Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan?
We have been resident of Henley in Arden and Beaudesert for the last 24 years and would like to express our deepest concerns and reservations regarding the proposed South Warwickshire local plan. Having brought up a family of four sons all of whom have been educated in the town, worked in the town and supported its local amenities, we must strongly object to the proposed additional development of the town. The proposals are totally disproportionate to the towns size and infrastructure capabilities. The proposed development makes no allowance for: – 1) additional sewage improvements that would be necessary. 2) additional school and educational services. 3) doctors and other medical support. 4) improvement to the already decrepit public transport systems. The proposed plan would destroy the uniqueness and historic heritage of the town. The proposed plan takes no account of the incredible risk to flooding in this area which we live with and we ourselves have experienced when in 2007 we lost our family car to flooding. We ourselves receive at least 10 to 12, texts/calls a year from the Environment Agency Flood Alert line emergency warning service. Therefore, we have to seriously question The SWLP proposal of adding 500 to 2000 homes in a flood prone area! Traffic congestion currently is a daily issue and when the local M40 experiences issues, the town is gridlocked! How can this support a further 500 to 2000 home? Even more alarming is the proposal to erode the greenbelt, which the Henley Arden and Beaudesert JPC and Stratford has spent years protecting. We fully accept some development is necessary, but it has to be in proportion to Henley’s size and capability, bearing in mind that the current occupation is a little over 3000 people in total. A more appropriate and sensible increase would be in the order of 10%, i.e. approximately 100 homes.
We are concerned that the plan as currently envisaged will leave many unanswered questions and could rely too heavily on the production of Site Allocation Plans or Neighbourhood Development Plans. The comments we have made above suggest some ways in which the level of uncertainty could be reduced and would urge them to be taken up. The Call for Sites is an important part of the plan making process but would appear destined to leave many site promoters uncertain of their position, potentially for a considerable length of time. This could be addressed, at least in part, by providing greater certainty on the scale and distribution of growth across the plan area and by providing for a strategic level of growth on small sites (i.e. with a capacity of less than 50 dwellings for housing and say less than 10 hectares for employment).
We are concerned that the plan as currently envisaged will leave many unanswered questions and could rely too heavily on the production of Site Allocation Plans or Neighbourhood Development Plans. The comments we have made above suggest some ways in which the level of uncertainty could be reduced and would urge them to be taken up. The Call for Sites is an important part of the plan making process but would appear destined to leave many site promoters uncertain of their position, potentially for a considerable length of time. This could be addressed, at least in part, by providing greater certainty on the scale and distribution of growth across the plan area and by providing for a strategic level of growth on small sites (i.e. with a capacity of less than 50 dwellings for housing and say less than 10 hectares for employment).
I am writing in response to the South Warwickshire Local Plan Consultation. I am submitting my comments via email. Due specifically to the complexity of the online portal, I am submitting this as an email, it should be treated as an individual personal response to the consultation. I feel that this whole consultation has not been done in a manner that is accessible to the general public to understand. The portal is not very straightforward, the questions are very convoluted and this makes me think that it has been overly complicated to try to dissuade the general public from having their say, or even understand what this may actually mean for the area in which they live. I am very disappointed in the way the council have handled this.
If you have any further comments, please write them here.: There are housing developments everywhere, the housing forecast seems vastly inaccurate and where are all these potential purchasers coming from ? There is no infrastructure to support all these developments and no upgrades to road networks which are GRIDLOCKED AT THE MOMENT so what will happen if these developments are allowed to continue ? We cannot continue to lose good agricultural land and wildlife habitats for the sake of our future generations.
Chapter 1 – Introduction A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it is may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then, although Part 2 will need to be in conformity with the SWLP, preparation of Part 2 should be undertaken, as far as possible, in parallel with Part 1 in order to expedite its adoption. Even so, it is possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. Every effort should be made to avoid the delays which have resulted in the situation where although the current Stratford on Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not yet adopted. The Plan Period The vision for the Local Plan is set out up to the year 2050. The current National Planning Policy Framework (NPPF) at paragraph 22 states that strategic policies should look ahead over a minimum 15-year period from the date of adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055. As such, we contend that the Plan should have a 30 year horizon and run until 2055. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP including a Green Belt study. Approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are located within, the Green Belt. It is inevitable that the emerging plan will need to remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is essential in order to understand the sensitivity of different parts of the Green Belt to development. This matter should be considered alongside other evidence based documents to help establish the most appropriate locations for allocations. There are, however, a number of non Green Belt settlements in the plan area that are suitable for an allocation. Bishop’s Itchington is located outside of the Green Belt. As detailed within these representations it is a sustainable location for development. BDW control land at Ladbroke Road, to the east of Bishop’s Itchington that is ideally suited to residential development. As detailed in our Call for Sites submission is a readily deliverable housing site that should be preferred location for residential development.
Chapter 1 – Introduction A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then, although Part 2 will need to be in conformity with the SWLP, preparation of Part 2 should be undertaken, as far as possible, in parallel with Part 1 in order to expedite its adoption. Even so, it is possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. Every effort should be made to avoid the delays which have resulted in the situation where although the current Stratford on Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not yet adopted. The Plan Period The vision for the Local Plan is set out up to the year 2050. The current National Planning Policy Framework (NPPF) at paragraph 22 states that strategic policies should look ahead over a minimum 15-year period from the date of adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055. As such, we contend that the Plan should have a 30 year horizon and run until 2055. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP, including a Green Belt study. A Green Belt study is absolutely necessary as approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are located within, the Green Belt. All the train stations that will deliver Growth Options 1, 2 and 3 are in the Green Belt. It is inevitable that the emerging plan will need to remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is essential in order to understand the sensitivity of different parts of the Green Belt to development. In order to support this matter our updated Call for Sites representations consider the Green Belt constraints and opportunities associated with BDW’s land interests at Bearley Station.
Chapter 1 – Introduction A Two Part Plan Some concerns exist with the preparation of a two part Local Plan. It is understood from paragraph 1.4 of the Draft Plan that the SWLP Part 1 will set out the core principles, common strategic policies, climate change policies and identify the strategic allocations that are critical to the delivery of the plan. The Part 2 Plan will contain detailed policies and non-strategic allocations. This approach could be problematic as it is may delay the delivery of non-strategic housing and employment allocations. It is anticipated that the SWLP will be adopted between June and December 2025 (Draft Plan Figure 2). Should the Councils decide to produce a 2 part Local Plan then, although Part 2 will need to be in conformity with the SWLP, preparation of Part 2 should be undertaken, as far as possible, in parallel with Part 1 in order to expedite its adoption. Even so, it is possible that the Part 2 Plan will not be adopted for at least two to three years following the adoption of the SWLP Part 1. Every effort should be made to avoid the delays which have resulted in the situation where although the current Stratford on Avon Core Strategy was adopted in 2016, some 7 years later the Part 2 Site Allocations Plan is not yet adopted. The Plan Period The vision for the Local Plan is set out up to the year 2050. The current National Planning Policy Framework (NPPF) at paragraph 22 states that strategic policies should look ahead over a minimum 15-year period from the date of adoption, with policies to be set within a vision that looks further ahead to at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy. These growth scenarios are currently being considered within South Warwickshire and if preferred, given adoption is likely in 2025, the plan period should be extended to at least 2055. As such, we contend that the Plan should have a 30 year horizon and run until 2055. Supporting Evidence Base It is noted that Part 1.8 of the Plan advises that, in addition to the existing evidence base studies, additional technical studies will be commissioned to inform the SWLP, including a Green Belt study. A Green Belt study is absolutely necessary as approximately one third of the SWLP area falls within the Green Belt. A large proportion of the major towns and sustainable villages are located within, the Green Belt. All the train stations that will deliver Growth Options 1, 2 and 3 are in the Green Belt. It is inevitable that the emerging plan will need to remove land from the Green Belt in order to meet its growth requirements. A Green Belt study is essential in order to understand the sensitivity of different parts of the Green Belt to development. In order to support this matter our updated Call for Sites representations consider the Green Belt constraints and opportunities associated with BDW’s land interests at Wilmcote Station.
Q-P1.1: Do you agree with the proposed broad content of the Part 1 Plan? 10.1 The Church Commissioners broadly supports the broad content of the Part 1 Plan, however reiterates that there remains a large amount of evidence required to understand all the topics listed. Furthermore, it is important that the content is clear in terms of what is deemed as a strategic policy at this level. Those identified strategic policies also need to be reflective and appropriate for future allocations that may be identified within the Part 2 Local Plan.
The Parish Council has had difficulty assessing the volume and detail of the plan in the timescale. We realise that some difficulties are inevitable but there are in reality only a few key issues in the plan and they are lost in the excessive detail. It would be better if several of the policy areas were dealt with in a separate consultation probably reserved to the individual District authorities in line with the subsidiarity principle. The website states that consultation has been undertaken with parish and town councils, but when and in what depth. Details of consultation undertaken should be stated. The Parish Council considers that the Part 1 plan should be a high level strategic plan which contains the issues which are central to the long term settlement pattern of the sub Region. The plan is also unrealistically long given the rate of social and economic change. The failure to include a major set of options about the green belt in the consultation indicates a lack of appropriate focus. This seems to indicate the Plan is developer led.
“Burton Green Parish Council (BGPC) has serious doubts about the veracity of the SWLP process, especially as the new plan will endeavour to make determinations for the period up to 33 years from the starting point of the present 2017 WDC Local Plan — which was prepared on the basis of (excessively) over-optimistic population and household growth projections. These have potentially resulted, or are currently resulting, in an over-provision of new homes which are most likely excessive to, or are at least unsuitable, to meet the requirements of local needs, such as affordable housing for young people, and are instead likely meeting the needs of inward migrants, including substantial numbers (perhaps as many as 30% in Warwick District) of second home owners. Ease of travel via the M40 and/or Chiltern Railway corridor, and lower house prices than in, say, Buckinghamshire or Oxfordshire, may well have encouraged/are now enabling people to buy new homes below the sale value of their homes further south, enabling them to move with a substantial profit — a trend likely to have been enhanced during the Covid-19 lockdowns which led to a desire by many to move out of larger towns or cities into more ‘countrified’ areas.. BGPC has strong views on this matter — and no desire for the situation to be perpetuated by the new SWLP — as the parish is faced with 425 additional homes being already imposed on the village (south of Westwood Heath Road), doubling the size of Burton Green in terms of both dwellings and population compared with just six years ago. This development, unnecessary then and now in the view of BGPC, is taking place under the terms of the 2017 Warwick Local Plan which was amended from its original draft form in order to meet alleged housing needs of Coventry city. Moreover, an adjacent site south of Westwood Heath Road was also removed from the green belt and classified as ‘safeguarded’ for future development of perhaps 700-900 homes which, if perpetuated in the new SWLP, would quadruple the size of Burton Green since 2017. BGPC objected to the addition of both sites south of Westwood Heath Road when the original WDC Plan was revised at the requirement of the Inspector conducting the Local Examination in order to meet needs that were then claimed could not be accommodated within Coventry. This occurred despite emerging evidence — even then — that the population projections for Coventry were seriously overstated, a view also held by CPRE-Warwickshire and the then-newly-formed Coventry & Warwickshire Keep Our Greenbelt Green (KOGG) campaign [of which BGPC was a founding member] but our complaints and concerns were not accepted by either of the planning authorities or by the inspectors who conducted the public examinations of both Warwick’s and Coventry’s Local Plan proposals. However, the 2021 Census results have confirmed the rightness of our objections to the additional sites being added into the 2017 Warwick Local Plan. The likely consequence now is that there is an over-provision, either actual or emerging, of new housing to meet local needs but which is being/will be absorbed by inward migration and/or second home purchases due to either the attraction of prices or the desire of developers to fulfil sales targets for homes they have committed to build. This is not true growth but merely transfers of economic activity from other areas to South Warwickshire, and not necessarily to the benefit of local residents. In the view of BGPC, a full and proper understanding of recent and current circumstances, and these trends and their consequences, is now essential before seeking to set about finalising any new Local Plan for all of South Warwickshire for the next 27 years.”
No answer given
Caddick Land broadly supports the broad content of the Part 1 Plan, however re -iterates that there remains a large amount of evidence required to understand all the topics listed. Furthermore, it is important that the content is clear in terms of what is deemed as a strategic policy at this level. Those identified strategic policies also need to be reflective and appropriate for future allocations that may be identified within the Part 2 Local Plan.
I agree with all comments made by the Old milverton and Blackdown Parish council. My own concerns with regard to any major residential developments, is the failure to provide necessary infrastructure eg Schools, Doctor's Sugery and road accessibility.
Q-P1.1: Do you agree with the proposed broad content of the Part 1 plan? NWBC Response – Agree with broad content.
Feedback on consultation process I am a computer-literate and educated adult. However, I have found this horrendous to navigate and have no idea how normal working people – members of the general public – are expected to make reasonable judgements on the information provided. The information is just so overwhelming, even if you don't read the hundreds of pages that are referenced in background documents (which in some cases people are being asked to read in order to answer questions). I suggest that the councils need to consider the consultation response in the context of this. There will be so many people who just find this inaccessible, so you will never get their views. It would take many hours it to go through this properly – time and energy that regular working people (especially in the current climate) don't necessarily have. And that's not even considering the level of detail supplied: the NHS, for example, aims for a reading age of 9–11 in its online material, in recognition of estimated literacy levels. The SWLP consultation materials are pitched at a level much higher than this. I appreciate that a lot of work has gone into this and that the councils will want to provide evidence behind their proposals. However, there are ways this can be done and structured in a more accessible way, for example with summaries, key points and minimal text. The bottom line is that the general public just want to know what it means for them, their lives, their families, their homes, and their wellbeing.
Strategic site allocations should form part of Part 1 to support the effective delivery of residential, commercial, and other necessary uses. Allocations forming the Part 1 Local Plan should not only meet the needs identified within South Warwickshire but identify sites to meet unmet needs arising within Coventry, Birmingham, and the Black Country. There are advantages and disadvantages to having a single document and to having a two-part document. In the former case, there will be certainty right from the start. The council should have a healthy housing land supply from adoption, prevailing into at least the medium term of the plan period. However, adopting such a plan generally takes a long time. The part 1 document of a two-part plan may take less time to adopt but would leave the council vulnerable to having an insufficient housing land supply. Therefore, it is essential that Part 1 of such a plan can demonstrate an adequate land supply allocated for housing along with the respective housing land supply numbers, to ensure the council maintains a healthy land supply into the medium term. Further to the previous Knight Frank response (ref. 2102), the strategic site at Copham’s Hill, Stratford-upon-Avon would provide a mixed-use scheme, including approximately 800 residential dwellings, shops, a primary school, open space and associated infrastructure that could be delivered in the early years of the Local Plan.
Q-P1.1. Do you agree with the proposed broad content of the Part 1 plan? 3.60 Whilst we agree with the proposed broad content of the Part 1 plan, it is worth highlighting to the Council’s the implications of the transitional arrangements to new Joint Spatial Development Strategies and new style Local Plans as proposed in the LURB in the context of the SWLP progressing as separate parts. In particular, the broad content proposed at this stage does not include site specific allocations or policies, therefore it is worth flagging the potential issues of delayed plan-making. Notwithstanding this, the South of Coventry study area as set out in the Cabinet Report from April 2022 from Warwick District Council, should be considered as a strategic policy through the Part 1 plan via appropriate status without the need for it to be defined through Part 2 and this would be more fragmented and site specific. It must be clear, in terms of transparent decision making, how the SWLP authorities identify the South of Coventry study area as a potential area for future growth or not (referring to para 1.7 of the April 2022 Cabinet Report). 3.61 Whilst the approach the SWLP authorities are taking should remain unchanged, we wish to use this opportunity to remind the Councils that timescales in relation to the transitional arrangements set out by the draft NPPF changes are of consideration. 3.62 Given the SWLP is in the earlier stages of plan making (i.e., pre-Reg 18), we note the current up to date timeline indicates that the SWLP will reach submission stage by June 2025. Assuming this deadline is met, then work on a new plan will need to start by the latest January 2032. If the deadline is missed, new style plan preparation will need to begin immediately from that date (July 2025). 3.63 If the deadline is met, this has benefits in that late commencement of a new-style plan, gives the SWLP authorities more guidance, best practice, and case law to consider. 3.64 We urge the SWLP authorities to continue with preparing the local plan at the current timetable for the June 2025 submission target date, as this will ensure the timely preparation of the SWLP.