Preferred Options 2025

No

Representation ID: 107786

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to Policy Direction 1 as the policy sets out both the Coventry and Warwickshire Housing and Economic Development Needs Assessment (2022 HEDNA) and Standard Method figures for the number of dwellings required for Warwick and Stratford across the plan period.
The HEDNA (2022) sets out a housing need of 41,975 dwellings for the 25-year plan period. This document was prepared over 2 years ago and does not reflect the recent changes to the Standard Method (December 2024). The Standard Method identifies a minimum housing need of 54,700 dwellings over the plan period. The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.

Other

Representation ID: 107787

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We note that a New Settlement is proposed to be allocated for strategic growth in a sustainable location. Although we do not object to a proposed new settlement, new settlements take a significant amount of time to deliver and it will therefore be important to allocate a sufficient number of sites which can be delivered in the short term, Site ID 471/466 within proposed Strategic Growth Location SG19. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).

The NPPF is clear that where new settlements are proposed in plans, the policies should be set within a vision that looks further ahead, at least 30 years, to take account delivery timescales (paragraph 22). The SWLP will only cover the period of 25 years up to 2050 and should therefore be extended.

No

Representation ID: 107788

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to the part of the Policy which states that the SWLP will support Neighbourhood Plans allocating sites.
We acknowledge that there may be a role for some growth to be identified in Neighbourhood Plans, however, the SWLP has no control on when NPs will be produced or reviewed to accommodate growth and therefore, there should not be an over reliance on NPs delivering growth. Major and small-scale sites should be allocated as part of any future Part 2 plans. Any growth directed to NPs will need to set a specific requirement and the LPAs should be
satisfied that the NPs will progress and deliver much needed housing within the plan period.

No

Representation ID: 107789

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to draft Policy Direction 10 that providing the right tenure and type of homes will only have regard to the latest evidence. This should be one of a few factors. The latest evidence is the Coventry and Warwickshire HEDNA 2022, which, as already stated above, is based on the old standard method figures. Existing evidence will become out of date during the lifetime of the plan. Housing mix and tenures should be left to be agreed on a site-by-site basis and informed by market demand at the time of the application as that is the best indicator of need.

No

Representation ID: 107790

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to the proposed requirement development sites of over 100 dwellings to deliver 5% self-build and custom-build plots. There is no evidence to justify the requirements for allocating a percentage of plots on sites to provide custom-self build and whether there is a projected need to identify this level of provision. There is also no specific requirement in the PPG (reference 57-025-20210508) to require allocated sites to deliver self and custom build plots.
We are aware that Stratford on Avon District Council produce an annual position statement (December 2024) which sets out the demand for Self-build and Custom Housebuilding. The demand in Warwick District differs to the demand in Stratford District, therefore we object to the blanket approach of 5% for all developments of more than 100 dwellings. We consider that the LPAs should continue with the approach which provides overall support for self-custom build development but leaves it to the housing market to deliver plots when demands arises or allocate specific sites to deliver self and custom built plots to meet identified need where evidenced.

Other

Representation ID: 107792

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We are generally supportive of draft Policy Direction 31.
Bellway’s land (Site reference 466/471) is part of proposed Strategic Growth Location SG19 which has been identified for growth and the settlement is also located in Priority Area 3, therefore is considered a sustainable and accessible location suitable for accommodating growth. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).
The second part of the Policy proposes to require developments to demonstrate that they will incorporate or contribute towards the provision of cycle lanes, pedestrian paths and public transport and public transport links should be integrated into the development. The policy should specifically note that not all development will be of a scale to enable public transport links through the site. Additionally, only developments subject to a S106 Agreement would be able to contribute to off-site sustainable access improvements and any requests for upgrades will be required to demonstrate that they are complaint with Section 122 of the Community Infrastructure Levy Regulations 2010.

Other

Representation ID: 107793

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We note that further evidence is being produced to inform the landscape character of sites and is expected to be published with the Regulation 19 SWLP. We withhold comment until this evidence has been made available. The policy should be clear that it is not just ‘local need’ but District wide need which would outweigh landscape harm.

Yes

Representation ID: 107794

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

SG19 is extremely well-located and in close proximity to the eastern edge of Stratford-on-Avon, which is the largest settlement in the District. SG19 is therefore located in close proximity to existing transport links and facilities / services and employment opportunities. This accessibility is reflected in the SA with SG19 being the 4th best performing SGL against SA objective 11, for accessibility and performs well against Objective 13 (economy).
We note that SG19 scored ‘minor negative’ for landscape (objective 4). A Landscape Assessment has not yet been published to support the SWLP so it is unclear how this has been evidenced. The Landscape is not statutorily designated in this location so we assume this score is a result of the site being greenfield and on the edge of a settlement. Further evidence is required to justify the score in the SA. However, we note that compared to the other SGLs, SG19 scores well comparatively.
Furthermore, we do not support the ‘major negative’ score applied for cultural heritage (objective 5). We expect this assessment is likely been deduced as the SG19 site covers a wider land interest than Bellway’s land which is not constrained by any heritage assets. This is confirmed in the HELAA which concluded that Site ID 471/466 scores ‘Green’ for heritage, meaning ‘the location/site does not include any designated heritage assets, and it is unlikely to directly impact upon the setting of any heritage assets’ (HELAA methodology November 2024).
As the largest and most sustainable settlement in the District, the most housing growth should be directed to Stratford-on-Avon and SG19, and Bellway’s land, is well placed to deliver this growth.
In light of the above, proposed SGL SG19 is one of the higher performing proposed SGL in the SA and it should therefore be allocated wholly or in-part within the SWLP. Bellway’s land (Site ID 466/471) is located within SGL SG19 and has been assessed positively within the HELAA. We therefore strongly support the proposed allocation of SG19 and Site ID 466/471.

Yes

Representation ID: 107795

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway’s site (Site ID 466/471) is located within the proposed SGL SG19. As stated in our separate responses, Bellway strongly support the proposed allocation of their land. Reference to two site ID’s is included as Bellway’s land has been assessed as the eastern half of site ID 471 (c.4ha) (Land North of Loxley Road, Stratford upon Avon) and the eastern part of a wider parcel, site ID 466 (c.16.73ha) (Land at Knights Lane, Loxley Road and Pimlico Lane, Stratford upon Avon).
Site ID 466 scored 34.40 overall and Site ID 471 scored 33.30 overall. Across all sites assessed in Part B, the median score was 45. We note a lower score is considered better and therefore Site ID 466/471 score reflects a very positive assessment and is better performing than the majority of sites assessed in the HELAA.
In the ‘Settlement Design Analysis’ (January 2023), Site ID 466 has also been given a ‘connectivity grade’ of ‘B’ which is good connectivity. The SWLP evidence base therefore recognise that the Site ID 466/471 is in a sustainable and accessible location.
Site ID 466/471 is located on the edge of the largest and most sustainable settlement in the District which offers a wide range of services and facilities and is served by public transport. The Site is also not located within the Green
Belt or restricted in terms of any landscape or ecological designations. Site ID 466/471 also offers the opportunity for housing delivery in the short term as it is in single ownership and being promoted by a housebuilder.
In light of the above, Site ID 466/471 should remain as a proposed residential allocation within the SWLP.

No

Representation ID: 108821

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

The Policy states that the SWLP will be underpinned by housing need and availability evidence base. As stated in our response to Policy Direction 1, the HEDNA is required to be updated to reflect the updated Standard Method and the implications that this may have on the Coventry and Warwickshire Housing Market Area (‘HMA’) and the Greater Birmingham and Black Country HMA. The majority of authorities within the HMAs are seeing an increase in their minimum housing need.
The NPPF is clear that the housing needs of neighboring authorities should be met over the plan period (paragraphs 11 and 69). In order to be positively prepared (NPPF paragraph 36), the SWLP should make a contribution to the both HMA shortfalls.