1. Were communities given comparable opportunities to engage?

Regulation 18 was the stage at which residents could comment on the emerging spatial strategy, potential development locations and reasonable alternatives before the final strategy was settled.

The available evidence suggests substantial differences in the degree to which local councils actively informed and mobilised residents in communities affected by major proposed growth locations.

In Bearley and Wilmcote, the Parish Council actively alerted residents to the potential new settlement, explained its significance, directed residents to the consultation material, organised a dedicated public meeting and encouraged residents to respond. In addition, the council submitted a formal objection to the plan.

In South Stratford, no equivalent programme of resident-facing engagement by Stratford-upon-Avon Town Council has been identified from its website and social media. In addition, Stratford-upon-Avon Town Council submitted a Regulation 18 response supporting both STR.2 and the Long Marston Airfield development proposal.

This resulted in dramatically different numbers of responses submitted regarding the two locations: the BW proposal generated 1,064 Regulation 18 representations, including 934 objections. By comparison, SG19 / East of Stratford generated 279 representations.

On a population-adjusted basis, Bearley and Wilmcote generated approximately 22 times as many representations per 1,000 residents as South Stratford. These figures do not establish the number of individual residents involved, but they demonstrate a substantial difference in recorded participation.

This distinction is particularly significant because the communities with the highest levels of recorded participation subsequently saw their proposed growth locations removed from the Regulation 19 spatial strategy, while other locations with substantially lower levels of recorded participation progressed.

The issue is therefore not whether a particular number of objections should determine the outcome of a Local Plan. Rather, it is whether residents affected by different strategic growth proposals had a genuinely comparable opportunity to become aware of, understand and respond to the emerging spatial strategy.

2. Was Stratford-on-Avon District Council's publicity sufficiently effective?

Stratford-on-Avon District Council was under a statutory duty to publicise the Regulation 18 consultation and undertook wider publicity through social media, a dedicated website, promotional videos, press releases, newspaper advertising and public consultation events.

The issue identified by this review is therefore not whether publicity took place, but whether the methods used were sufficiently targeted, accessible and informative to reach residents affected by major strategic growth proposals.

The Council's own figures suggest relatively limited active engagement with its social-media publicity. Across Stratford District's channels, the consultation videos received 1,900 views for the Preferred Options explainer, 1,005 for the Growth Strategy video and 879 for the video explaining the interactive map and response process.

On Facebook, the Council records 33 reactions, 2 comments and 71 shares across 40,989 views. On X, there were 13 likes and 16 retweets across 4,380 impressions. LinkedIn recorded 6 reactions and 1 share across 976 impressions, while Instagram recorded 21 reactions, 3 comments and 17 shares across 1,218 views.

These figures do not establish the number of unique residents reached. However, they raise a legitimate question about whether social media was an effective means of communicating the significance of the proposals to affected communities, particularly where individual allocations involved thousands of homes.

The content of the publicity is also relevant. For example, a Stratford-on-Avon District Council Facebook post dated 22 February 2025 presented the consultation through the question “Is it true that 11,000 houses are planned for Stratford-upon-Avon town?”

The response stated that “nothing is confirmed at this point”, explaining that the locations shown on the Growth Strategy map were potential development sites which would be assessed for suitability and that not all would be required for housing.

While factually accurate, this presentation provided limited information about what was actually being proposed in particular communities, the scale of individual strategic growth locations or the potential consequences for residents living in or around them.

The Council's more traditional publicity methods also raise questions about how it sought to reach residents who were not already engaged with the planning process.

Printed posters were sent to libraries, while electronic copies were sent to Town and Parish Councils with encouragement to print and display them locally or include them in parish publications or social media. Paper consultation documents and postcard-size information leaflets were also made available at designated deposit points, including all 15 South Warwickshire libraries.

However, the Consultation Statement does not identify an equivalent programme of targeted household leaflet or postcard distribution to residents living in or around the proposed strategic growth locations.

This distinction is important. Making consultation material available at libraries, Council offices and online, or placing responsibility on Town and Parish Councils to reproduce and distribute posters, is not necessarily equivalent to actively notifying the communities most directly affected by individual proposals.

3. Was there a realistic opportunity to scrutinise the Regulation 19 evidence?

Regulation 19 is the final formal consultation before submission of the Plan for independent examination. The Publication Plan contains the final growth strategy, final locations for growth and final policies, with representations principally directed towards legal compliance and soundness.

Meaningful scrutiny at this stage therefore requires consultees to understand the evidential basis for the final Plan and, where evidence has changed, to understand what changed, why it changed and what effect those changes have had on the Plan.

The Technical Evidence Register shows a substantial volume of evidence completed or updated in the three months immediately preceding Regulation 19. At least 37 evidence entries are recorded as completed in May 2026, with a further 20 entries completed in June or July 2026.

These include evidence concerning proposed growth locations, capacity, sustainability, transport impacts, infrastructure, heritage, viability and deliverability. The material includes reports, appendices, site-specific assessments, addenda and supplementary documents.

In several cases, the newer evidence builds upon or supersedes earlier material. This includes revisions to the Growth Strategy evidence, the Green Belt Review and the HELAA, together with numerous addenda and supplementary documents.

Meaningful scrutiny may therefore require comparison with earlier consultation and evidence documents dating from November 2024 onwards, rather than consideration of the Regulation 19 evidence in isolation.

The issue is therefore not simply whether seven weeks constitutes a formally adequate consultation period. The question is whether, given the volume of evidence completed or materially updated immediately before Regulation 19, the need to consider that evidence alongside earlier iterations and consultation documents, and the timing of the consultation across the summer holiday period, consultees had a realistic opportunity to understand the evidential changes and formulate fully informed representations.