Yes

ID sylw: 105767

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

Asiant : Savills

Wates Development support Draft Policy Direction 12, which incorporates the findings from the South Warwickshire Employment Land Study and the West Midlands Strategic Sites Study. We believe it is essential to identify suitable sites for non-strategic employment development in the Regulation 19 plan. Wates Developments propose Coppington Farm in Wellesbourne, a 32ha site, for an employment-led scheme that meets local needs. Its proximity to the M40 and the University of Warwick makes it suitable for development. We are eager to engage with stakeholders to ensure the site is developed comprehensively with the necessary infrastructure.

Other

ID sylw: 106891

Derbyniwyd: 06/03/2025

Ymatebydd: Historic England

We note that two potential strategic employment sites in Warwick District are being considered in this consultation document.

The first, land at Red House Farm, to the south of Leamington, presumably forms part of Strategic Growth Location SG09 – South of Europa Way; identified as being potentially suitable for mixed use development. Whilst we have greater concerns about the impact of development of the most northerly parcel of land within SG09, the parcel around Red House Farm also has the potential to cause harm to heritage assets, particularly to the setting of Warwick Castle RPG (GI), and we strongly recommend that a HIA is carried out prior to allocation.

In terms of the second potential strategic employment site at Wedgnock Park Farm, we note that this is SG07, and we have no comments to make regarding this option.

Other

ID sylw: 107022

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 6.1, Policy Direction 12 – Locations for employment growth
The MOD would like to see this policy provide recognition of, and support for, additional development at
existing sites providing employment in the South Warwickshire area, rather than focussing solely on new
locations for growth.

Other

ID sylw: 107036

Derbyniwyd: 21/02/2025

Ymatebydd: Coventry and Warwickshire Chamber of Commerce

The CWCC does not, at this stage have a strong preference for the sites identified. As it has noted elsewhere the Chamber favours a final figure for employment land provision at the upper end of the range (125 ha) and believes that this figure should be a minimum and that it should also be informed by further qualitative work that could help both refine the overall target figure to 2050 and, critically, inform the
type of sectoral provision that is required across the development plan period.
There are two major “Strategic sites” identified and clearly both sites have the potential to make a major contribution to employment provision. However as noted in the text
the timing of implementation may differ and that may be important to ensure a steady “flow “of employment opportunities over the plan period.

In the final paragraph of this Policy Direction there is a recognition that the larger sites portrayed in this Policy may be unsuitable to accommodate and expand the range of smaller businesses and enterprises located in smaller towns and villages. This is in line with the current NPPF and Section 6.6 of the draft proposals. This recognition/acknowledgement is welcomed by CWCCC.

Other

ID sylw: 107060

Derbyniwyd: 27/02/2025

Ymatebydd: Nuneaton & Bedworth Borough Council

The Preferred Options states that three ‘priority areas’ have been delineated which determine areas of land which fall within the Spatial Growth Strategy, based on proximity to the various elements that form part of the Strategy. South Warwickshire’s existing urban areas fall within Priority 1, and full use will be made of suitable urban brownfield land before development is considered elsewhere. However, the SWLP outlines that there is insufficient urban brownfield land to accommodate South Warwickshire’s housing and employment land needs and so the majority of SWLP’s strategic growth needs will be met within priority areas 1-3.

Draft Policy Direction 12 – Locations for Employment Growth, identifies specific sites for allocation in the Regulation 19 version of the SWLP. To note, Wedgnock Park Farm is also proposed as a potential Strategic Growth Location (SG07) in the SWLP. NBBC considers the three strategic sites under consideration are consistent with the requirements set out in the WMSESS and is supportive of utilising previously developed land, which the Coventry and Warwickshire HEDNA identified by using gross completions. NBBC also considers that an amount of supply could be accounted from recycling existing employment sites.

Other

ID sylw: 107197

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

In terms of economic need, it is welcome that South Warwickshire has identified potential locations to accommodate strategic employment sites as identified in the recent West Midlands Strategic Employment Sites Study and that it plans for the continued growth of well-established economic assets of regional importance.

Other

ID sylw: 107236

Derbyniwyd: 26/02/2025

Ymatebydd: Oxfordshire County Council

Significant amounts of local industrial need are identified, as well as 75-125ha of strategic employment need. A Strategic Rail Freight Interchange is also identified as being needed, but at this stage the location has not been decided.

Other

ID sylw: 107243

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Meeting Employment Need
SMBC welcomes the inclusion within the Preferred Options plan of land to meet strategic employment needs as identified in the West Midlands Strategic Employment Sites Strategy. SMBC participated in this joint study and acknowledges the outcome. It is noted that the plan includes provision for the upper limit of the requirement identified in the WMSESS (between 75 to 125ha) for the M40 / A46 corridor in South Warwickshire to reflect that the WMSESS only forecasts up until 2045. The figure derived from the WMSESS relates to the whole study area rather than individual authority areas. Two sites capable of meeting the qualitative and quantitative strategic need have been identified. SMBC expect the delivery of strategic employment sites and the relationship to labour patterns and wider housing need within the housing market area to continue to form part of duty to cooperate discussions. Further consideration of these matters following the outcome of this consultation and as part of part 2 of the West Midlands Strategic Growth Study will be needed.
It should also be acknowledged that the provision of strategic employment land, whilst primarily to provide sites of a size and nature to attract large scale regional or national operators will also meet local needs.
The plan also identifies a Core Opportunity Area based on the road opportunity area (ROA 8) and rail opportunity area (ROA 4) identified within the WMSESS and the South Warwickshire Employment Land study 2024. The Core Opportunity area will be the focus for new employment within South Warwickshire. It is noted that this includes the area around Burton Green which adjoins the Solihull local authority boundary. Major investment sites have been identified within the plan area including the University of Warwick to the north of the plan area. Any expansion or significant economic development to the south of Solihull may have implications for the wider transport network and delivery of economic objectives and would need to be considered as part of duty to cooperate discussions.

Yes

ID sylw: 107257

Derbyniwyd: 07/03/2025

Ymatebydd: R. Adams & Sons R. Adams & Sons

Asiant : Iceni Projects

The sentiment of this policy is supported. However, we strongly promote the allocation of small and medium sites to meet employment need to avoid an over-reliance on a small number of sites to meet all of employment needs. The allocation of a greater variety of employment sites ensures that there is sufficient employment land to meet the different needs and importantly, help to support the rural economy. In light of the above, the RA&S Site is ideally suited for small scale employment and should be allocated for such.
In addition, given South Warwickshire rural and Green Belt context, as well as supporting large-scale growth, the contribution of small-medium scale businesses in local economies must be recognised and supported. The policy should be expanded to award weight to proposals that: 1) maintain employment opportunities within existing employment sites and the locality; 2) expand existing small-scale businesses; and 3) utilise existing strategic transport networks. Additional allowance and reference should made to Green Belt sites in delivering employment growth.

No

ID sylw: 107535

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. The councils Evidence base recommends that between 75 and 125ha of land be allocated for Employment Growth, however the Plan proposes 125ha, the upper limit of development. This is unnecessary and will have larger impacts on important environmental assets and habitats in the area, as well as designated sites and protected species, and does not align with the Government’s 30% by 2030 targets.
WWT is also concerned regarding the lack of up-to-date employment need evidence with three different studies and Office needs unclear. Also, no evidence for Strategic Industrial Need yet and it only goes up till 2045.
The allocations are directly next to Chesterton Wood, an important Local Wildlife site, and extremely close to the River Avon and Tributaries LWS, Redlands Brake PLWS, New Waters LWS, Budbrooke Farm Woodlands and Black Brake Plantation LWS, development on which would have detrimental effects for wildlife and climate change targets.

Yes

ID sylw: 107543

Derbyniwyd: 05/03/2025

Ymatebydd: Ellis Machinery Ltd

Asiant : Frampton Town Planning

Draft Policy Direction 12 outlines that “it is proposed for the existing 100ha. JLR
allocation at Gaydon (Proposal GLH in the SDC Core Strategy) to be released to the wider market for strategic manufacturing (Use Class B2 use) uses and small-scale logistics (Use Class B8) units”. The release of this land to the wider market will further increase employment provision, providing further justification for identifying locations, such as land off Old Town, Kineton Road, Gaydon for development close to new employment.

Other

ID sylw: 107589

Derbyniwyd: 06/03/2025

Ymatebydd: Birmingham City Council

Employment Land - Birmingham City Council has identified a shortfall of approximately 74hectares of employment land. Again, further work is being undertaken to establish whether that shortfall can be reduced or eradicated, and an update will be provided as part of the revised preferred Options consultation in November 2025.

Other

ID sylw: 107605

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

We note that two principal potential strategic employment site locations have been
identified in the South Warwickshire Employment Land Study (2024) which would
meet the strategic need of providing up to 125 ha of employment land. Both of these
sites at least partially border the SRN, with the Land at Red House Farm site for 121
hectares abutting the M40 and the Wedgnock Park Farm site for 141 hectares
bordering the A46.
These large sites would likely have a significant impact on the operation of the SRN
and would need to be supported by a detailed transport evidence base to determine
impacts and potential mitigation requirements. The Draft Policy Direction also
references the proposal for the existing 100 hectare JLR allocation at Gaydon to be
released to the wider market for strategic manufacturing uses and small-scale logistics
and the impact of this proposal would also need to be appropriately assessed to
determine impacts on the nearby M40. It is noted in the document that further work
will be done prior to the next stage of the SWLP to help to determine the sites put
forward for allocation and this is welcomed.

Other

ID sylw: 107930

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : 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.

No

ID sylw: 108000

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

Draft Policy 12 identifies three potential sites: Land at Red House Farm; Wedgnock Park Farm; and JLR allocation at Gaydon. Each potential site is discussed in turn below:
Land at Red House Farm
Land at Red House Farm comprises approximately 121ha of employment land and appropriate use classes could include E(g)(iii), B2 and B8 uses. This site is reliant on the delivery of a new junction to replace the two one-way junctions at Junction 13 and Junction 14 of the M40, as well as changes to the A452 and B4100. Delivery of new or significantly altered motorway junctions is a complex and timely endeavour. Taking account of the necessary steps to delivery which includes approval of various business cases, obtaining necessary permissions, land assembly (including potential for CPO), numerous stages of design, funding and eventual construction the timeframe for delivering infrastructure of this nature is 5-7 years as a minimum. In CEG and its consultant’s experience it is much closer to 10 years. On this basis, CEG has serious reservations regarding the viability and deliverability of the Red House Farm site.
In addition, there is a large area of ancient woodland and Local Wildlife Site is located to the south, also containing a Scheduled Monument. A further Scheduled Monument is also located to the south east of the junction. To the north lies Bishops Tachbrook Conservation Area. The configuration of the motorway junction is considered to be a significant constraint affecting the suitability of this location for large scale commercial development.
In view of the above, CEG have serious concerns regarding the meaningful delivery of this site the within the period up to 2050. Therefore, the SWLP should be looking at alternative locations for employment growth.
Wedgnock Park Farm
Wedgnock Park Farm comprises approximately 141 ha and is located to the west of Warwick. The site falls entirely within the Green Belt. For this reason and when considering alternative options for employment development such as CEG’s site at Land East of Gaydon, Wedgnock Park Farm is not considered sequentially preferable. Notwithstanding, as set out within the draft policy direction, this site relies on a much broader strategy for growth west of Warwick/Leamington therefore in isolation would not be appropriate. It is also CEG’s understanding that existing capacity at is heavily constrained and would require significant infrastructure improvements to accommodate the level of growth identified.
JLR Allocation at Gaydon
CEG support the inclusion of this allocation within the SWLP however it would need to be released to the wider market. However, the inclusion of a restriction on B8 unit size should be removed. There is no evidence or justification that larger B8 units are not needed to support the automotive supply chain and such a policy restriction could suppress appropriate investment. Not having this site available for strategic B8 upon adoption of the plan
risks the ability for this type of development to be delivered within the first 5-10 years. This is particularly important as alternative sites cannot accommodate this easily, as outlined previously.
Land East of Gaydon and Land East of the M40, Junction 12
CEG request that Land East of Gaydon (included within SG13) and CEG’s site Land East of the M40, Junction 12 (included within SG14), are identified as a location for employment as an extension to the JLR allocation as, jointly, the key economic ‘hub’ within the Local Plan area. The sites extend to approximately 30 ha and 20ha in size respectively and has capacity to deliver significant commercial floorspace at an established employment hub.
Junction 12 has the capacity now and would not require such significant additional highway works to accommodate the full potential growth in the area.(unlike Red House Farm and Wedgnock Park Farm) and would concentrate commercial investment in an area that requires minimal infrastructure investment. The site therefore can come forward early within the plan period. It is clear from the HEDNA (2022) that there is a substantial need for employment floorspace in the District and an acute short term need for floorspace to be available now to satisfy the increasing end-user demand in the District. The ability of CEGs sites to provide readily available floorspace to assist with meeting the overall needs and the short-term user specific demand, is considered to be a significant economic benefit and when assessed against other identified employment options within the SWLP.
The site is also relatively unconstrained, There are no ecologically important sites within or adjacent to the site and it lies entirely within Flood Zone 1. Furthermore, in accordance with the paragraph 147 of the NPPF in relation to taking a sequential approach, it reduced the requirement for Green Belt release.
Therefore, in light of the above, CEG’s land interests should be included as extension to the 100ha JLR allocation which would take the total employment land supply in this location to 150ha covering the strategic needs of the plan period. Moreover, this is currently being assessed but it is anticipated that some 2 million sqft (60ha) of land could come forward before any further major highway infrastructure is required. With CEG controlling all these sites there would be no legal constraints and they can come forward in the short, medium and long term ensuring the SWLP has a continual supply of employment land.

No

ID sylw: 108021

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

Draft Policy 12 identifies three potential sites Land at Red House Farm, Wedgnock Park Farm and JLR allocation at Gaydon. Each potential site is discussed in turn below:
Land at Red House Farm
Land at Red House Farm comprises approximately 121ha of employment land and appropriate use classes could include E(g)(iii), B2 and B8 uses. This site is reliant on the delivery of a new junction to replace the two one-way junctions at Junction 13 and Junction 14 of the M40, as well as changes to the A452 and B4100. Delivery of new or significantly altered motorway junctions is a complex and timely endeavour. Taking account of the necessary steps to delivery which includes approval of various business cases, obtaining necessary permissions, land assembly (including potential for CPO), numerous stages of design, funding and eventual construction the timeframe for delivering infrastructure of this nature is 5-7 years as a minimum. In CEG and its consultant’s experience it is much closer to 10 years. On this basis, CEG has serious reservations regarding the viability and deliverability of the Red House Farm site.
In addition, there is a large area of ancient woodland and Local Wildlife Site is located to the south, also containing a Scheduled Monument. A further Scheduled Monument is also located to the south east of the junction. To the north lies Bishops Tachbrook Conservation Area. The configuration of the motorway junction is considered to be a significant constraint affecting the suitability of this location for large scale commercial development.
In view of the above, CEG have serious concerns regarding the meaningful delivery of this site the within the period up to 2050. Therefore, the SWLP should be looking at alternative locations for employment growth.
Wedgnock Park Farm
Wedgnock Park Farm comprises approximately 141 ha and is located to the west of Warwick. The site falls entirely within the Green Belt. For this reason and when considering alternative options for employment development such as CEG’s site at Land East of Gaydon, Wedgnock Park Farm is not considered sequentially preferable. Notwithstanding, as set out within the draft policy direction, this site relies on a much broader strategy for growth west of Warwick/Leamington therefore in isolation would not be appropriate. It is also CEG’s understanding that existing highways capacity at this site is heavily constrained and would require significant infrastructure improvements to accommodate the level of growth identified.
JLR Allocation at Gaydon
CEG support the inclusion of this allocation within the SWLP on the basis that it is released to the wider market. It is important to draw to your attention the response of JLR to the South Warwickshire Issues and Options (reference
78209) who confirmed that they still require additional space in this location and would only be willing to remove the user-specific nature of the allocation if further land within their control was allocated through the SWLP.
Furthermore, the inclusion of a restriction on B8 unit size should be removed. There is strong evidence that larger B8 units are essential to support the manufacturing sector, and specifically the automotive supply chain, and such a policy restriction would therefore suppress appropriate investment and economic benefits. A restriction on use will impact upon delivery/take up rates as the B2 sector historically makes up only 20-30% of total demand and the inclusion of the proposed restriction as drafted therefore risks the ability for this site to be delivered within the first 5-10 years. This is particularly important as alternative sites cannot accommodate this easily, as outlined previously. A more appropriate policy position would be that a mixture of unit sizes should be provided on the site to meet market demand.
Furthermore, it is considered that the triangular parcel south of the identified employment site boundary should also be included within the allocation, being suitable for a range of uses. It is strategically placed and capable of accommodating small scale development with appropriate buffers to Gaydon. The SWLP through Draft Policy Direction 19 acknowledges the issue of providing affordable residential units at an appropriate scale. It is considered that this specific part of the site can assist in meeting this identified need and therefore should be allocated and included as part of this employment location. Date
07-03

No

ID sylw: 108263

Derbyniwyd: 07/03/2025

Ymatebydd: Sovereign Man Simon of the family Thomas

Evidence recommends that between 75 and 125ha of land be allocated for Employment Growth, however the Plan proposes 125ha, the upper limit of development. This is unnecessary and will have larger impacts on important environmental assets and habitats in the area, as well as designated sites and protected species, and does not align with the Government’s 30% by 2030 targets.
I am also concerned regarding the lack of up to date employment need data, and no evidence for Strategic Industrial Need before 2045.
The allocations are directly next to Chesterton Wood, an important Local Wildlife site, and extremely close to the River Avon and Tributaries LWS, Redlands Brake PLWS, New Waters LWS, Budbrooke Farm Woodlands and Black Brake Plantation LWS, development on which would have detrimental effects for wildlife and climate change targets.