Yes

ID sylw: 108744

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 25 in principle, however we note that design codes can often be relatively strict and prescriptive in comparison to a “Design Framework”, masterplan or “Design Guide”. We would encourage the Councils to avoid any design coding which is overly prescriptive in nature, as this could add significant delay to the delivery of housing. We consider that greater flexibility should be provided to ensure that the preparation of additional policy material, particularly where it relates to large sites, does not lead to protracted timescales for delivering much needed housing in the SWLP area.
Whilst setting an appropriate framework for design is important, the requirement for multiple levels of design codes (national x2, local, and site specific) can serve to delay the delivery of housing. The site context (e.g. in or adjacent to a conservation area) and the need for flexibility are important considerations when determining when to require an additional layer of design coding.

Yes

ID sylw: 108745

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 27 in principle. We note that there are significant numbers of heritage assets within the SWLP area, including over 100 conservation areas. Therefore, it is highly likely that in order to meet the significant housing requirement of the SWLP area, development will to be accommodated in close proximity to heritage assets. We consider that high quality development which is sensitive development to heritage assets in close proximity should be accommodated and integrated with its historic context.

Yes

ID sylw: 108746

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 29 in principle and note that NPPF paragraph 187e states that planning policies should contribute to and enhance the natural and local environment by “preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability”. If selected for allocation, land at Budbrooke Lodge Farm (part of the SG08 Strategic Growth Option) would ensure that impacts are as minimal as possible, and suitable mitigation measures are put in place where any residual impacts are identified.

Yes

ID sylw: 108747

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 30 in principle and consider the role of planning in creating healthy and safe spaces to be of vital importance. We consider that the development of Budbrooke Lodge Farm(part of the SG08 Strategic Growth Option) could facilitate multiple health and wellbeing benefits, both for new residents as well as existing residents in Warwick. This would be demonstrated through increased access to open space and the potential to link into existing Public Rights of Way (including those running through Warwick Racecourse) to facilitate increased connectivity and public access to key amenity and leisure spaces.

Yes

ID sylw: 108748

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 31 and consider that allocating land at Budbrooke Lodge Farm (part of the SG08 Strategic Growth Option) could help to meet the aims of this policy direction.
We support the aspiration within the policy direction to prioritise access to public transport, walking and cycling routes and consider that land at Budbrooke Lodge Farm can deliver these via the enhancement of the existing Public Right of Way network which links to Warwick Racecourse to the east, beyond which lies Warwick town centre. This will provide excellent access to existing shops and other facilities / amenities in Warwick via active travel, as well as access to Warwick railway station. There is also the potential for a pedestrian connection to be facilitated to Budbrooke Industrial Estate to the north, enabling a connection to employment opportunities in the vicinity of the site.
Finally, there is a further potential to provide a pedestrian/cycle connection to the BP / M&S / Starbucks service station on the A46 to the west of the site. A summary of the distance (taken from the proposed site access on Hampton Road) to key services and facilities via existing footways is provided below:
Service / Facility Distance
Warwick High Street 1.6km (22 minute walk)
Local shopping centre (Warwick District Local Plan) 0.8km (11 minute walk)
Warwick railway station 2.8km (39 minute walk)
Warwick Parkway railway station Potential connection via SG08
Budbrooke Industrial Estate Potential connection via SG08
A46 services (BP/ M&S / Starbucks) Potential connection via SG08
Bus stop (Hampton Road) 0.5km (6 minute walk)
Doctors surgery 1km (13 minute walk)
Community Centre 1km (13 minute walk)
Primary School 1km (14 minute walk)
Secondary School 1km (14 minute walk)
Post office 1.9km (27 minute walk)
With regards to vehicular access, SLR have prepared a Transport Technical Note (Appendix 2) 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 and the dual access option able to service up to 1,700 dwellings. However, it is recognised that due to additional technical constraints (such as flood risk) which are not considered in SLR’s highways report, that 1,700 dwellings cannot be delivered at this location. SLR’s report also provides multiple potential emergency access options, including via Hampton Road. It is anticipated that the proposed access point(s) will also deliver pedestrian and cycle access, further contributing to the overall accessibility of the site.

No

ID sylw: 108749

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 32 on the basis that electric vehicle charging points are already required under Building Regulations Approved Document S for all new dwellings and commercial developments. Therefore, there is no need for the duplication of Building Regulations within planning policy, as supported by NPPF paragraph 16f which requires planning policies to serve a clear purpose.
We note that the draft policy direction makes reference to the Councils’ strategy to provide electric vehicle charging points within its own car parks. We consider that this is a matter to be dealt with outside of the planning policy arena and should therefore not form part of the SWLP.

No

ID sylw: 108750

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 38 and consider that the Councils should not seek to require Biodiversity Net Gain (BNG) in excess of the 10% statutory requirement. We consider that the 10% BNG requirement is an important statutory requirement which should be provided in line with existing legislation. However, Planning Practice Guidance ( Paragraph: 006 Reference ID: 74-006-20240214) states that any requirement for BNG in excess of 10% will require robust evidence as to why a further requirement is necessary and that viability will not be impacted. Such evidence has yet to be provided by the Councils and therefore we object on this basis.

No

ID sylw: 108751

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 39 on the basis that evidence has yet to be provided to justify the inclusion of an Environmental Net Gain (ENG) policy, nor any information about how such a policy would function 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. Developing an ENG policy from this starting point could lead to additional delay to the adoption of the SWLP due to the amount of evidence base which would need to be collected, in addition to developing a metric through which to quantify gains.
We also consider that the inclusion of an ENG policy could place a further financial burden on developers in addition to the statutory requirement to deliver 10% Biodiversity Net Gain, as well as other requirements to provide on-site public open space, green infrastructure and Sustainable Drainage Systems. We remain concerned that the introduction of a further requirement could impact viability of development sites and lead to a further reduction in net developable areas.

Yes

ID sylw: 108752

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy Direction 40 in principle, however we note that no evidence has been produced to date in support of the proposed “Greening Factor” mechanism. 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 the provision public open space.

No

ID sylw: 108753

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 47 on the basis that it is not supported by sufficient evidence to warrant the designation of Special Landscape Areas (SLAs). The policy therefore cannot be considered to be justified, as per the requirements of NPPF paragraph 36. We consider that the designation of SLAs would undermine the importance of the Cotswolds National Landscape and would also lead to confusion given the designation is not in widespread use. It is considered that the content of other landscape-related policies in the SWLP, such as Draft Policy Direction 48 (Protecting and Enhancing
Landscape Character) will provide adequate protection to landscape as part of the development management process.