Yes

ID sylw: 108724

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the vision and objectives for the SWLP, which set out a vision for sustainable growth across the plan area in line with the requirements of paragraph 8 of the NPPF. We support Strategic Objective 2 which focuses on delivering homes to meet South Warwickshire’s current and future housing need, and also support Strategic Objective 3 which sets out the Councils’ objective to ensure that development is supported by sufficient infrastructure to support this growth. Additionally, Strategic Objective 1 states that appropriate and proportional levels of growth will be supported in the most sustainable locations, especially in locations with high levels of accessibility to key facilities and services.
We consider that land at Budbrooke Lodge Farm, Warwick (within Strategic Growth Option SG08) is well located to support this objective through the provision of residential development at this location.
The site is well-located adjacent to the western edge of the existing Warwick urban area boundary and is therefore located in close proximity to existing transport links and facilities / services, as evidenced by the positive performance of the site against Sustainability Appraisal Objective 11. Additionally, the site is bound to the west by a significant defensible boundary (the A46), beyond which lies the West Midlands Green Belt. Therefore, the site is considered to be a highly suitable location for development to support the growth of Warwick in a non Green Belt location.
Strategic Objective 11 expands on this further through an aspiration to increase and improve access to sustainable and active travel options that enhance connectivity by connecting people to centres, jobs, education, cultural facilities, green spaces and countryside. We support Strategic Objective 11 and consider that the residential development of land at Budbrooke Lodge Farm, Warwick, along with the wider land within the SG08 Strategic Growth Option, can offer significant active travel opportunities via connections to existing Public Rights of Way, including access to Warwick town centre via Warwick Racecourse and potential access to Budbrooke Industrial Estate to the north. Land at Budbrooke Lodge Farm is in significantly closer proximity to Warwick town centre than other recent developments in the vicinity, including the Chase Meadow development south of Hampton Road.
Finally, we note that objective 5 (Making effective use of land and natural resources) and 6 (Contributing towards Net Zero targets) relate to the overarching principle ‘A resilient and Net Zero Carbon South Warwickshire’. We support these objectives and recognise that combatting climate change through the planning process is becoming an increasingly important consideration in achieving sustainable development.
In addition, we consider that development at Budbrooke Lodge Farm could assist in meeting Strategic Objectives 10 (Improving the health, safety and quality of life of our communities), and 12 (Protecting and enhancing our environmental assets) through the provision of new public open space, facilitating increased public access to existing Public Rights of Way and through providing key environmental benefits as part of the development including Biodiversity Net Gain.

Yes

ID sylw: 108725

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the Spatial Growth Strategy set out in Chapter 4.1 of the Preferred Options document and consider that the “Sustainable Travel and Economy” option presents a suitable option for growth which prioritises access to sustainable travel options as well as access to key centres and employment areas.

No

ID sylw: 108726

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 1 because, as currently written, it does not comply with the requirement for Local Plans to be positively prepared and consistent with national policy, as set out in paragraph 36 of the NPPF.
NPPF paragraph 62 requires strategic policies to be “informed by a local housing need assessment, conducted using the standard method”. Planning Practice Guidance1 supports this further, stating that: “The National Planning Policy Framework expects strategic policy-making authorities to follow the standard method in this guidance for assessing local housing need. The standard method uses a formula that incorporates a baseline of local housing stock which is then adjusted upwards to reflect local affordability pressures to identify the minimum number of homes expected to be planned for.
The standard method set out below identifies a minimum annual housing need figure, and ensures that plan-making is informed by an unconstrained assessment of the number of homes needed in an area. It does not produce a housing requirement figure”.
Draft Policy Direction 1 states that the SWLP will make provision for at least 1,679 dwellings per annum in line with the findings of the Coventry and Warwickshire Housing and Economic Development Needs Assessment (HEDNA) 2022, with the flexibility to accommodate up to 2,188 dwellings per annum in line with the revised 2024 standard method. The HEDNA was prepared over 2 years ago and does not reflect amendments to the standard method which have given rise to significant increases in local housing need for both Warwick district (+62%) and Stratford-on-Avon district (+103%).
We consider that, in order for the policy to comply with national policy as set out above, the standard method figure of 2,188 dwellings per annum should be the starting point for identifying the housing requirement for the SWLP. We also consider that the Councils should consider whether to make provision for additional housing beyond this figure, particularly in order to assist other LPAs within the Greater Birmingham & Black Country and Coventry and Warwickshire Housing Market Areas towards meeting any unmet needs. We note that the 24 Strategic Growth Options and 12 potential new settlements have a combined capacity of 156,549 dwellings, as set out in the Preferred Options Sustainability Appraisal (Appendix B, Table B.1.1 and Appendix C, Table C.1.1). This means that there is likely to be sufficient capacity for South Warwickshire to meet its own development needs, in addition to contributing towards those of other authorities (for example Birmingham).

Yes

ID sylw: 108727

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the inclusion of Strategic Growth Option SG08 in the SWLP and consider that this location is appropriate for residential development. We note that the HELAA assesses the SG08 Strategic Growth Option holistically as site reference 214. As well as this, a smaller area of land forming the southern part of SG08 has been assessed separately as site reference 128 (Land at Budbrooke Lodge Farm).
King Henry VIII Endowed Trust is promoting land at Budbrooke Lodge Farm, Warwick (HELAA site reference 128), which is located directly to the west of Warwick Racecourse. Technical work has been undertaken to understand the capacity of the site for residential development. This is summarised in the Vision Document prepared by Node (Appendix 1), which concludes that up to 500 dwellings can be delivered on the site as part of a sustainable extension west of Warwick. Additional land to the north (which, together with the Trust’s land, comprises Growth Option SG08 / HELAA site 214) could potentially deliver up to 650 dwellings in total across SG08.
We wish to highlight that the SG08 Growth Option is under the ownership of two parties, including King Henry VIII Endowed Trust which owns circa two thirds of the SG08 Growth Option. Whilst these representations relate primarily to the Trust’s land interests at Budbrooke Lodge Farm, the fact that there are only two landowners comprising SG08 is considered to make SG08 a highly deliverable option for growth in the SWLP area due to the reduced number of landowner interests in the site.
We consider that Budbrooke Lodge Farm could also come forward independently of the remainder of SG08 to deliver around 500 dwellings. Further details of site capacity, along with an initial Framework Masterplan, are set out in the Vision Document prepared by Node (Appendix 1). Notwithstanding this, it is likely that the incorporation of land to the north of Budbrooke Lodge Farm, which is also within SG08, could deliver further development and associated public benefits such as significant open space and connections to Budbrooke Industrial Estate and Warwick Parkway station to the north. It is considered that a potential pedestrian and/or cycle access could be provided to Warwick Parkway station via the existing bridge over the A46 in the north-western corner or SG08, to provide a sustainable link with the site, as well as benefitting developments such as Chase Meadow to the south. King Henry VIII Endowed Trust has engaged with the landowner to the north to explore options for the comprehensive development of SG08 and will continue to engage further with them throughout the
SWLP preparation process.
A Transport Technical Note (Appendix 2) has been prepared by SLR setting out how vehicular access to the site can be accessed via Hampton Road A4189 to the south of the site. This demonstrates that either a ghost island right turn or a four-arm roundabout (or a combination of the two) could be used to
serve the site, with a single access able to serve up to 650 dwellings. SLR’s report also concludes that
a dual access option could service up to 1,700 dwellings. The SLR Technical Note also provides multiple
options for the provision of an emergency access via Hampton Road, utilising land within the Trust’s
control. It is noted, however, that this assessment does not take into account other key constraints
including areas of flood risk within the SG08 area and the need to provide public open space and other
amenities. With these constraints taken into account, it is anticipated that around 500 dwellings could
be delivered on land controlled by King Henry VIII Endowed Trust, potentially rising to around 500-650
dwellings if the remainder of SG08 is also developed (where technical issues can be addressed).

Other

ID sylw: 108728

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

Comments on HELAA Site 128
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 major (Flood Zone 2 or 3) 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.
The scoring of both Budbrooke Lodge Farm (site 128) and the SG08 Growth Option (site 214) in relation to landscape considerations suggests that this may represent a challenge to development due to the site intersecting with an ‘area of moderate visual sensitivity’.
However, as set out on page 18 of the Vision Document prepared by Node (Appendix 1), there are no specific landscape designations within the site. However, we recognise that consideration should be given to the relationship between the site and its landscape setting. Therefore, a landscape-led approach to masterplanning will be taken as part of detailed proposals for the site at the planning application stage, ensuring that key landscape features are incorporated into the proposals. This will include the retention of as many mature trees and hedgerows as possible.
It is anticipated that any proposed development at Budbrooke Lodge Farm could be sensitively designed to ensure that the significance of nearby heritage assets is not affected. As set out in the Framework Masterplan prepared by Node (Appendix 1), the proposed development at Budbrooke Lodge Farm will provide a significant buffer of undeveloped land in the eastern part of the site which abuts the Warwick Conservation Area. Further consideration will be given to how heritage matters can be considered in the design of the scheme as the SWLP preparation process progresses.
Notwithstanding the above considerations, we wish to highlight that a number of sites assessed in the HELAA scored similarly with respect to proximity to heritage assets, owing to South Warwickshire’s significant number of heritage assets and conservation areas. It is therefore anticipated that in order to meet South Warwickshire’s development needs it is likely to be necessary to situate new development in relatively close proximity to existing heritage assets.
We consider that this scoring relates to the existing ‘flat mile’ spur off Warwick Racecourse, which sits outside of King Henry VIII Endowed Trust’s ownership. We wish to highlight that the base map used for the Settlement Analysis exercise does not accurately reflect the extent of the ‘flat mile’, giving the impression that access to the northern part of the SG08 Growth Option cannot be achieved via Hampton Road to the south. As shown in the extract from the Framework Masterplan prepared by Node (Appendix 1), a suitable access to the northern part of SG08 can be achieved via Hampton Road, in addition to an emergency access point. This has been informed by the Transport Technical Note prepared by SLR (Appendix 2) which presents various options for providing a safe and suitable vehicular access to the site via Hampton Road to the south. This confirms that access into the development can be achieved and can suitably support up to 650 dwellings via this single point of access.
Additionally, it is considered that a range of improved pedestrian and/or cycle connections can be provided to improve the overall connectivity of the site, including improvements to the existing Public Right of Way network which connects the site to Warwick Racecourse to the east. Options for these improvements are explored further in the supporting Vision Document prepared by Node (Appendix 1).
The baseline habitat scoring for site 128 was relatively elevated based on the outcome of the ‘Assessment of Carbon Sequestration and Habitat baseline and opportunities’ report provided as part of the SWLP evidence base. An Initial Biodiversity Metric Assessment has been prepared by Middlemarch (Appendix 4). This document assesses the baseline biodiversity value of the site and confirms that, subject to appropriate detailed landscaping proposals being set out at later design stages, it is feasible to achieve the required 10% Biodiversity Net Gain through on-site habitat enhancements.
It is therefore considered that site 128 is able to provide the required 10% BNG via on-site enhancements, representing a significant uplift in biodiversity value in this location relative to the current position.

Other

ID sylw: 108729

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

Whilst it is recognised the role that a new settlement can play in delivering new housing development, it should be recognised that expanding the existing urban area is likely to be more achievable in the short term with a greater availability of existing infrastructure that can be connected to or upgraded.
Therefore, when settling on the most appropriate strategy, a balance should be struck between short term delivery, which will be required to provide a continuous 5 year housing land supply and the need to establish other sustainable patterns of development, as required by the NPPF (paragraph 22).

Yes

ID sylw: 108730

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the draft policy direction and consider that if any arising unmet needs are declared by any authority within the Coventry and Warwickshire HMA or Birmingham and Black Country HMA prior to the publication of the Regulation 19 Publication SWLP, then the Councils should allocate land to support meeting these needs. Notably, authorities including Birmingham City Council and Sandwell
Metropolitan Borough Council have already declared unmet needs of 78,4152 and 15,9163 dwellings respectively. The changes to the standard method for housing need calculation will also give rise to increased housing requirements for many of the authorities within these HMAs and therefore there is a potential that the list of authorities who are unable to meet their own housing requirements will grow in the coming months.
It is noted that the combined potential capacity of the Strategic Growth Options and New Settlement options, as set out in the Preferred Options Sustainability Appraisal (Appendix B, Table B.1.1 and Appendix C, Table C.1.1), is 156,549 dwellings. This shows that there is significant capacity in the South Warwickshire area to provide additional housing in support of wider sub-regional needs. Given that
Table 3 of the Preferred Options document indicates that a total of 28,257 additional dwellings need to be identified to meet outstanding need in the SWLP plan period, it is therefore considered that there are enough potential housing sites identified in the Preferred Options document to meet South Warwickshire’s housing need, whilst contributing towards the needs of other authorities.

Yes

ID sylw: 108731

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the policy direction and consider that development should provide appropriate on and off-site infrastructure where a need is demonstrated in compliance with Regulation 122 of the CIL Regulations 2010. However, we consider that new development should be located, where possible, in sustainable locations with good access to existing facilities and services where there is capacity for existing infrastructure to absorb growth or locations where the scale of growth and expansion proposed will deliver the necessary infrastructure to support its delivery.

Yes

ID sylw: 108732

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support the policy direction in principle, subject to robust evidence being provided to support any identified density parameters being placed on allocations and/or specific settlements. NPPF paragraph
129 states that planning policies should support development that makes efficient use of land, taking into account the following:
“a) the identified need for different types of housing and other forms of development, and the availability of land suitable for accommodating it;
b) local market conditions and viability;
c) the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use;
d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and
e) the importance of securing well-designed, attractive and healthy places.”
In light of the above, we consider that any policy wording proposed in density policies, including the inclusion of density requirements within design codes, should ensure that the above requirements, particularly regarding viability and market conditions, are taken in to account and an element of flexibility allowed for to ensure the proposed development can respond appropriately to its spatial and market context. This will ensure that the development coming forward in all parts of the SWLP area will appropriately meet market needs.

No

ID sylw: 108733

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to the draft policy direction as written. Whilst we agree that the Councils should have regard to the latest evidence relating to housing tenure, mix and type when drafting policy wording, we wish to highlight that the 2022 HEDNA, which represents the most recent evidence base on housing, does not base its findings on the revised standard method for the calculation of housing need.
Therefore, whilst the HEDNA provides an assessment of affordable housing needs across the plan area, we consider this evidence base to be largely out of date.
Planning Practice Guidance4 states that once an affordable housing need has been identified “the total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by eligible market housing led developments. An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.” (Savills emphasis)
In this context, we welcome the Councils’ recognition at page 59 of the Preferred Options plan that the forthcoming Strategic Housing Market Assessment (SHMA) and the revisions to the NPPF will directly impact emerging policy on affordable and specialist housing. We consider that, should the SHMA identify a significant affordable housing need in South Warwickshire, the Councils should consider increasing the housing requirement of the plan in order to ensure that significant affordable housing can be viably delivered across all identified allocations. We note that the Strategic Growth Options and New Settlements included in the Preferred Options consultation amount to a total capacity of circa 156,000 new dwellings. Given the residual housing requirement is around 28,000 dwellings, we consider that there is ample potential within the SWLP area to provide additional housing in order to facilitate the delivery of additional affordable housing.