Preferred Options 2025

No

Representation ID: 102300

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

Concerns about the Two-Part Plan approach. The Plan must identify deliverable sites for the first five years post-adoption (2028-2033). While existing commitments help, new allocations are needed. For strategic allocations in Part-1 to contribute to 5YHLS, clear evidence of housing completions within five years is required. Delivery may be delayed if detailed policies, masterplans, and design codes follow in the Part-2. To speed up housing delivery, the Councils should abandon the two-part Plan approach and move to a single Local Plan which identifies its full requirement and allocate sites, one being Land East of Rouncil Lane.

No

Representation ID: 102305

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

The Vision should recognise that there are unmet development needs outside of South Warwickshire that may need to be met within South Warwickshire. A Strategic Objective should also be to meet any unmet housing needs from communities elsewhere that cannot meet their needs, where it is practical and consistent with achieving sustainable development. This would align the strategic objective with the ‘positively prepared’ test of soundness.

Yes

Representation ID: 102308

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

Richborough support the inclusion of land East of Rouncil Lane (HELAA Site Ref: 199) (part of SG04) within the Plan for the following reasons:
- Within priority growth area
- Alignment with the spatial growth strategy
- Performance against other SGs
- Alignment with the Overarching Principles on the HELAA
- Green Belt – Site is grey belt and should be prioritised for release from the Green Belt
- Addressing the Sustainability Appraisal Assessment
- Infrastructure Requirements and Delivery
- Joint and Collaborative Approach to Development
- Right Choice for Development South of Kenilworth

No

Representation ID: 102310

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

The South Warwickshire Councils must continually review the Local Housing Need up to adoption, they must consider an increased higher housing need, implement a 5% lapse rate to account for unimplemented commitments, and reassess the existing commitments and windfall allowance as outlined.

Yes

Representation ID: 102311

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

In relation to HELAA Site 199, we raise into question the utility and methodology of a number of the HELAA results, including:
- A climate resilient and Net Zero Carbon South Warwickshire
- A well-designed and beautiful South Warwickshire
- A well-connected South Warwickshire
- A biodiverse and environmentally-resilient South Warwickshire
- Viability

Yes

Representation ID: 102313

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

It is imperative that the SWLP adequately considers accommodating unmet housing needs arising from outside of South Warwickshire. There are significant unmet needs arising from the GBBCHMA which require attention, and potential unmet needs arising from Coventry which should be taken account of accordingly. There is also potential for unmet needs arising from Cotswold District, Redditch Borough and Solihull Metropolitan Borough which should be considered. Failure to do so would render the SWLP not positively prepared nor effective and thus unsound in line with Paragraph 36 a) and c) of the NPPF.

Yes

Representation ID: 102316

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

Development proposals should endeavour to deliver the infrastructure set out in the transport strategies outlined, but the SWC’s must acknowledge the ability and need for strategic scale sites to deliver infrastructure that is considered important to a local community but not formally identified within an IDP or other transport strategy. Regarding infrastructure requirements for strategic allocations, the SWCs should collaborate with those bringing the site’s forward to understand site-specific requirements. Allocations with overly onerous infrastructure requirements may delay the delivery of sites due to viability or feasibility concerns. Requirements for infrastructure should not undermine the deliverability of the plan.

Yes

Representation ID: 102317

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

b. Richborough consider there would be negative consequences for sustainable development if all development was channelled to locations outside the Green Belt, and in accordance with paragraph 148 of the NPPF the need to promote sustainable patterns of development is paramount.

Draft Policy Direction 7 states “…if there are clear sustainability benefits to utilising one or more Green Belt locations, then this will form the basis of an argument that "exceptional circumstances" exist to justify releasing that land from the Green Belt”

Richborough agree there are exceptional circumstances to warrant the release of Green Belt land.

No

Representation ID: 102321

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

The principle of Draft Policy Direction 8 is acceptable. The SWLP should ensure that policies regarding density align with Paragraphs 129 and 130 of the Framework, particularly local market conditions and viability (Paragraph 129b). Any density policy within the SWLP should acknowledge the impact that evidence-based housing needs.

Yes

Representation ID: 102323

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

The South Warwickshire Councils are justified in their approach to housing mix and tenure as it reflects the ambitions of Paragraph 63 of the NPPF, and the NPPF as a whole. The Councils should ensure they provide flexibility within their housing mix and tenure policies to account for circumstances where delivering a housing mix in-line with the identified mix is not feasible or logical.