigation and a masterplan responding to the constraints. We have submitted a Vision Document which incorporates the mitigation outlined below. In some areas the methodology of the HELAA can also be improved. These revisions give a more accurate score (13.80).

Spatial Growth Areas - score should be 0. Rather than GIS-based scoring, a judgement should be made on how well sites relate to the settlement. The proposed development would provide new community services and facilities as part of expansion.

Minerals Safeguarding Area - score should be 0. There is little prospect of mineral extraction at the site given proximity to the existing settlement. Most of the SWLP area is covered so this designation is not notable.

Employment Land Study - score should be 0. It seems unreasonable to negatively score all sites which could be reasonably sustainable for employment development. They may also be suitable for residential and mixed-use development.

Ground Mounted Solar - score should be 0. Only a small portion of the site falls within land 'most-suitable'. Due to settlement-adjacency it could not form part of a larger, commercially viable solar development. The development would not preclude solar provision in future.

Flood Zones 2 & 3 - score should be 0. No development would be proposed in the flood zone. The watercourse would be unaffected and is beneficial rather than a constraint as a sustainable means of discharging surface water from the outfall of the SuDS incorporated into the development.

Surface Water Flooding - score should be 0. Development would change the landform and integrate a sustainable drainage strategy.

Listed Buildings - score should be 0. There are opportunities for mitigation which would eliminate the impacts on a single Grade II listed building 200m from the boundary of the site.

Connectivity - score should be 1.8. A transport technical note has been submitted outlining opportunities to create good connections between the site and key destinations in Southam. The site should be scored as 'B' post-mitigation.

Accessibility to local services - score should be 0. Given the size of the site it would incorporate as a minimum a local centre, neighbourhood hub, primary school, café, recreation and leisure provision. The site also benefits from proximity to existing services and facilities in Southam.

The remaining negative scores relate to only three factors - the fact that it is greenfield land, a change in landscape character which is inevitable for a greenfield development, albeit not in a landscape which is particularly sensitive to change, and the connectivity score for the site. It is therefore irrational that the site is not identified as part of the Southam SGL given its very positive assessment.

Other

Representation ID: 107917

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

These representations broadly support the vision. It reflects Paragraph 7 of the NPPF which states that the purpose of the planning system is to contribute to sustainable development. The overarching principles do not align with the vision. None of them refer to delivery of homes and jobs which are key to sustainable development. Reference must be made to this to then feed into the Strategic Objectives which do reference housing and employment. The selected spatial growth strategy, ‘Sustainable Travel and Economy’ should be referred to and woven into the other principles.

The vision and first principle strongly emphasizes the climate emergency. While generally supported this should not dominate the vision and strategic objectives to the detriment of delivery of development to meet identified needs. The second principle refers to a beautiful south Warwickshire. This is supported and Paragraph 131 of the NPPF makes reference to beauty but this needs to be defined and supported by guidance on what it means in practice.

The Strategic Objectives cover the social, economic and environmental dimensions of sustainable development as set out in Paragraph 8 of the NPPF and they are therefore considered consistent with national policy.

No

Representation ID: 107926

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

The HEDNA housing need is now out-of-date. The Standard Method identifies 2,188 homes as a starting point. The Draft Policy Direction seems to suggest this is the maximum number of homes. The NPPF is clear that the Standard Method establishes the minimum number. Treating this as a minimum would pose no issues for deliverability of the plan as completions across Stratford and Warwick have exceeded this figure in 6 of the last 8 years.

Land at Thickthorn, Kenilworth is within Priority Area 1. We support prioritising brownfield land. However, we note the findings of the Urban Capacity Study which suggest brownfield can meet only 11% of the minimum housing need over the plan period. The acceptable uses of brownfield land should be more flexible to ensure it is brought forward for development. The site can be delivered early in the Plan period which would assist Warwick DC in providing much-needed housing given its current lack of 5 year land supply.

Other

Representation ID: 107927

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

The provision of appropriate infrastructure is supported in principle; Paragraph 20 of the NPPF is clear that strategic policies should make sufficient provision for infrastructure, and this is also key for the delivery of sustainable development. The Site at Thickthorn is within the built-up urban area and as part of the existing permission for the Site infrastructure has been delivered in this sustainable location. It can therefore support development early in the Plan period, to assist in the early delivery of housing for Kenilworth.

Other

Representation ID: 107929

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

The Further Advice on Housing & Employment Land Needs report shows that there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows that 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR identifies that the annual need for 374 affordable dwellings has only been met 3 times since the start of the plan period. The number of households on the two Councils’ housing registers has increased from 7,048 in April 2021 to 7,684 in April 2023.

To ensure the policy is sound, it should specify the type of affordable housing required (including the minimum proportion of Social Rent homes required), with reference to local needs identified in the evidence base, in line with NPPF Paragraph 64 of the NPPF. This will ensure that the policy is justified and sound. The HEDNA identified a need for 4,200 units of specialist housing, and around 1,450 care and nursing home bedspaces. This specialist accommodation accounts for 13% of overall housing need. The Further Advice on Housing & Employment Land Needs report does not provide updated figures, but states the provision of retirement housing, extra care and residential care/nursing home spaces will all be necessary to meet the needs of an ageing population. Policy requirements for housing for older people must be justified by the latest evidence.

Other

Representation ID: 107930

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

Draft Policy Direction 12 – Locations for Employment Growth and 13 – Core Opportunity Area

Neither of these policy directions are objected to in principle. However, the land at Thickthorn should not be retained as an employment allocation if there is no prospect of the land coming forward for its identified uses. As the Site is not considered suitable for B8 uses, this restricts market options. The Market Report accompanying this submission shows that demand in the Industrial and Logistics market is dominated by the B8 Storage and Distribution sector, which makes up 70-80% of all take-up of units. The market for newbuild office and R&D floorspace is extremely challenging outside of prime locations and there is very little if any new floorspace being delivered, with occupiers focusing on second-hand space.

The information submitted with these representations demonstrates a lack of interest in the Site for Use Class E (formerly B1) or B2 uses and consideration should be given to alternative uses, as promoted in this submission, which would still contribute to the economy and growth within South Warwickshire.

Other

Representation ID: 107931

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

Draft Policy Direction 12 – Locations for Employment Growth and 13 – Core Opportunity Area

Neither of these policy directions are objected to in principle. However, the land at Thickthorn should not be retained as an employment allocation if there is no prospect of the land coming forward for its identified uses. As the Site is not considered suitable for B8 uses, this restricts market options. The Market Report accompanying this submission shows that demand in the Industrial and Logistics market is dominated by the B8 Storage and Distribution sector, which makes up 70-80% of all take-up of units. The market for newbuild office and R&D floorspace is extremely challenging outside of prime locations and there is very little if any new floorspace being delivered, with occupiers focusing on second-hand space.

The information submitted with these representations demonstrates a lack of interest in the Site for Use Class E (formerly B1) or B2 uses and consideration should be given to alternative uses, as promoted in this submission, which would still contribute to the economy and growth within South Warwickshire.

Other

Representation ID: 107932

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

Protecting and enhancing town centres accords with the NPPF policy guidance. However, this shouldn't constraint investment and opportunity in the area. The Kenilworth Town Centre and primary shopping boundary is a contained area with development adjacent in all directions. To ensure choice and competition and encourage additional investment in Kenilworth it may be appropriate to identify other locations that could accommodate retail development. The Site at Thickthorn could be such a location, within the defined settlement boundary and accessible by a choice of modes of transport. There has been interest from retail providers who see the site as suitable for a supermarket offering. It is available, deliverable and suitable for such a use and within a Priority 1 Area in the emerging Spatial Strategy, at the top of the hierarchy for locations for future growth and development.

Other

Representation ID: 107933

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

Barwood Land support high quality design. The overarching strategic design principles align with national policy. The policy direction refers to 20-minute neighbourhoods, which the SA notes would result in positive impacts for many SA Objectives. The policy should define the principles of such neighbourhoods. This may be based on the Town and Country Planning Association (TCPA)’s 20-minute Neighbourhoods guidance (March 2021). Kenilworth, being a Priority 1 Area could deliver such a vision, including Barwood Land’s interests. Their development for flexible uses would contribute to the concept of 20-minute neighbourhoods as identified by the Site’s location in relation to services, amenities and facilities, referred to in the ‘Site’ section of this submission.

Other

Representation ID: 107935

Received: 07/03/2025

Respondent: Barwood Land

Agent: Pegasus Group

Land at Thickthorn, Kenilworth is allocated under Policy DS9 in the Warwick Local Plan. The subject site has a current reserved matters application W/24/1536 and the wider site has had a number of approvals and is under development. The subject site has been actively marketed for B1 and B2 uses with limited interest, as evidenced in the marketing report. The site could accommodate Use Class B8, a supermarket, or residential development. We request that the Councils give consideration to all three uses.