Preferred Options 2025
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Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-42-Trees, Hedges and Woodland?
Representation ID: 108842
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
The policy seeks to protect trees of ‘value’. It is unclear what the LPA consider is a tree of ‘value’. National policy only seeks to protect irreplaceable habitats which include veteran trees and ancient woodland (NPPF paragraph 193). The SWLP should not seek to protect every tree which is not ‘dead’ or ‘dangerous’. The policy should seek for trees to be protected ‘where possible’.
The policy also states that development will be expected to increase tree canopy cover. We object to this requirement. The feasibility of this requirement as well as its impact on the viability and a site’s ability to be delivered efficiently has not been evidenced and justified. Trees with a large canopy cover need to be properly located on development sites away from proposed built development (e.g. to avoid shading / shadowing and root damage to hard standing). Therefore, the more trees proposed, the greater the likelihood that the developable areas of a development site will be impacted.
No
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction 43c- Open Spaces?
Representation ID: 108843
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
We object to the proposed requirement for developments that result in the loss of open space to only be permitted where they provide significant public benefits. This does not align with national policy (NPPF paragraph 104) and should be properly justified.
Where off-site open space provision is required, the policy seeks to ensure this is delivered within 400m. The policy will need to state that this is required ‘where possible and practicable’. Enhancements within 400m of the site may not always be achievable and should be determined on a site by site basis.
No
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction 43d-Urban Parks and Play Areas?
Representation ID: 108844
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
The policy proposes that Multi Use Games Areas (MUGA) will be requested as part of Major development sites and the aspiration is that every resident will have a MUGA available to them within 15 minutes’ walk. The threshold to delivering MUGAs should only be required in line with national guidance such as the Fields for Trust guidance which sets a requirement of 0.3ha per 1,000 people. The threshold for ‘major’ development is significant. A site of just 11 dwellings could be counted as ‘major’ but it would not be appropriate for a scheme of this scale to deliver a MUGA. The provision of MUGAs should be agreed on a site by site basis.
No
Preferred Options 2025
Do you agree with the approach laid out in Policy Direction 43e Allotments, Orchards and Community Gardens?
Representation ID: 108845
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
This policy proposes that development provides space for growth through allotments, orchards and gardens however the policy does not set a threshold for what type and size of development should seek to provide this space, it is also not clear how much space will be required. We consider that the policy should be amended to provided more flexibility as not all development will be able to provide onsite allotments, orchards and/or community gardens and consideration on the impact on site capacity and viability is necessary.
No
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-45- Areas of Restraint?
Representation ID: 108846
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
We object to draft Policy Direction 47 as it is not supported by sufficient evidence to designate Areas of Restraint. We also note that further evidence is being produced to inform the landscape character of sites and is expected to be published with the Regulation 19. It is unclear whether new areas of restraint are being proposed in Warwick District and where these will be located. Therefore, the draft policy is not considered to be justified, as required in NPPF paragraph 36.
No
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction 47- Special Landscape Areas?
Representation ID: 108847
Received: 07/03/2025
Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon
Agent: Savills
We object to draft Policy Direction 47 as it is not supported by sufficient evidence to designate Special Landscape Areas (SLAs). We also note that further evidence is being produced to inform the landscape character of sites and is expected to be published with the Regulation 19. It is unclear whether new SLAs are being proposed and where these will be located. Therefore, the draft policy is not considered to be justified, as required in NPPF paragraph 36.