Preferred Options 2025

No

Representation ID: 108734

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We object to Draft Policy A as currently worded, on the basis that some of the requirements within the policy are not supported by adequate evidence and therefore the policy is unsound as it does not meet the requirements of NPPF paragraph 36. Planning Practice Guidance (Paragraph: 002 Reference ID: 56-002-20160519) is clear that the Nationally Described Space Standard (NDSS) is an optional technical standard and that LPAs will need to gather evidence to determine whether there is a need for additional standards, including consideration of viability (Paragraph: 003 Reference ID: 56-003-20150327) . No evidence has been provided as part of the Preferred Options consultation documents to justify the requirement for NDSS, and therefore we consider this element of the policy to be unsound and not in accordance with NPPF paragraph 36.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is also unevidenced and goes beyond the requirements of NDSS. The 2022 Coventry and Warwickshire
Housing and Economic Development Needs Assessment (HEDNA) does not provide clear justification for the need for this additional bedroom requirement and therefore we consider that this element of the policy lacks justification and does not accord with NPPF paragraph 36(b).
We note that the 2022 HEDNA recommends at paragraph 14.74 that all dwellings are constructed to M4(2) standard and 10% are constructed to M4(3) standard, with the potential to require a higher percentage for affordable housing. However, there is no justification within the SWLP evidence base for 25% of affordable dwellings to meet the M4(3) standard and so we consider this element of the policy to be unjustified and therefore unsound unless sufficient evidence is provided to demonstrate a clear need for this in line with the requirements of Planning Practice Guidance (Paragraph: 005 Reference ID: 56-005-2015032)
. Planning Practice Guidance (Paragraph: 007 Reference ID: 56-007-20150327)also states that as part of the requirement to demonstrate a clear need for requiring M4(2) or M4(3) standards, LPAs should take into account the overall impact on viability. We wish to highlight that the Councils must provide robust evidence that the requirement for residential development to be built to increased accessibility standards will not impact viability, and therefore housing delivery.
Overall, we consider that prior to the next stage of consultation, the Councils will need to demonstrate that the above requirements do not pose significant challenges to the overall viability of the plan.

No

Representation ID: 108735

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We object to Draft Policy B as currently worded. We consider that the requirement for 5% of the developable area of sites of more than 100 dwellings to be made available for self-build and custom-build homes does not reflect existing residual demand across the SWLP area. Planning Practice Guidance (Paragraph:011 Reference ID: 57-011-20210208) states that local authorities should use the demand data from the registers in their area to understand and consider future need for this type of housing in their area. The Warwick District Council Authority Monitoring Report (2022-23) identifies a residual unmet demand of 35 plots (p.33) for the monitoring period. Table 3 in the Stratford-on-Avon Self-Build and Custom Housing Position Statement (December 2024) showed a surplus of 18 plots in the most recent monitoring year (2020/21). We do not consider that this provides sufficient evidence to justify a 5% requirement. Furthermore, we consider that the modest residual demand (and slight surplus in Stratford District) suggests that the market is already delivering sufficient housing of this type without the need for a specific policy requirement. The unevidenced requirement potentially represents an unnecessary delay to housing delivery later down the line, where marketing of these plots is required.
We consider that there is insufficient evidence to justify the requirement for allocated plots to be delivered at a range of costs, sizes and types, in accordance with the latest identified local need. We consider this policy requirement to be overly prescriptive and reliant on factors which are out of the control of housebuilders who will be expected to provide serviced plots of land as part of larger sites. It is also considered to be likely that individuals wishing to build their own homes will prefer to do so on smaller sites as opposed to at large urban extension sites. Therefore, we consider that small scale self/custom build sites should be identified specifically to meet identified needs for this type of development. We consider that if a bespoke call for sites exercise was undertaken in respect of custom and self-build opportunities (e.g. for sites of 1Ha or less) then the Council would be inundated with landowner responses willing to have their land identified as being available for custom and self-build opportunities for small scale development.

No

Representation ID: 108736

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We object to the draft policy direction on the basis that the requirement for sites of 500+ dwellings to provide gypsy and traveller plots is unjustified and therefore does not comply with the requirements of NPPF paragraph 36. The Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Assessment (August 2024) sets out the number of gypsy and traveller pitches required in the plan area. Paragraphs 8.27 and 8.28 identify a need for between 74 and 89 permanent pitches across the plan period, as well as 18 additional travelling showpeople plots. Paragraph 8.14 recommends that new sites do not exceed 20 pitches, suggesting that circa 4-5 new pitches are required during the plan period.
Paragraph 8.6 of the assessment states that “there is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security”. Therefore, we question whether requiring sites of over 500 dwellings to provide pitches is a justified approach, particularly given the modest need identified in the evidence base. We consider that it would be more appropriate to engage with the gypsy and traveller community to identify the locational requirements to meet their specific needs rather than arbitrarily requiring any site greater than 500 dwellings to make the provision. Only this approach would ensure that this need can be met in the right locations. Therefore, the evidence base for the provision of gypsy and traveller accommodation should be enhanced to ensure the locational requirements are appropriately met.

Yes

Representation ID: 108737

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support the recognition and proposed strategy set out in Figure 10 the draft plan which identifies a Core Opportunity Area (COA) which is proposed to be the focus for new employment development in
the South Warwickshire Area. We consider that the COA should also be supported by a commensurate level of housing development to support sustainable patters of growth. This in turn will support the Spatial Growth Strategy the Council propose to pursue – “Sustainable Travel and Economy”.

Other

Representation ID: 108738

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We broadly support the contents of Chapter 7 of the plan and agree that combatting climate change through the planning process is becoming an increasingly important consideration in achieving sustainable development.
However, we wish to stress that any requirements included in the Regulation 19 version of the SWLP must be the subject of robust viability testing to ensure that these requirements, along with other key policy requirements in the plan (e.g. affordable housing, Biodiversity Net Gain) do not compromise the delivery of housing through the plan period. We also consider that all policies in this chapter should be drafted on a ‘subject to viability’ and ‘subject to feasibility’ basis, to ensure that individual site-by-site circumstances can be taken into account when individual site allocations come forward. We welcome the recognition, which is included in the justification text for the policies in Chapter 7, that further work needs to be undertaken to demonstrate that the policies are deliverable ahead of the Regulation 19 stage.
We also appreciate that the Councils are cognisant (at pages 118-119 of the Preferred Options document) of the Government’s Written Ministerial Statement dated December 2023, which states that any proposed planning policies which propose energy efficiency standards beyond current or planned building regulations should be rejected at Examination if they do not have a well-reasoned and robustly costed rationale. We trust that the Councils will take this into account as further work is completed to progress these policies ahead of the next consultation stage.

No

Representation ID: 108739

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We object to Draft Policy H as currently worded. Planning Practice Guidance (Paragraph: 014 Reference ID: 56-014-20150327 and Paragraph: 015 Reference ID: 56-015-20150327) states that where there is a clear local need, Local Plan policies can “require new dwellings to meet the tighter Building Regulations optional requirement of 110 litres/person/day”. LPAs are required to establish a clear need
based on:
• “existing sources of evidence.
• consultations with the local water and sewerage company, the Environment Agency and catchment partnerships.
• consideration of the impact on viability and housing supply of such a requirement.”
We recognise that the Water Cycle Study (2024) produced to support the plan recommends that a water efficiency standard of 100 litres/person/day should be required in the SWLP. However, there is no basis for implementing such a strict requirement, which goes beyond the optional technical standard of 110 litres.
The Written Ministerial Statement issued on 13 December 2023 (Statement UIN HCWS123, 13 December 2023)
states that “the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations”. The statement goes on to state that any planning policies which propose standards in excess of current or planned building regulations must ensure that development remains viable and that the impact on housing deliverability and affordability is considered. Aat this stage in the plan-making process, the evidence base for the SWLP does not include evidence to demonstrate the viability of the 100 litres/person/day requirement. In the absence of this information to justify the policy requirements, we object to the policy as currently worded due to a lack of compliance with national planning policy as set out in the PPG.

Yes

Representation ID: 108740

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy I, which requires development proposals to ensure that there is adequate water supply to serve new development and also requires the use of suitably designed SuDS schemes to manage surface water runoff.
With regards to wastewater infrastructure, SLR have produced a Preliminary Flood Risk Assessment and Surface Water Drainage Strategy (Appendix 3) which states at Section 7 that there is a Severn Trent Water public foul sewer which crosses the site north-south. It is therefore proposed that any development at Budbrooke Lodge Farm, Warwick (part of the SG08 Strategic Growth Option) would connect to this public sewer and there is unlikely to be a requirement for a pumped drainage solution.
Appendix E of SLR’s report provides a combined flood risk constraints plan. This has been used to inform the Framework Masterplan and Vision Document produced by Node (Appendix 1), which confirms that development can be located outside of areas considered to be at risk of flooding. As set out above, SLR consider that the EA’s flood mapping could potentially be overexaggerating the extent of risk across the site. Therefore, the approach in the concept plan is considered to be a conservative approach, in the absence of any hydraulic modelling having been undertaken to date.

Yes

Representation ID: 108741

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy J and agree that new development should be prioritised in areas at lowest risk of flooding.
We note that Strategic Growth Option SG08 (West of Warwick Group) scores relatively poorly in relation to flood risk in the HELAA Part B assessment. SLR has produced a Preliminary Flood Risk Assessment and Surface Water Drainage Strategy (Appendix 3) in support of these representations. This document considers how land at Budbrooke Lodge Farm, which forms part of SG08, could be developed in a way which ensures that development is located outside areas at risk of flooding in line with the aspirations of Draft Policy J.
With regards to surface water flood risk, SLR state at section 5.2 of their report that much of the existing surface water flood risk is likely to be caused by overland flows which pool in the topographically lower areas of the site. It is considered that appropriate management of surface water via SuDS systems can appropriately manage surface water flows across the site.
Overall, it is considered that flood risk does not pose a significant constraint to residential development at land at Budbrooke Lodge Farm. Any areas of the site which are at risk of flooding will not contain built development and can instead be utilised to provide high quality public open space for new and existing residents.

Yes

Representation ID: 108742

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy K in principle and agree that development should not be permitted where there is an increase in flood risk to the site or surrounding area. We agree that high quality SuDS features should be implemented proportionately to manage surface water runoff. SLR has produced a
Preliminary Flood Risk Assessment and Surface Water Drainage Strategy (Appendix 3) in support of these representations. This document considers how land at Budbrooke Lodge Farm, which forms part of Strategic Growth Option SG08, can provide a surface water drainage solution which ensures SuDS features are used to manage surface water run-off.
A concept plan and vision document have also been produced by Node (Appendix 1). These documents incorporate the recommendations of SLR’s work to ensure that suitable and appropriate SuDS features are incorporated into the site masterplan to ensure the appropriate management of surface water across the proposed development. As the SWLP preparation process continues, further technical work can be undertaken to further demonstrate the suitability of the site and proposed SuDS features.

Yes

Representation ID: 108743

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy Direction 25 in principle and agree that the principles listed within the policy direction will contribute to achieving development which meets the design aspirations set out in Chapter 12 of the NPPF.