Preferred Options 2025

No

Representation ID: 108832

Received: 07/03/2025

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

Agent: Savills

This policy is prescriptive and does not allow much flexibility to site specific circumstances. ‘Where possible, practicable and viable’ should be added throughout.
The policy requires sites which include existing watercourses to appraise the risk of flooding, this may be through hydraulic modelling. The policy also notes that development layout should be sympathetic to any existing watercourse and overland surface water flow routes. The policy should align with national guidance which seeks for built development to avoid areas at risk of flooding, public open space within an area at risk of flooding should be supported (NPPF paragraph 175).

Other

Representation ID: 108833

Received: 07/03/2025

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

Agent: Savills

Bellway is generally supportive of the principles set out in draft Policy Direction 25. However, the design principles set out are not justified unless they are to be considered on a site-by-site basis and incorporate flexibility to adapt to site specific circumstances. Design codes should not be overly prescriptive or restrictive where they are not informed by detailed evidence and engagement with the Applicant team.
In addition the reference in the Policy Direction to ‘the principles of the 20-minute neighbourhood’ should be applied flexibly. At present the wording of the policy does not define what is considered to be ‘a reasonable walking distance of their homes’ or acknowledge potential implementation challenges.
It is noted that page 3 of the “Guide to existing housing densities in South Warwickshire” (January 2023), which forms part of the SWLP technical evidence, defines a 20-minute neighbourhood as “every-day services to be accessible within a 10-minute walk or cycle each way”. This is an unrealistic aim for larger strategic residential developments located adjacent to larger settlements, as well as developments within smaller settlements, where infrastructure constraints and service provision limitations make such proximity difficult to achieve.
Accordingly any design measures must be justified with evidence (as required by paragraph 36 of the NPPF) and worded to allow for site-by-site consideration of requirements, rather than apply a blanket approach to new development.

Other

Representation ID: 108834

Received: 07/03/2025

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

Agent: Savills

Table 8 states that the production of site-specific design codes will be led by the SWLP team. The production of site-specific design codes should be done with collaboration between SWLP and sites’ landowners / developers /
promoters to ensure effective engagement and the site’s deliverability.

No

Representation ID: 108835

Received: 24/09/2025

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

Agent: Savills

The Policy Direction requires major development to be supported by a Health Impact Assessment. It is considered that the plan should set a threshold for what the policy considers to be ‘major’ to ensure that the policy and requirements are clear (NPPF paragraph 16d). Without a clear threshold, assessments could become inconsistent and create uncertainty. Therefore it is important that the Policy Direction provides the necessary clarity to ensure the requirement is justified (as required by paragraph 36 of the NPPF).
Policy Direction 30 states that: “developments with significant negative impact on health and wellbeing will not be supported unless mitigated or compensated for through planning obligations”. This is a broad statement and does not define what is considered a constitute a negative impact on health. It should accordingly be made clear that any mitigation / compensation should be site specific, and would need to comply with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (as amended).

No

Representation ID: 108836

Received: 07/03/2025

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

Agent: Savills

Bellway object to draft Policy Direction 32, providing that it does not seek to go beyond the Building Regulations Approved Document S which states:
‘’In respect of new residential building, the number of associated parking spaces that have access to an electric vehicle charge point must be a minimum of either of the following:
a. The number of associated parking spaces.
b. The number of dwellings that the car park serves.
If some associated parking spaces are not required to install electric vehicle charge points, then cable routes may need to be installed.’’
As the Council is seeking to go beyond these requirements in emerging policy, then suitable evidence is required to be provided to ensure it is justified in line with paragraph 36 of the NPPF.
Turley, Sustainability and ESG, have undertaken a review of Policy Direction 32 and state that in addition to setting out a strategy for EV charging infrastructure within Council buildings and public realm the Policy notes the need for robust policies for EV structure in new development.
Bellway supports the installation of EV infrastructure and notes that Part S of the Building Regulations { Infrastructure for charging electric vehicles: Approved Document S - GOV.UK} sets out requirements for EV charging in new development, with an EV charger required for every house with dedicated parking, as well as non-residential development requirements.
The policy notes the greatest challenge is installing EV charging infrastructure in existing areas, in particular this will include urban areas with terrace housing, where the lack of charging infrastructure and low cost charging is a barrier to uptake of EVs.
Turley have agreed in their review that any provision beyond the Building Regulations will need to be justified, evidenced and considered as part of a viability assessment.

Other

Representation ID: 108837

Received: 07/03/2025

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

Agent: Savills

We understand that the Warwickshire Local Nature Recovery Strategy (‘LNRS’) is in the early stages of consultation, and it is not yet clear what the draft LNRS will include. This work will need to be completed in order to inform the draft policy. If not, the feasibility and viability of ‘maintaining and enhancing local ecological networks through habitat creation, protection, enhancement, restoration and/or management’ as currently stated in the draft Policy Direction, should be considered to ensure that allocations coming forward in the plan are positively prepared and that allocated sites can deliver housing to meet South Warwickshire’s need. The policy should be worded with additional flexibility, such as adding ‘where possible and practicable’.

No

Representation ID: 108838

Received: 07/03/2025

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

Agent: Savills

We object to the consideration in draft Policy Direction 38 to seek a higher percentage of biodiversity net gain (‘BNG’) than the mandatory 10%. If a higher percentage is sought, then the policy should be supported by evidence base to ensure that the policy is justified in line with NPPF paragraph 36. Consideration should also be given to the implications that a higher BNG would have on the viability of sites and their ability to be delivered efficiently. The provision of on-site BNG above 10% will have implications on site yields and is likely to lead to more sites requiring allocation to meet the significant development needs of South Warwickshire.

No

Representation ID: 108839

Received: 07/03/2025

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

Agent: Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works in practice. To our knowledge, there are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

Representation ID: 108840

Received: 07/03/2025

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

Agent: Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

Representation ID: 108841

Received: 07/03/2025

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

Agent: Savills

The policy seeks to protect and enhance carbon sinks. Reference is made to a supporting plan but these plans are unclear. More detail needs to be provided to demonstrate how much of the district is considered to be a ‘carbon sink’ and the Council’s justification for this identification.