Blackford Mill Planning Objection

re: OUTLINE PLANNING APPLICATION 26/02084/OUT

Application reference: 26/02084/OUT
Case Officer: Stuart McIver
Site Location: Land to the South of Henley known as Blackford Mill Farm
Development proposal: Outline planning application with all matters reserved, EXCEPT for
detailed access into and out of the site, for up to 265 dwellings (Use Class C3), open space,
landscaping, and infrastructure.
Submitted by: Henley’s Future Counts (HFC) – see appendix for description
Date of submission: 15 October 2026

Executive Summary

Although SDC states that all matters are reserved EXCEPT for Access in and out of the site, our
objection and representations are focused on those matters that are critical to consideration of the principle of development which we understand will be expressly before the Council for
determination at this Outline Application stage.

Having reviewed the applicant’s Planning Statement and supporting documents (the application), we wish to object in the strongest terms because we do not believe that permission would be justified for planning policy reasons and on certain legal grounds.

In summary our objection is based on the following matters:

National Planning Policy Framework (NPPF)
The applicant’s Planning Statement is based on the requirements of NPPF 2024 whereas we
believe the application will be determined under NPPF 2026, published in August. DM1,
requires major applications to explain compliance with national decision-making policies, and
DM3, directs councils to seek solutions and consider conditions or obligations where
appropriate. Accordingly, SDC should:

• Require an updated explanation of compliance with relevant 2026 policies.
• Obtain further or revised technical evidence where changed policies expose an evidential
  gap.
• Consider whether substantive amendments or new evidence warrant further consultation.
• Refuse permission if the proposal remains unacceptable under the applicable policies and
  the deficiencies cannot adequately be resolved.

Highways, traffic congestion and road safety
The applicants Transport Assessment (TA) does not provide sufficient evidence to demonstrate
that the development would not have severe adverse impacts on traffic flows, congestion and
road safety. It fails to demonstrate compliance with NPPF TR6 which requires transport impacts
to be assessed using reasonable future scenarios. Furthermore, the TA’s conclusions on traffic
congestion and road safety are in direct contradiction with the observations in a recent
Warwickshire Police report. The TA required Stage1 Road Safety Audit and Designers response
is outstanding. In their Consultation response, National Highways have highlighted flaws and
shortcomings in the applicants TA and as result have recommended SDC delay determination for three months pending the better information needed for assessment and satisfactory answers to their queries. This is so fundamental, it must not be deferred to Reserved Matters.

Sustainable modes of transport and connectivity
Neither Henley nor Wootton Wawen are well connected or adequately served by rail or bus
services to areas of employment and economic growth as defined in the Reg 19 South
Warwickshire Local Plan. Furthermore, there are no committed plans by the bodies responsible
for rail infrastructure to transform capacity on the Shakespeare Line. The off-site infrastructure
to support local active travel is virtually non-existent and as explained elsewhere would give rise
to unacceptable road safety hazards. As a consequence, the applicants prediction of a modal shift in transport is at best aspirational and very unlikely to give rise to a meaningful reduction in
vehicular usage.

Ecology and biodiversity
Many measures to protect our ecology and biodiversity including threatened species are
enshrined in law, enforced by legal remedies. The applicant’s own Ecology Appraisal recognises
the shortcomings in its evidence presented on the presence of various protected species. The
potential harms to protected species and other wildlife caused by the construction of the houses and related infrastructure, noise, lighting, contamination and pet predation are very serious, and are not adequately mitigated against. Furthermore, harms caused by such development and inadequate mitigation cannot be reversed. There is an unacceptable level of uncertainty and lack of precision in the applicants Biodiversity Net Gain Audit (BNG), which is a statutory requirement of the Environment Act 2021.

Flooding and drainage

The submitted Flood Risk Assessment (FRA) does not provide sufficient evidence to demonstrate that the proposed development is safe from flooding for its lifetime or that it fully complies with the National Sustainable Drainage Standards (NSfS) and Warwickshire County Council LLFA guidance. Key elements of the strategy and detailed drainage design remain untested or have been deferred to future stages. Both Henley and Wootton Wawen are increasingly at risk from both fluvial and pluvial flooding. Given that the geology of the site, Mercia Mudstone Group, does not lend itself to efficient infiltration, a highly complex sustainable drainage scheme would be required, and even then, it is not certain that such a scheme would not be overwhelmed with the type and scale of flood events we are experiencing on an annual basis.

Green Belt

Henley’s Future Counts objects to the applicants claimed grey belt status of the site. The site contributes to historic Henley’s rural setting, distinctive linear form and southern approach. Developing up to 265 homes would broaden the town into countryside towards Wootton Wawen, weakening the settlements’ separate identities. Limited intervisibility and vegetation screening do not demonstrate that the site’s contribution to historic character is merely moderate. The Council should independently assess its visual, physical and experiential relationship with Henley. An assessed strong contribution to preserving the setting and special character of a historic town would prevent the land qualifying as grey belt.

Arden Special Landscape Area (ASLA)

The site lies within the ASLA which is an adopted Local Development Plan designation. Core Strategy Policy CS.12 requires land within an SLA to be protected from development that would harm its distinctive character and appearance. Appropriate weight should continue to be given to such a policy. We don’t believe that the applicant’s Landscape and Visual Statement (LVIA) properly reflects SDC’s own landscape sensitivity evidence.

Heritage harm

The site directly surrounds Grade II Listed Blackford Mill and Blackford Mill Farm Buildings. Tithe maps from 1840 and sale particulars from 1887 prove the fields form the original agricultural setting of these assets. Development severs this historic link, triggering the statutory presumption against permission under Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

Infrastructure
Critical community facilities, such as the Medical Centre and Secondary School, are at or beyond full capacity. Severn Trent’s Pennyford Lane waste-water and sewage treatment Plant in Wootton Wawen is capacity constrained. This has resulted in the Plant having a very poor historical record of sewage discharge into the River Alne. Without a committed plan with funding in place to address the structural capacity, this unacceptable record is likely to become even worse. The infrastructure required to support an ‘active travel’ strategy beyond the on-site development design, eg cycle paths, is little better than non-existent. The applicant does not propose any solutions to these serious critical infrastructure shortcomings.

Sustainability and cumulative development impact
Taking account all the above, it is apparent that this development is not close to being sustainable. Furthermore, the measures and investment that would be required to achieve
sustainability are either impractical, commercially unviable or both. Given the affordable
housing component, the combined CIL and S106 contributions, while still allowing commercial
viability for the developer, would fall far short of the likely total cost of addressing all the
required on and off-site mitigation measures and the infrastructure investment required.

FOR THESE REASONS WE URGE THE COUNCIL TO REJECT THIS APPLICATION

1. NATIONAL PLANNING POLICY FRAMEWORK (NPPF)

HFC objects on the basis that the applicant’s Planning Statement is based on the requirements of NPPF 2024 whereas HFC believe the application will be determined under NPPF 2026,
published in August. DM1, requires major applications to explain compliance with national
decision-making policies, and DM3, directs councils to seek solutions and consider conditions or obligations where appropriate.

Conclusion and request
There are some very material differences between the requirements of NPPF 2024 and NPPF
2026 which impact this application. These differences are dealt with in each of the major
objection sections that follow. However, one of the most important changes is the requirement of HC3 that infrastructure requirements must be made concrete. They cannot remain aspirational, unplanned, uncommitted and unfunded.

HFC requests that SDC:

1. Require an updated explanation of compliance with relevant 2026 policies.
2. Obtain further or revised technical evidence where changed policies expose an evidential
   gap.
3. Consider whether substantive amendments or new evidence warrant further consultation.
4. Refuse permission if the proposal remains unacceptable under the applicable policies and
   the deficiencies cannot adequately be resolved.

2. HIGHWAYS, TRAFFIC CONGESTION and ROAD SAFETY

HFC’s primary objection relates directly to highways, traffic and road safety. The proposed
vehicular access into and out of the site via two priority junctions on single-carriageway A4189
Warwick Road and A3400 Stratford Road creates severe highway safety hazards and will
exacerbate the existing congestion on the approaches to the crossroads at the southern end of
Henley High St. These crossroads are identified by Warwickshire County Council as a current
major problem for congestion with no obvious solution given the built-up nature of the location.

Proximity to the proposed site access points
One of the two proposed access points into and out of site is virtually opposite the Arden Rd
junction with the A4189 Warwick Rd. Arden Rd represents a single entry and exit for c440
dwellings and the only vehicular access to Henley’s Primary Schools. Within 200 yards, Prince
Harry Rd provides the entry and exit for a further 110 dwellings and crucially is the only
vehicular access to Henley’s Medical Centre. The Warwick Rd site access is next to Henley’s
Secondary School and Venture Academy. While there are fewer dwellings (estimated at around 130) exiting onto the A3400 between the crossroads and the proposed site access, there are a significant number of access road junctions. Furthermore, Birmingham City FC training ground is opposite the site access and up to 75 cars may be entering or exiting at key times on weekdays. Further along the road, the Henley Memorial Sports Ground often accommodates c150 vehicles on match days. While not as severe as on the A4189, there will be an unavoidable adverse impact on congestion and road safety arising from the A3400 site access junction.

Traffic congestion, speed and road safety
265 dwellings will most likely translate into 400+ cars spilling out on to the A4189 and A3400 at
peak times creating even worse congestion and road safety hazards. Local residents are acutely
aware of the relatively high speeds (well in excess of the designated speed limits) of vehicles and powered two-wheeler traffic on the A3400 immediately south of the crossroads and on the
A4189 east and west of the crossroads, corroborated by Automatic Traffic Count surveys in
March. Pedestrians and cyclists face unacceptable hazards negotiating traffic at speeds up to and sometimes over 50mph when attempting road crossing.

Warwickshire Police view
In their response to a recent statutory planning consultation, Warwickshire Police stated that the
A4189 and A3400 are in the top 15 hotspots in the whole of Warwickshire for congestion, traffic
accidents and road safety. They make specific reference to the tailbacks in all 4 directions at the
crossroads at peak periods which is exacerbated by school traffic and multiplied many times over when traffic is diverted through Henley because of ‘incidents’ on the M40/M42.

Impact on emergency services.

Another increasing concern is the ability of emergency services to navigate their way through the congestion because the largest/heaviest vehicles often block the High St and rural lanes at peak times and when a motorway diversion occurs. No priority has been given to resolving the current congestion issues and accidents continue to occur even after speed calming measures have been put in place.

The requirements of NPPF 2026

TR6 para 3 states:
In assessing movement patterns and potential impacts, including whether they are considered to be severe, reasonable future scenarios should be considered, taking into account impacts at relevant times of the day, potential cumulative impacts, multimodal trip generation and the promotion of sustainable modes of travel, and realising the transport vision for the development itself. Development proposals should be considered having regard to these potential impacts and the other policies in this Framework which are relevant (including TR3, TR4 and DP3(2)(d)).
The Transport Assessment (TA) accompanying the Application does not adequately assess
‘reasonable future scenarios’ on the basis described above. Such an assessment is vital to
properly understand the impact.

NPPF 2026 – TR6 para 4 states:
Development proposals should be refused if they would have a severe adverse impact on the transport network (in terms of capacity and congestion, including cumulative impacts), or an unacceptable impact on highway safety; taking into account any mitigation measures proposed as well as any wider network improvements, including measures to support sustainable patterns of movement. This applies both during the construction phase and following completion.
As highlighted above, this development would have the severe adverse impact described in TR6
para 4. The mitigation measures proposed by the developer are totally inadequate and there are
no planned wider road network improvements that would ease the congestion and improve road
safety

Road safety audit
The required Stage 1 Road Safety Audit and Designers response was outstanding at the date of
the application. Only the brief for the Audit was included as an appendix to the TA

National Highways response
In their recent Consultation response, National Highways have highlighted serious flaws and
shortcomings in the applicants TA and, as result, have recommended SDC delay determination
for three months pending the better information needed for assessment and satisfactory answers to their queries. This is so fundamental, it must not be deferred to Reserved Matters.

Conclusion and request
HFC considers the above shortcomings in data analysis and the unresolvable impacts of this
proposed development on local highways, traffic congestion and road safety are so fundamental
that SDC should reject of this application rather than defer the question of site access points to
Reserved Matters.

3. SUSTAINABLE MODES OF TRANSPORT and CONNECTIVITY

HFC objects on the basis that the off-site infrastructure does not support a truly active travel
strategy and public transport services/connections are totally inadequate to support the strategy with very little prospect of that changing.

An active travel strategy that is not grounded in reality

Much is made of an ‘active travel’ strategy in the application. That would be fine if Henley was
an economic and employment growth centre and had ‘well-connected’ rail services and bus
routes. Unfortunately, neither condition is satisfied. The South Warwickshire Economic Strategy
does not identify Henley as an area for priority investment in economic development and
employment growth. It follows that an assumed working age population of 400+ will either need
to work from home or travel elsewhere to find jobs. The application identifies Henley Railway
Station as within walking/cycling distance of the development. We estimate that the centre of the site is around 1.6km from the railway station with a gradient involved rather than the 800m
without gradient used in Planning Policy as a measure of proximity. In any case, proximity to a
railway station is not the same as a ‘well-connected’ rail service and the current one train per
hour in either direction, with regular cancellations, is not going to help the vast majority of the
working age residents of the new development get to and from their place of work. Active travel
is a wonderful aspiration but wholly unrealistic in our area. While cycle paths can be included in
the design of the site, once off-site, ‘active travellers’ will find there are no dedicated cycle paths. Cyclists will need to run the gauntlet of congested roads, mega sized vehicles on narrow roads and lanes, haphazard and often illegal parking narrowing routes and frustrated drivers prepared to break the speed limit even on the High St. There isn’t any dedicated cycle parking on or near Henley High St which, in itself, tells a story.

Prospects for transformation in public transport services

There are very serious capacity constraints within the Birmingham/West Midlands railway
system which is regarded by Network Rail as one of the most congested and complex systems in the UK. There are some major projects such as the creation of the Midlands Rail Hub in progress to increase capacity between Birmingham and Cities and major towns to the North and South-West. However, the West Midlands Rail Strategy 2026-41 does not have enhanced services on the Shakespeare Line as a priority for investment over this timescale. In any case the Shakespeare line is a linear line running north to south only. Connectivity to other settlements and areas of employment east and west of Henley is virtually non-existent. There are no direct train services east to west and the bus services are very limited.

Requirements of NPPF 2026
Section TR6 para 4 states:
Development proposals should be refused if they would have a severe adverse impact on the transport network (in terms of capacity and congestion, including cumulative impacts), or an unacceptable impact on highway safety; taking into account any mitigation measures proposed as well as any wider network improvements, including measures to support sustainable patterns of movement. This applies both during the construction phase and following completion.

As highlighted above, there are no investment plans for the provision of sustainable modes of
travel, such as well-connected rail services, that would mitigate the impact of additional
vehicular movements.

Conclusion
The modal transport shifts assumed in the applicant’s TA used to extrapolate a future decline in
vehicular journeys is unjustified. Consequently, the TA understates the impact on traffic flows,
increased congestion and road safety. Required mitigation measures are neither practical nor
viable. Accordingly, HFC asks SDC to reject this application on this basis.

4. ECOLOGY and BIODIVERSITY

While the Ecology Appraisal accompanying the OPPA is extensive and includes seasonal
surveys, there remains unresolved evidence, the issue of survey limitations, deferred design and a mismatch between recorded sensitivity and the appraisal’s headline conclusion.

Inadequacy of evidence gathered re protected species
The evidence collected regarding such protected species as great-crested newts and water voles is admitted in the appraisal to be ‘inconclusive’ or that ‘no definite conclusion’ could be reached. The appraisal also notes that certain ponds were inaccessible. The evidence gathered so far is totally inadequate and Stratford District Council (SDC) must require further independent surveys under the supervision of Natural England before determining the OPPA.

Protection of bat population
There are 11 species of bat recorded along the river Alne corridor. At the OPPA stage there has
been no lighting design put forward that can be assessed as regards the threat it might pose to
these protected species. SDC must insist on a detailed lighting design scheme that includes a
parameter-level lighting envelope, a lux contour plan and dark -corridor standards. Additionally,
there must be satisfactory completion of extensive roost surveys for trees affected by the
development access and layout.

Presence of otters
As regards the presence of otters, the absence of a holt during surveys does not remove the
likelihood of commuting or resting scenarios. Construction excavations, noise, lighting and
recreational access are threats that require attention with a protected riparian corridor, escape
measures, sensitive working hours and a pre-construction update survey all secured in
enforceable controls.

Presence of white-clawed crayfish
There are 14 recordings of white-clawed crayfish within 1.5 miles of the site although the
Appraisal states that onsite eDNA was negative. This is not a reliable basis to conclude an
absence of white-clawed crayfish because it makes no allowance for upstream or downstream
connectivity, pollution sensitivity or future colonisation. SDC should ask WCC Ecology and the
Environment Agency to review the sampling effort and timing and determine what further
evidence is required to be collected.

More evidence required re wintering birds and invertebrates
SDC should also ask WCC Ecology to review the evidence gathered as regards wintering birds
and invertebrates to determine its adequacy.

NPPF 26 compliance
The following is an extract from the NPPF 2026 – Section 19 ‘Conserving and enhancing the
natural environment’ – para N2 para 2:
If significant harm to biodiversity resulting from a development cannot be avoided (through
locating on an alternative site with less harmful impacts), adequately mitigated or, as a last
resort, compensated for, then the development should be refused.

Given the widely recognised richness of biodiversity along the river Alne corridor, SDC must not
determine the OPPA until sufficient evidence has been gathered which can be properly assessed as regards the level of harm which cannot be satisfactorily mitigated. Otherwise, there is significant risk that the statutory environmental protections will be contravened and legal
remedies pursued.

Conclusion and request
The potential harms to protected species and other wildlife caused by the construction of the
houses and related infrastructure, noise, lighting, contamination and pet predation are very
serious, and in our view are not adequately mitigated against. Furthermore, harms caused by
such development and inadequate mitigation cannot be reversed.

If SDC are disposed to grant permission, they must require strict steps to be taken to prevent
pollution, contamination and harms during the construction phase and after. Furthermore, they
must ensure other robust and verifiable protection measures are in place to ensure biosecurity
irrespective of established presence of protected species.

BIODIVERSITY Net Gain Audit
The claimed gains (18.75% habitats, 13.34% hedgerows and 20.29% watercourses) are expressly indicative and depend on the illustrative layout of the scheme, the estimated land-cover split, assumed habitat conditions, 150 estimated street trees (position and specification undetermined) and 30 years + of future management, monitoring and remediation.

The floodplain meadow is classified as ‘other neutral grassland’ because its flooding regime is
uncertain.

The metric does not include indirect effects such as increased lighting, disturbance, recreation
activity, pets, surface water run-off, and pollution.

Conclusion and request
HFC considers this level of uncertainty and lack of precision unacceptable given that BNG is a
statutory requirement (Environment Act 2021).
SDC should require the following BNG safeguards:

• A parameter-plan land budget fixing the minimum areas required for river buffers,
  woodland, veteran-tree buffers, retained habitat, SuDS and significant BNG enhancements.
• A sensitivity test showing whether the scheme still exceeds 10% if street-tree numbers fall,
  target grassland/woodland condition is not achieved, or developable parcels expand.
• Agreement that the final metric cannot reduce safeguards shown in the outline evidence;
  otherwise, the Council risks approving a scheme whose only demonstrated BNG scenario
  later proves undeliverable.
• A draft Habitat management and monitoring plan at outline stage sufficient to demonstrate
  ownership, funding, responsibilities, monitoring intervals, success criteria and remedial
  measures for at least 30 years.
• Separate ecological mitigation for protected species and the River Alne LWS. The 10%
  metric must not be treated as a substitute for avoiding or mitigating those impacts.

5. FLOODING and DRAINAGE

The proposed surface water drainage strategy for the site is not in accordance with the design
standards outlined in the National Sustainable Drainage Standards (NSfS) or Warwickshire
LLFA guidance. This is not compliant with NPPF 2026 which requires surface water drainage
strategies to be designed in accordance with the NSfS design requirements.

Outfall hierarchy
Under NSfS Standard 1 consideration of the outfall hierarchy is required. The first priority
outfall is the re-use of water. No justification other than the development type been residential
has been provided to evidence why rainwater harvesting cannot be utilised as the proposed
discharge methodology. The Flood Risk Assessment (FRA) identifies a surface water strategy
based on discharge to the River Alne and concludes that infiltration is not a viable option.
However, it simultaneously confirms that no BRE365 infiltration testing has been undertaken
and that infiltration has been discounted on the basis of desktop geological information alone –
the site will have Mercia Mudstone Group as its geological composition. Consequently, the
proposed discharge methodology is to the River Alne which bisects the site and is located within Flood Zones 2 and 3.

Management of rainfall
A significant concern is the assessment against NSfS Standard 2 (management of everyday
rainfall). The report acknowledges that the proposed soft SuDS features would intercept only
54% of the first flush rainfall volume and relies heavily on assumptions that additional features
or favourable infiltration rates may be incorporated at a later stage. Rather than demonstrating
compliance, the report effectively states that compliance could potentially be achieved during
Reserved Matters. This falls short of the requirement to show that the site can deliver the
interception standards and therefore does not provide sufficient evidence of compliance at
outline stage. This is likely to have a fundamental impact on the space required for SuDS areas
which will impact on the net developable area at the site.

Inadequacy of the applicant’s drainage strategy
HFC consider that the proposed surface water drainage strategy should have been calculated
considering the impermeable area associated with the attenuation basins and an allocation of any green spaces within the development. This is a requirement under Standard 3 of the NSfS. This is highly likely to result in a requirement for additional attenuation area, which has not been considered within the masterplan and will also have an impact on developable area of the site and housing numbers and/or density. The attenuation basins which have been proposed within the surface water drainage strategy, are deep features with side slopes of 1:3 for the majority of the basin. This is not in accordance with the Warwickshire County Council LLFA Flood Risk Guidance for Developers, which requires attenuation basins to be no deeper than 1m with an additional allowance of 0.3m for freeboard. The proposed attenuation basins are up to 2m deep which presents a health and safety risk due to the depth of water and does not provide the amenity benefits of a shallower basin. The Warwickshire County Council LLFA design guide recommends the use of 1:4 side slopes for attenuation basins, which would also provide the amenity benefits required under Standard 5 of the NSfS. This will require additional space to be allocated for attenuation in the masterplan.

Assessment of outfall during flood events

Similarly, whilst discharge to the River Alne is proposed, there is little assessment of outfall operation during flood events, or the interaction between the proposed drainage system and the river when water levels are elevated. There has been no consideration of surcharged outfalls which are highly likely due to the flood extents shown within the Environment Agency flood zone mapping.

Lack of comprehensive, integrated SuDS management train

The drainage strategy is also heavily reliant on large attenuation basins located at the end of the drainage system, with swales, rain gardens, permeable paving and other source control measures only suggested rather than fully incorporated into the design. Warwickshire LLFA guidance promotes a distributed SuDS management train integrated throughout developments to provide flood risk, water quality, biodiversity and amenity benefits. The current approach demonstrates storage capacity but does not clearly demonstrate delivery of a comprehensive SuDS management train across the site. There is no consideration of the inclusion of amenity and biodiversity benefits within the SuDS design at the site, with a largely pipe to pond design approach with swales only incorporated at the edges of the development. There is no indication of an integrated SuDS approach throughout the entire development to convey surface water flows to the attenuation features. This is a requirement within Standard 5 and 6 of the NSfS. Evidence should be provided that amenity and biodiversity have been considered within the development of the drainage strategy at the site.

Flawed foul water drainage strategy

The proposed foul water drainage strategy requires the inclusion of a Type 3 foul water pumping station, which will require a 15m cordon sanitaire from a residential dwelling. The drainage strategy does not indicate the cordon sanitaire on the drawing, which yet again will impact on the net developable area, housing numbers/density. The western area of the site is proposed to outfall via a rising main from the pumping station under the River Alne. This is inconsistent with the general principle of designing infrastructure out of areas of flood risk and introduces an avoidable operational and pollution risk within a sensitive river corridor. This does not represent a sustainable or resilient foul drainage strategy.

Groundwater conditions

The FRA contains limited site-specific evidence relating to groundwater conditions, despite acknowledging groundwater susceptibility of 25-50% across the site. No groundwater monitoring has been undertaken, and no evidence is provided to demonstrate how groundwater may affect the long-term performance of attenuation features. Consideration of the floatation requirements of the attenuation basin may be required at detailed design.

Flood hazard rating assessment outstanding

The Environment Agency’s surface water flood map clearly demonstrates that there is surface water flood risk on the Warwick Road in the 1 in 100-year event including consideration of climate change. No hazard rating assessment has been undertaken to confirm that safe access and egress has been provided for the lifetime of the development, which is a requirement of the NPPF. If evidence cannot be provided that safe access and egress can be achieved, then a site-specific sequential test should be applied to the site. As the site is not allocated within the local plan and therefore has not passed a sequential test assessment this should be considered by SDC.

Conclusion and request

The submitted FRA does not provide sufficient evidence to demonstrate that the proposed development is safe from flooding for its lifetime or that it fully complies with the NSfS and Warwickshire County Council LLFA guidance. Key elements of the strategy, including infiltration potential, interception requirements, groundwater conditions and detailed drainage design, remain untested or deferred to future stages, whilst the Sequential Test has not been robustly addressed. As a result, significant uncertainty remains regarding the deliverability, resilience and sustainability of the proposed drainage solution, and the application should not be supported until the necessary technical evidence has been provided.

The potential impact of addressing the shortcomings highlighted above of the site is likely to have significant implications for the developable area of the site and, therefore, on the number and density of housing. We urge the Council to take a robust approach to these outstanding assessments and requirements, even if the result is to materially impact the viability of the applicant’s scheme.

6. GREEN BELT

Henley’s Future Counts objects to the applicant’s assertion that Blackford Mill Farm qualifies as
grey belt.

Requirement for an independent assessment
The Council should independently assess the land’s contribution to preserving the setting and
special character of historic Henley-in-Arden, rather than accept the applicant’s characterisation of that contribution as merely “moderate”. Henley’s historic character extends beyond individual buildings. Henley is a distinctive historic market town whose development is principally organised along the linear spine of its High Street. Its concentration of well over 100 listed buildings on or close to that street, together with its conservation area, establishes the importance of its historic townscape.

Preserving Henley’s special character and rural setting
That significance is expressed through the relationship between the historic high street, the
settlement’s overall form and its surrounding countryside. Preserving the buildings while
substantially changing the town’s rural setting and southern approach would not necessarily
preserve its special character.

The application site should therefore be assessed as part of this wider relationship. Its position
south-east of Henley, within the countryside towards Wootton Wawen, is material to
understanding how Henley is experienced as a distinct historic town in a rural setting.

The assessment must also address the site’s physical and experiential relationship with the
historic town. Relevant considerations include the transition from countryside into Henley, the
legibility of its southern edge, the relationship between its linear historic form and surrounding
open land, and the experience of the landscape from roads and public rights of way.

Excessive reliance on limited intervisibility
In HFC’s view the applicant places excessive reliance on intervisibility. At paragraph 6.7, printed
page 25, the Planning Statement summarises the applicant’s assessment of Green Belt purpose
(d). It relies on limited intervisibility with the conservation area, intervening development and
infrastructure, and an asserted absence of effects on key views, landmarks or designated heritage assets. These considerations do not, individually or collectively, establish that the site makes only a moderate contribution to Henley’s historic setting.
A restricted view from the High Street does not demonstrate that surrounding countryside is
unimportant to the town’s setting. Equally, the presence of intervening infrastructure does not
establish that the historical and spatial relationship has been severed.

Broadening Henley’s settlement form
The development would significantly broaden Henley’s settlement form. The proposal for up to
265 dwellings would introduce a substantial area of residential development south-east of
Henley’s historic linear spine. HFC’s concern is that this would broaden and consolidate the
settlement into countryside, weakening the distinction between the historic town and its rural
surroundings.

At paragraph 6.7, in the Planning Statement, the applicant acknowledges that development
would extend Henley’s settlement boundary but describes that extension as not significant. That
conclusion requires a reasoned assessment supported by comparative settlement plans and
landscape evidence.

The Council should examine the proposed change in the town’s footprint, depth and southern
edge. The question is whether the land currently makes a considerable contribution to the special character of historic Henley—not simply whether new housing could be partially screened.

Henley and Wootton Wawen are separate settlements
The countryside between Henley and Wootton Wawen has a meaningful role. Henley and
Wootton Wawen are separate settlements with their own historical identities and rural settings.
The intervening countryside allows each to be experienced as a distinct place rather than as part of an increasingly continuous developed corridor.

HFC does not suggest that this application would physically join the two settlements. The
objection is that it would advance Henley’s developed edge into the intervening countryside and
weaken the rural transition which helps distinguish the settlements.

Wootton Wawen’s status as a village means that this issue should not be treated as automatically establishing Green Belt purpose (b). Nevertheless, the contribution of the intervening landscape to Henley’s historic setting, settlement identity and rural character remains material.

Vegetation and roads do not resolve the objection. The applicant relies on well-vegetated
boundaries and intervening infrastructure as evidence of containment. These features may
influence visibility, but they do not establish that a substantial residential extension would
preserve the town’s relationship with its countryside.

Retained planting, landscaped buffers and public open space may soften development. They
cannot be assumed to preserve the existing historical and spatial relationship after open
agricultural land is converted to a residential neighbourhood.

Our conclusion and request
HFC considers that the applicant has not adequately demonstrated that the site makes less than a strong contribution to Green Belt purpose (d). The Council should reject the claimed grey belt status unless a properly evidenced assessment establishes otherwise

Accordingly, before determining the application, HFC requests that the Council obtain an
independent assessment which:

1. Evaluates the site’s contribution to the setting and special character of historic Henley,
   including physical and experiential relationships.
2. Compares the existing and proposed settlement form, with particular attention to
   Henley’s linear pattern and southern approach.
3. Examines winter views and experiences from relevant roads, public rights of way and
   Beaudesert Mount.
4. Explains whether different parts of the site make different contributions, rather than
   relying on a single overall rating.
5. Addresses the implications of the outline proposal without assuming that an illustrative
   layout or future planting will secure acceptable effects.

7. ARDEN SPECIAL LANDSCAPE AREA (ASLA)

Henley’s Future Counts objects to the proposed development because it would permanently
urbanise agricultural land within the Arden Special Landscape Area, harming its distinctive
landscape character and the relationship between historic Henley-in-Arden and its rural
surroundings.

Policy CS.12 provides substantive protection
Core Strategy Policy CS.12 protects the landscape quality of Special Landscape Areas, including
their historic and cultural features. It requires consideration of cumulative impacts and respect
for the current and historic relationship between settlements and their surrounding landscape.
The designation is not an absolute prohibition on development. However, the Council must
identify the harm to the qualities for which the landscape is designated, assess the proposal’s
compliance with CS.12 and give any conflict appropriate weight in the planning balance.
Neither a housing land supply shortfall nor a conclusion that the site qualifies as grey belt would, by itself, remove this separate landscape objection.

The applicant narrows the Council’s landscape sensitivity findings
The applicant’s Landscape and Visual Appraisal, paragraph 3.16, page 20, identifies the two
northernmost fields as falling within assessment parcel H05.

The Council’s Landscape Sensitivity Study rates H05 as high/medium sensitivity to housing. Its
assessment identifies concerns about development prominence, departure from the existing
settlement pattern, loss of sensitive pasture and effects on Henley’s rural eastern approach.

The applicant reproduces those findings at paragraph 3.17, page 21. However, paragraph 3.18
then presents the key finding principally as a visual-impact issue concerning views from the
eastern approaches.

In our view that interpretation is too narrow. The Council’s concerns also address landscape
character, land use and settlement form. Screening buildings would not, in itself, resolve those
concerns.

The study’s generic description of high/medium sensitivity allows development only in limited
circumstances without significant adverse effects. It does not override the specific assessment of H05. The applicant should demonstrate why this particular proposal satisfies those limited
circumstances.

The applicant’s own findings demonstrate lasting landscape change
The appraisal recognises:
 High landscape value at paragraph 3.34, page 29.
 High sensitivity of the site at paragraph 3.38, page 30.
 High sensitivity of the ASLA in the site’s context at paragraph 3.45, page 31.
 A major effect on the site’s character at Year 1, paragraph 6.11, page 45.
 A major/moderate effect remaining at Year 15, paragraph 6.13, page 45.

These findings require substantial scrutiny. The permanent replacement of farmland by housing,
roads, gardens and associated infrastructure cannot be dismissed simply as an expected
consequence of developing a greenfield site.

HFC considers that this lasting change would harm the distinctive character protected by CS.12.

Assessing the entire ASLA risks understating local harm

At paragraphs 6.25–6.26, page 47, the applicant relies partly on the development affecting a very small proportion of the ASLA taken as a whole. It predicts moderate/minor adverse effects at Year 1, reducing to negligible effects at Year 15.

A development can cause serious harm to a particular part of a designated landscape while
affecting only a small percentage of its total area. The Council should assess the importance of
the affected landscape and the magnitude of its alteration, alongside the geographical extent of
effects.

Otherwise, successive developments could each be described as too small to matter, despite
progressively eroding the landscape qualities which CS.12 protects.

Planting would soften development without restoring the agricultural landscape

Retaining hedgerows, adding woodland and providing public open space may reduce visibility
and offer environmental benefits. Those measures do not necessarily preserve the existing rural
character.

The appraisal acknowledges at paragraph 2.6, page 8, that field parcels and public rights of way
have remained substantially intact since the late nineteenth century. Their value lies partly in
their relationship with the surrounding agricultural landscape.

Retaining field boundaries or footpath alignments within a residential development would
preserve individual features while fundamentally changing their context. Mature planting at Year
15 would not restore the lost farmland or reverse the extension of Henley’s developed edge.

Landscape safeguards must be demonstrated at outline stage
The appraisal relies on an illustrative masterplan, substantial open space and future planting.
With layout, scale and landscaping reserved, the Council should require sufficient binding
parameters to establish that the claimed mitigation can be delivered.

These should identify development limits, maximum building heights, protected landform,
retained vegetation, river and heritage buffers, and the minimum extent of permanent open space. Claimed landscape benefits should not depend on an arrangement which could materially change at reserved matters stage.

Our conclusion and request
HFC asks the Council to obtain an independent landscape review addressing the specific H05
findings, the applicant’s acknowledged lasting effects on site character, and the assessment of
local harm within the wider ASLA.

The Council should assess cumulative effects with other relevant committed development and
explain how the proposal respects Henley’s historic relationship with its landscape.

Unless that review demonstrates otherwise, HFC considers that the development conflicts with
Policy CS.12 and that this conflict should weigh strongly against permission being granted.

8. HERITAGE HARM

HFC objects to the proposed development of up to 265 dwellings at Blackford Mill Farm
because of the harm it would cause to the significance and setting of Blackford Mill and the
associated historic buildings. We consider that the applicant’s conclusion of no heritage harm is
insufficiently justified and understates the importance of the surviving relationship between the
mill, its agricultural surroundings and the River Alne.

The site directly surrounds Grade II Listed Blackford Mill and Blackford Mill Farm Buildings.
Tithe maps from 1840 and sale particulars from 1887 prove the fields form the original
agricultural setting of these assets.

We ask the Council to refuse the application in its present form. Before reaching any decision,
the Council should obtain a reasoned assessment from its Conservation Officer addressing each
affected heritage asset, their significance as a group, and the consequences of transforming their surrounding rural landscape.

The significance of Blackford Mill and its associated buildings
Blackford Mill is a Grade II listed former corn mill, National Heritage List entry 1382224.
Historic England dates the building to approximately 1830 and records surviving corn-milling
machinery, including an unusual cast-iron supporting structure supplied by a Tanworth
millwright and three grinding wheels with hoppers. These recorded features demonstrate
architectural, technological and historic interest extending well beyond the building’s external
appearance.

The nearby farm buildings are separately listed at Grade II under entry 1382225, Farm Buildings
Approximately 20 Metres North East of Blackford Mill. Their description identifies late
eighteenth-century stables and cattle sheds and a nineteenth-century barn, and expressly
recognises their group relationship with the mill. They provide surviving evidence of the
agricultural activities associated with this historic location.

Blackford Mill comprises the water mill and its attached residence. The heritage assessment
should address the significance of the complete building, including the relationship between its
milling and residential components. The attached residence forms part of the historic complex
whose significance and setting would be affected by the proposed development.

HFC understands that the water mill has been lovingly and meticulously restored over a great
many years by the current owners and occupants of Blackford Mill. The heritage assessment
should establish the extent of surviving and restored machinery, water-management features and other historic fabric, and explain their significance. Restoration should not be treated as
diminishing the importance of conserving the surroundings through which the mill’s original
purpose can still be understood.

The rural and riverside setting contributes to heritage significance
The mill complex should be understood as an interconnected historic place: a water-powered
corn mill, associated buildings, agricultural land and a river supplying the essential conditions
for milling.

The surrounding fields are therefore potentially more than an attractive backdrop. Their historic
ownership, use and spatial relationship with the mill help explain why the buildings exist here
and how the complex operated. Retaining the buildings while substantially urbanising the setting would preserve their fabric but could materially diminish the ability to understand and
appreciate their historic significance.

Our earlier review of the applicant’s Archaeology and Heritage Assessment identified that its
Blackford Mill assessment acknowledges both the historic connection between much of the
application site and Blackford Mill Farm and the positive contribution made by the surviving
rural setting. The Council should examine how those findings have been reconciled with the
subsequent conclusion of no harm.

A landscape buffer cannot, by itself, preserve the historic relationship between an agricultural
complex and the surrounding agricultural land.

Development would change the character of the heritage setting
HFC considers that housing development across the surrounding fields would introduce a
substantially different environment around the mill complex. Houses, residential roads, parked
and moving vehicles, domestic boundaries, lighting and associated activity would replace
important elements of its agricultural surroundings.

The concern is the effect of those changes on heritage significance. The mill and farm buildings
would increasingly be experienced within a residential development rather than as a historic
agricultural and milling group in a rural riverside landscape.

Keeping some land undeveloped beside the river would not necessarily avoid this harm. The
Council must assess whether the proposed open space would retain the meaningful historic
setting of the assets, taking account of development on either side, or instead become an amenity corridor within a housing estate.

Setting cannot be assessed through visibility alone
The applicant’s reliance on vegetation, restricted views and separation distances requires
particular scrutiny. Historic England’s setting guidance recognises that the contribution of setting encompasses the surroundings in which an asset is experienced and understood; assessment must extend beyond whether new buildings can be seen from selected viewpoints.

The assessment should address:
 Historic and functional connections between the mill, farm buildings, house, river and
surrounding fields.
 Views towards and between the historic buildings, including winter conditions.
 The experience of approaching the group along existing routes and public rights of way.
 Changes arising from traffic, lighting, noise and residential activity.
 The effect of proposed planting on the appreciation of the historic group itself

Screening may reduce some visual effects, but it does not restore lost agricultural relationships.
Extensive screening could also obscure the historic buildings and reduce opportunities to
appreciate their connection with the surrounding landscape.

The mill’s relationship with the water environment requires assessment
The River Alne and any surviving mill channels, races, weirs, sluices or related archaeological
remains should be considered as potential components of the mill’s significance.

The Council should establish which features survive and assess whether drainage proposals,
outfalls, earthworks, paths, crossings or other infrastructure could affect them. Where relevant,
this should include changes to water levels, flows, sediment movement and maintenance
arrangements.

HFC does not assert that damage to the mill’s water system has already been demonstrated. Our objection is that these potential pathways of harm require investigation before the Council can confidently conclude that the development would preserve the heritage assets and their settings.

Heritage acceptability must be established at outline stage
Although detailed layout, appearance, scale and landscaping may be reserved, the principle and
amount of development have consequences for heritage significance.

The Council should not grant outline permission on the assumption that later design and
landscaping will resolve harm that arises from developing the surrounding land itself. It needs
sufficient information now to establish whether the proposed amount of development can be
accommodated acceptably.

Any reliance on mitigation must be supported by enforceable parameters, including justified
development-free areas, building-height limits, protection of important views and historic routes, and lighting controls. An illustrative buffer does not provide equivalent certainty.

The statutory and policy duties require a properly weighted heritage judgement
Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires
special regard to the desirability of preserving listed buildings, their settings and their features of special architectural or historic interest.

Core Strategy Policy CS.8 protects designated and non-designated heritage assets and their
settings, including traditional farm buildings and features reflecting historic human interaction
with the landscape. It requires proportionate assessment of significance and development
informed by the historic context.

The current NPPF’s national decision-making policies HE4, HE5 and HE6 require avoidance or
minimisation of heritage harm, adequate assessment of significance and effects, and substantial
weight to conservation. Harm to designated heritage assets requires clear and convincing justification and carries considerable importance and weight in the assessment against public
benefits.

HFC recognises that housing and affordable housing can provide public benefits. However, those benefits must be weighed against an accurately identified heritage impact. A conclusion of no harm must not remove heritage harm from the balance where the evidence does not support that conclusion.

We do not equate the size of the development automatically with “substantial harm”. The
Council must identify the degree of harm to the significance of each asset through a reasoned
assessment.

Conclusion and request
The central issue is whether this development would preserve the significance of an important
historic milling and agricultural group of buildings. Retaining the buildings while fundamentally
changing the surroundings that explain their origins and historic purpose does not, by itself,
demonstrate heritage conservation.

HFC considers that development of the site would sever this historic link, triggering the statutory presumption against permission under Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

Accordingly, HFC asks the Council to refuse the application in its present form because it has
not satisfactorily demonstrated that the proposed development would conserve the significance
and setting of the Blackford Mill heritage group.

Before determination, we request:

1. A conservation officer’s assessment of Blackford Mill, comprising the water mill and
   attached residence, and the separately listed farm buildings, addressing their individual
   significance and their relationship as a historic group.
2. Confirmation that the heritage assessment covers the complete Blackford Mill building,
   its milling and residential components, and any associated historic structures or water-
   management features relevant to its significance.
3. A reasoned examination of the applicant’s no-harm conclusion against the acknowledged
   historic land relationships and surviving rural setting.
4. Assessment of winter views, public approaches, non-visual effects and the mill’s
   relationship with the water environment.
5. Sufficient outline parameters to demonstrate that any necessary mitigation is achievable
   and enforceable.
6. An explicit identification of heritage harm and a properly weighted assessment against
   the claimed public benefits.

9. INFRASTRUCTURE

Henley’s Future Counts objects to the proposed development unless and until the Council is
satisfied, on current evidence from the relevant infrastructure service providers, that the
additional demand can be accommodated without unacceptable harm to existing residents,
service provision or the water environment. Where additional capacity is necessary, its scope,
funding, delivery and timing must be demonstrated and secured through appropriate conditions
and obligations.
Reserving layout, scale, appearance and landscaping does not remove infrastructure capacity
from consideration at outline stage. These matters affect the acceptability of the principle and
amount of development.

National Planning Policy Framework 2026 requirements

This objection relies on the August 2026 NPPF national decision-making policies. Annex A
paragraph 1 makes the Framework material to decisions from publication. Any transitional
arrangements applicable to preparation of the SWLP do not postpone application of the 2026
decision-making policies to BMF. References below use the new policy identifiers and numbered
subparagraphs, rather than the paragraph numbering of the 2024 Framework.

HC3 paragraphs 1(a), 1(b) and 3 are directly relevant to the proposed 265 homes. Proposals
generating significant additional numbers of people should be informed by an understanding of
necessary improvements to community facilities and public service infrastructure, on or off-site,
and provide the improvements needed to make the development acceptable, either directly or
through contributions. Paragraph 3 requires conditions and obligations to secure timely delivery
so that the necessary facilities are available when development, or an agreed proportion of it, is
first occupied. HFC therefore asks SDC to identify the healthcare and education capacity needed, the means of delivering it and appropriate occupation triggers. An unspecified payment or reliance on an uncommitted HEN.1 facility does not demonstrate compliance with this timing
requirement.

GB8 paragraph 1(b) includes necessary local or national infrastructure improvements among
the Golden Rules for major housing development on Green Belt sites subject to an application.
GB8 paragraph 2 requires substantial weight to be given to compliance with the Golden Rules.
Further, GB7 paragraph 1(g)(iv) makes compliance with GB8 a condition of the grey-belt
exception for major housing. Consequently, even if the applicant establishes that the land
qualifies as grey belt, it must also demonstrate the necessary infrastructure provision. HFC does
not concede that the site qualifies as grey belt.

P3 paragraphs 1, 2(b) and 2(f) require consideration of pollution, including cumulative and off-
site effects, avoidance or acceptable mitigation of water pollution, and assessment and mitigation where unacceptable water-quality effects could arise. These provisions support a site-specific assessment of BMF’s additional foul flows, the receiving sewerage system and effects on the River Alne. Under P3 paragraph 3 and DM7, separate pollution regulation is generally assumed to work effectively unless there is clear contrary evidence. Our objection therefore addresses the planning consequences of additional loading and delivery of infrastructure, without alleging that recorded overflow events alone establish unlawful operation.

DM6 paragraphs 1 and 4 govern conditions and obligations: conditions must be necessary, relevant, precise, enforceable and reasonable, and obligations should be used where potential unacceptable impacts cannot be addressed through a condition. HFC asks for identified, deliverable mitigation with appropriate triggers, rather than an assumption that unresolved capacity issues can always be deferred.

F8 paragraphs 1 and 2 support the drainage objection: SuDS should control runoff, follow national standards, have lifetime maintenance arrangements and, for major development, take account of LLFA advice. Surface-water measures do not establish adequate foul-sewage treatment capacity.

Scope of the references: HC1 concerns plan-making and should not be presented as a direct test for determining BMF; the Framework’s Introduction paragraph 8 expressly distinguishes the two policy categories. W4 concerns proposals for water infrastructure itself and supports necessary upgrades, rather than constituting a standalone capacity test for this housing application. Strategic-site-specific requirements should not be applied to BMF merely because they may apply to the much larger HEN.1 proposal.

HFC asks SDC to explain in its report how the proposal meets HC3, the applicable Green Belt requirements and P3, and to withhold permission where necessary infrastructure or pollution mitigation cannot be demonstrated and secured. This is a request to apply those policies within the overall planning assessment, not an assertion that every infrastructure uncertainty automatically requires refusal.

Henley Medical Centre
Under NPPF 2026 HC3(1)(a), HC3(1)(b) and HC3(3), HFC objects because the ability of local
primary healthcare provision to accommodate the additional population requires a specific, up-
to-date assessment. Proximity to Henley Medical Centre does not establish that it has spare
clinical or premises capacity.

The SWLP Infrastructure Delivery Plan Part 2, Table 5-5 (printed page 51), records 6,572
patients and 4.04 full-time-equivalent GPs at Henley-in-Arden Medical Centre, using January
2026 data. Published statements in relation to SWLP HEN.1 indicates this currently represents
full or near full capacity based on the current constraints of the physical location.

For illustration only, 265 occupied homes at 2.3 people per dwelling would accommodate
approximately 610 residents. If all registered with this practice, that would add approximately
9.3% to the published patient list. This is a sensitivity illustration, not an official occupancy
forecast or an assertion that every resident would register there.

SDC should obtain an assessment from the responsible NHS Integrated Care Board, informed by the practice, covering current list size, premises constraints, clinical workforce, forecast
additional demand and the practical means of accommodating it. It should assess the
development alongside committed growth affecting the same services.

Any necessary developer contribution should identify the works or capacity it will help deliver.
A capital payment alone does not establish that NHS recurrent funding or staff recruitment is
secured. Mitigation must also retain reasonable accessibility for existing patients, including older residents and those without cars. HFC asks SDC to withhold approval while any material
capacity deficit remains unresolved.

Henley in Arden Secondary School
Under NPPF 2026 HC3(1)(a), HC3(1)(b) and HC3(3), HFC objects because the published SWLP
evidence indicates limited overall headroom at Henley-in-Arden School, requiring a current,
year-group-specific assessment of the additional pupils arising from BMF.

The SWLP Infrastructure Delivery Plan Part 2, Appendix B school table (printed page 94), lists a
published admission number of 140, total capacity of 700 and 683 pupils on roll. This implies
only 17 places of overall headroom at that snapshot. It does not mean that 17 places are available in the year groups or at the dates required. The school’s 2026/27 admissions policy confirms the admission number of 140.

WCC should provide pupil-yield calculations using the proposed dwelling sizes, tenure and
occupation programme; current and projected places by year group; and the effect of committed development within the relevant education planning area. Forecasts should address special educational needs and post-16 demand as appropriate.

If expansion is required, SDC should establish the physical feasibility, necessary land, cost,
funding, approvals and delivery timetable in agreement with WCC and the academy trust. The
assessment should also address safe walking and cycling routes, road crossings and school
transport where needed.

HEN.1 proposes expansion of Henley-in-Arden School and a sixth form. That proposal
reinforces the need for a coordinated assessment, but does not prove that BMF can use future
places or that expansion is funded. The same spare places must not be counted for several
developments, and the same expansion must not be assumed to mitigate them all without a
quantified allocation of capacity.

Where a material shortfall is identified, permission should only be granted with a deliverable
remedy and appropriate phasing. A general promise to contribute towards education is
insufficient if the necessary places cannot be provided when children need them.

Wootton Wawen sewage treatment works
With particular reference to NPPF 2026 P3(1), P3(2)(b), P3(2)(f) and GB8(1)(b), HFC objects
because adequate sewerage infrastructure, treatment capacity, and protection of the River Alne,
must be demonstrated before the development is accepted in principle.

In responses to the SWLP Consultations, Severn Trent have previously commented on the
capacity constraints of their Wootton Wawen Sewage Treatment Works. Severn Trent should
confirm whether BMF would discharge to these works, the intended connection point,
intervening sewer and pumping arrangements, and the complete receiving catchment. This
objection does not assume that routing has already been confirmed.

Published summaries of annual event-duration monitoring report 54 storm overflow events
totalling approximately 474.6 hours in 2024 and 20 events totalling approximately 148.1 hours in
2025 at Wootton Wawen, discharging to the River Alne. These site-specific figures should be
checked against the original Severn Trent/Environment Agency returns before being used as a
formal evidence exhibit. They establish a reported history of repeated storm discharges, not their volume, lawfulness or the engineering cause. The lower 2025 totals do not, by themselves,
establish sufficient capacity for additional development.

SDC should obtain a reasoned assessment from Severn Trent, with Environment Agency advice
where relevant, addressing:
 Existing and forecast dry-weather and peak flows, infiltration and storm conditions.
 Capacity of local sewers, pumping stations, storm storage and treatment processes,
considered separately.
 Permitted discharge limits, compliance history and pollutant loads.
 The potential effect of BMF on sewer flooding and overflow frequency and duration.
 Additional loading from committed development in the same catchment.
 Necessary reinforcement or treatment upgrades, their funding, approvals and completion
dates.
 Effects on receiving-water quality, including low-flow conditions.

Separate surface-water SuDS do not treat foul sewage or establish spare treatment capacity. SDC should also establish that surface water will not be introduced into foul sewers in a way that worsens hydraulic loading.

HFC asks SDC not to approve the application on the basis of an unexplained “no objection” or a
future connection arrangement alone. Where essential improvements are required, an appropriate condition should prevent occupation of the affected phase until those improvements are operational. Such a condition needs a reasonable prospect of delivery; it should not conceal an unresolved fundamental constraint. If adequate provision cannot be demonstrated or secured, that weighs against permission.

Government planning guidance expressly permits requests for wastewater information where
capacity concerns arise, and consideration of occupation phasing pending necessary sewage
improvements.

Infrastructure to support cycling and pedestrian active travel
Proximity to nearby schools and community services such as the medical centre and Henley
High St, do not automatically mean safe access. There is no provision for cycling infrastructure,
whether dedicated safe cycle paths or cycle parking, outside of the proposed site development.
None exists at present. Safe pedestrian access is not assured due to the level of traffic congestion, speed of traffic on the A3400 and A4189 after the cross-roads and inadequate safe crossing points. The offered mitigation of one Toucan Crossing on the A4189 opposite the Secondary School is, frankly, little more than a token gesture and unlikely to alleviate the pedestrian risk which is already unacceptably high.

HFC objects unless the applicant demonstrates a deliverable network of safe, convenient and
inclusive walking, wheeling and cycling routes connecting the development to Henley-in-Arden
School, relevant primary schools, Henley Medical Centre, the town centre, railway station and
bus stops. Proximity measured on a map does not establish that the complete journey is practical or safe.

The following NPPF 2026 national decision-making policies apply:

TR3(1)(a) Development generating significant movement should be in a sustainable
location, or one that can be made sustainable, limiting the need for private-car
travel and offering a genuine choice of modes.

TR3(1)(c) and (e) Significant transport and safety effects should be mitigated acceptably, and
supported opportunities to improve walking, wheeling, cycling and public
transport in rural areas should be taken.

TR3(2) The Connectivity Tool should be used alongside other quantitative and qualitative evidence when assessing location connectivity.

TR4(1)(a) Walking, wheeling and cycling should receive first priority within the scheme
and in links with neighbouring areas, followed by access to high-quality public
transport so far as possible.

TR4(1)(b) Appropriate supporting features should be incorporated or contributed towards,
including continuous footways, segregated cycle facilities, appropriate
lighting, accessible secure cycle parking, seating and public-transport waiting
facilities.

TR4(1)(c)(i) and (ii) Routes should minimise conflicts between pedestrians, cyclists and vehicles
and meet the needs of disabled people, older people and children.

TR6(1) and (2) Significant-movement proposals should have a proportionate transport
assessment or statement and a travel plan, with delivery, monitoring,
management and fallback measures.

TR6(3) and (4) Reasonable future and cumulative scenarios should be assessed; unacceptable
highway-safety effects or severe transport-network effects, after mitigation,
warrant refusal.

TR8(1)(a) and (b)(iii)–(iv) Public rights of way should be protected and enhanced, with opportunities taken to improve safe, accessible links to services and public transport.

These provisions support the following requests to SDC and WCC:
 Assess the actual routes from the proposed housing areas to each key destination,
including crossings of the A3400 and A4189 where relevant, junctions, footway
continuity and widths, gradients, surfaces, accessibility and conflicts with traffic. Assess
school journeys at arrival and departure times.
 Identify the off-site works necessary to make those routes suitable, supported by
sufficient design and safety evidence to establish feasibility at outline stage. The form
and location of crossings should follow WCC’s assessment rather than be assumed in
advance.
 Demonstrate land availability, approvals, costs, funding, delivery responsibilities and
maintenance for the required works. Secure necessary routes and crossings before
occupation of the phase they serve, through justified and enforceable conditions or
obligations.
 Test any claimed reduction in car trips against the facilities and services actually
available. The travel plan should include measurable targets, monitoring, responsible
parties and funded fallback measures where initial measures fail.
 Ensure routes are usable by children, older residents and people with disabilities.
Recreational public footpaths should not automatically be treated as suitable year-round
school or healthcare routes, or as routes legally available for cycling.
 Reconcile lighting and active-travel design with protection of the River Alne corridor and
sensitive habitats. Safe access and ecological protection need an integrated, feasible
solution.

HFC asks SDC to establish the essential connections and their deliverability now. Detailed
internal street design may be addressed at reserved matters, but fundamental dependence on an unavailable off-site route, unproven crossing or uncommitted improvement should not be left
unresolved. Where the applicant claims the grey-belt exception, GB7(1)(g)(iii) expressly requires
a sustainable location with particular reference to TR3; active-travel connectivity is therefore
also relevant to that exception.

Failure to supply an adequate active-travel package should be assessed against TR3 and TR4 in
the overall planning balance. The specific refusal tests in TR6(4) require evidence of
unacceptable safety effects or severe network effects, rather than merely the existence of a route deficiency.

Conclusion and request
Required infrastructure to support a sustainable development must not be aspirational,
uncommitted, unfunded with no definite timescale. At present there are serious concerns over
inadequate infrastructure capacity in critical areas identified above. Before determining the
OPPA, we request that the Council obtain all relevant data from the providers of infrastructure to
assess any material inadequacies or shortfalls, and require a deliverable plan in each case to deal with the inadequacy or shortfall. The plan should demonstrate deliverability, funding and an
acceptable timescale for the provision ahead of the housing development.

APPENDIX

HENLEY’S FUTURE COUNTS
Henley’s Future Counts (HFC) was founded in June 2026 by a group of concerned residents in
response to the threat of significant developments that would overwhelm the town and
community threatening the historical character and rural setting of Henley in Arden.
We are an independent, non-political community action group dedicated to ensuring that any
future developments in Henley- in -Arden are properly planned, proportionate, sustainable and
genuinely beneficial to both current and future generations. Our guiding principle is the right
homes, in the right places, on the right scale supported by the right infrastructure. Invariably,
speculative development does not align with such a principle, in which case the Community
needs a strong voice.
HFC has over 700 declared supporters, which is increasing weekly, providing the community
with a focal point to voice their clear and considerable concerns over the threat and scale of the
developments we are facing.