Issue and Options 2023

Yes

Vision and Strategic Objectives 3. The HBF support the vision of the Plan to meet South Warwickshire sustainable development needs. The recognition that this should include planning for some of the unmet needs of neighbouring authorities is welcomed. The key aim of the plan to provide homes is supported. 4. Supporting the growth of new homes is an important Strategic Objective. Whilst the importance of infrastructure in delivering housing is noted, the infrastructure required to support growth may be funded in a variety of ways, including public funding and grants, not only through developer contributions. Development is only required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision.

Chapter 4 Meeting South Warwickshire’s Sustainable Development Needs Issue I1: Sustainability Appraisal (SA) 5. The HEDNA for Coventry and Warwickshire says it provides evidence about how many jobs should be created by 2050 and how many homes would be needed to house those workers (pg 25). The SA provides an evaluation of the different spatial options for growth, concluding that all options tested would increase the volume of housing. However, in terms of the level of growth the SA has only tested two options for housing numbers (page 128). Option I uses the HEDNA trend-based projections which point to a need for 4,906 dwellings annually across the whole sub-region with 868 dwellings per annum in Stratford-on-Avon and 811 dwellings per annum needed in Warwick. This results in a combined total of 1,679 per annum for South Warwickshire. Option II uses the Standard Method calculation and identifies a higher need of 5,554 dwellings annually across Coventry and Warwickshire, but only 564 dwellings per annum in Stratford-on-Avon and 675 dwellings per annum needed in Warwick. Resulting in a combined total of 1,239 per annum for South Warwickshire. 6. The HBF would suggest the Plan should be more ambitious with its housing numbers and the SA process should include options for a higher level of housing. As set out in the NPPF, the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Government’s standard methodology identifies the minimum annual LHN, which is only a minimum starting point. This is not a housing requirement figure. The Government’s objective of significantly boosting the supply of homes set out in the NPPF remains (para 60). 7. The HBF would also suggest that there is a need to consider the interaction between employment and housing. As the HEDNA itself acknowledges an increase in the number of jobs can it itself generate a requirement for additional housing. High/higher growth scenarios should be tested in the SA. 8. The HBF would request that the Council considers the annual LHN as only the minimum starting point and fully considers all of the issues that may result in a need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing. 9. It may be that a higher housing figure is needed for economic reasons and a higher housing number is also needed for housing delivery reasons. Both options could be tested in the SA separately and in combination. 10. The evidence provided in the supporting document called ‘High Level SA of Growth Options’ notes that the geographical distribution of development may impact on the Plan’s ability to deliver affordable housing where it is most needed. The HBF notes that the level of open-market housing provided may also impact on the amount of affordable housing that can be developed (see comments on Viability). Infrastructure Requirements 11. Development is only required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision. Any policy wording in the Plan about Section 106 agreements will need to ensure decision makers consider the need for infrastructure requirements at the time of making the decision. Planning obligations must be necessary to make the development acceptable in planning terms, directly related to the development; and fairly and reasonably related in scale and kind to the development (PPG, Reference ID: 23b-002-20190901).

Issue I3: Community Infrastructure Levy (CIL) 12. Whatever approach is adopted with regards CIL, as the consultation acknowledges, there is will still be a role for Section 106 agreements to address site specific issues. The Plan will need to set this out. 13. There needs to be robust testing of the appropriate level of CIL and other policy requirements. It should be noted that on-site requirements can also impact on viability of a scheme by reducing the amount of land available for housing development. 14. The HBF notes that CIL can also reduce flexibility in negotiations and if contributions are only for small amounts spending CIL can also become problematic. Issue 14: Infrastructure Safeguarding 15. The HBF would support safeguarding for infrastructure if the purpose of the safeguarding is to improve certainty for developers on what infrastructure is required where and when. However, the safeguarding of land must not serve as a barrier to development and hold up delivery of much needed homes. This issue may need to be considered on a case-by-case basis and/or flexibility may be required. 16. The Infrastructure Delivery Plan will be an important part of the evidence base for the Local Plan and the HBF and its members would welcome the opportunity to comment on and feed into this document. Issue I5: Viability and Deliverability 17. As the PPG (ID: 10-001-20190509) says plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Viability assessments should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan (PPG10-002-20190509). It will be important that policy requirements, and combination(s) of different requirements, are robustly tested through the whole plan-viability testing. 18. As noted in PPG (ID: 10-003-20180724) assessing the viability of plans does not require individual testing of every site or assurance that individual sites are viable. In light of this there will remain a need for flexibility within policy to enable site specific viability considerations to be taken account where required.

Urban Capacity Study 19. The Urban Capacity Study (UCS) considers the issue of windfall, concluding that evidence justifies a windfall allowance of 220 dwellings per annum across South Warwickshire, which it suggests can be applied from 2028-2050. This would equate to an overall total of 4840 dwellings. Of this total, it is estimated that 3360 dwellings would be within the 23 urban settlements of South Warwickshire. The HBF questions the robustness of this approach to windfall. 20. The HBF agrees with the observation (on page 30 of the UCS) that it is simply adopting historic windfall trends as an indicator of likely future rates of windfall is unlikely to be robust. The HBF also agree that a windfall allowance should not be included until the fourth year of a housing trajectory, given the likelihood that dwellings being completed within the next three years will already be known about (as they are likely to need to have already received planning permission to be completed within that timeframe). The Plan’s windfall allowance will need to be kept under review as the Plan progresses to ensure that it is informed by the latest data. 21. As set out in the NPPF (para 69a) at least 10% of the housing requirement should be accommodated on sites no larger than one hectare or demonstrate strong reasons for not achieving this target. The Council should ensure that the Local Plan is consistent with the NPPF. The Plan should allocate sustainably located small sites to help provide certainty for SMEs. This should be in addition to any windfall allowance. The Need for Small Sites 22. The HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have. 23. If the Councils are to ensure there is a wide variety of SME house builders operating in their administrative areas, and the benefits it brings to the speed of delivery and variety of homes, they must ensure that there is a variety of sites. This is why the Government, through the NPPF, now requires local authorities to allocate sites of varying sizes and why the HBF advocates for the allocation of more small sites in local plans. 24. It also will be important for the Plan’s policies and evidence base to set out how the plan will deliver 10% of homes on sites of less than one hectare, as required by paragraph 69 of the NPPF. The HBF would advocate that a higher percentage of small sites are allocated if possible. Such sites are important for encouraging the growth in SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the 1980s, small developers once accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80%.

Section 4.2 Development Distribution Strategy for South Warwickshire 25. The HBF would wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The HBF does not comment on individual sites, other than to say the Plan should provide for a wide range of deliverable and developable sites across the area in order to provide competition and choice and a buffer to ensure that housing needs are met in full. The soundness of strategic and non-strategic site allocations, whether brownfield or greenfield, will be tested in due course at the Local Plan Examination. 26. Whilst the principle behind the 20-minute neighbourhood is a reasonable aspiration to take forward within the Plan this should be seen as an aspiration within appropriate locations rather than a blunt tool for development management or site allocations across South Warwickshire. As noted in the consultation under Issue S4 the application of this principal in more rural areas is inevitably more difficult as populations are generally too low to meet all the features of a 20-minute neighbourhood, but this should not prevent development from happening in such locations to support the need for new homes in those areas in Part 2 Local Plans and/or Neighbourhood Plans. 27. The Spatial Strategy should recognise that there may be clusters of villages that provide a range of services for that area within reasonable travelling distance of each other, so villages may need to be grouped together. These areas might be able to sustainably support a substantial level of development but may not meet the principles of the 20-minute neighbourhood. The plan will also need to recognise that settlements that currently do not have the services that are consistent with the 20-minute neighbourhood could expand to include those services if new development is allocated in those areas. The 20-minute neighbourhood should not be used as a basis for only locating development close to existing services rather identifying where services could be improved through new development. There is a real danger that the principle could be used negatively and become a way of preventing development in certain communities rather than promoting improved neighbourhoods. 28. With regards the potential for new settlements, the HBF notes that new settlements have long lead times. Reliance on one (or more) new settlement(s) for housing delivery will mean delivery from this source will occur later on in the Plan period. This increases the importance of the need for a range of other sites to be provided to ensure a 5 Year Land supply and early delivery of much needed housing. It will be important for policies and allocation in the Plan to provide for a range of housing sites. 29. The HBF agrees that if homes are being provided to meet needs arising in Birmingham and Black Country HMA and the Coventry HMA, then the Plan needs to consider where best such housing should be located. This must include considering the benefits of locating these homes as close as possible to the source of those needs, for example, in order to minimise travel. This consideration therefore necessitates the need for a review of the Green Belt (see also comments on Chapter 5).

Nothing chosen

Chapter 6 Delivering Homes that meet the needs of all our Communities Issue H1: The right number of homes 30. Although the consultation identifies the need to increase the delivery of affordable homes as a key issue for the Plan, as para 11 of the NPPF states plans should promote a sustainable pattern of development that seeks to meet the development needs of their area and as a minimum provide for objectively assessed needs for housing. There is a therefore a need for the Plan to meet the needs of everyone in South Warwickshire. This will include a need to deliver new open market housing, not just affordable housing. 31. The Issues and Options consultation explains that if the Councils use the standard methodology based on 2014 household projections this results in a need for 5554 new houses per annum across the HMA. • 564 per annum in Stratford-on-Avon and • 675 per annum in Warwick In contrast, using a trend-based projection reduces the HMA total to 4,906 per annum but increases the need within south Warwickshire to • 869 per annum in Stratford-on-Avon and • 811 per annum in Warwick 32. As set out in the NPPF (para61) the determination of the minimum number of homes needed should be informed by a LHN assessment using the Government’s standard methodology unless exceptional circumstances justify an alternative approach (para 61). The Authorities would therefore need to justify what exceptional circumstances were in play that warranted departing from the standard method. 33. The HBF would support the higher numbers of housing for Stratford-on-Avon and Warwick of the trend-based approach but suggest the Authorities may wish to further consider the justification for the higher number required. Any departure from standard method of calculating need can be only be supported in exceptional circumstances. However, using the standard method as intended, as a minimum (not maximum) figure, enables the Authorities to arrive at a higher housing requirement. The standard method and the trend-based approach do not need to be seen as being two different (and competing) methods. An approach using the Standard ethod plus an adjustment for trend-base information is possible. 34. The Standard Method plus additional housing for trend-based reasons could then be further supplemented with additional housing required to meet the unmet needs of neighbouring authorities (see comments later on) and/or increased further to reflect the economic ambitions for growth of the area. 35. The HBF agrees that South Warwickshire Plan should include housing to meet the unmet needs of the Birmingham and Black Country, and the Coventry areas (see comments on Issues H4). 36. The South Warwickshire Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver the housing requirement. This sufficiency of Housing Land Supply (HLS) should meet the housing requirement, ensure the maintenance of a 5 Year Housing Land Supply (5YHLS) and achieve Housing Delivery Test (HDT) performance measurements. 37. The HBF notes that work is ongoing to confirm how much housing can be provided from various sources, in terms of both existing and future capacity, to help meet the housing needs. The HBF and its members would welcome the opportunity to comment on this work as it emerges. It will be important to review sites with planning permission and those identified for development in existing Plans to ensure they remain deliverable and viable. The HBF comments on windfall can be found in the Urban Capacity Study section of this response. 38. The Government’s objective of significantly boosting the supply of homes set out in the NPPF (para 60) is important. The soundness of strategic and non-strategic site allocations will be tested in due course at the Local Plan Examination. The HBF would not wish to comment on individual sites proposed for allocation, but it is noted that the Council will need to provide a site by site analysis to check of the deliverability of individual site allocations. 39. HBF responses are submitted without prejudice to any comments made by other parties, but it is critical that the Councils’ assumptions on lapse rates, non-implementation allowances, lead in times and delivery rates contained within its overall HLS, 5YHLS and housing trajectory are correct and realistic. These assumptions should be supported by parties responsible for delivery of housing and sense checked by the Councils. The housing trajectory will be an important part of the evidence base and should provide as much detail as possible.

Affordable Housing 46. The consultation sets out the Authorities view that the rented affordable need (per annum) are as follows: Stratford-on-Avon • Rented Affordable Need 419 • Affordable Home Ownership Need 129 • Total Affordable Need 547 Warwick • Rented Affordable Need 582 • Affordable Home Ownership Need 258 • Total Affordable Need 839 47. The Plan will need to provide certainty for developers on what affordable housing will be sought, whilst still allowing flexibility to respond to any site specific issues. It will be important for the levels of affordable housing sought are robustly tested through the viability assessment. 48. As affordable housing policy usually refers to the amount of affordable housing required being a percentage of all the housing units on a site, one way to increase the delivery of affordable housing would be to increasing the amount of housing, and the number of housing sites.

selected

selected

selected

Housing for Older People 49. The consultation sets out the Authorities view of Older Persons Need to 2032 that the rented affordable need (per annum) are as follows: Stratford-on-Avon • Housing with Care/Support 175 • Bedspace Allowance 29 • Total Need 204 Warwick • Rented Affordable Need 59 • Bedspace Allowance 13 • Total Need 73 50. The HBF is supportive of measures to increase the supply of specialist older people’s housing and supports the view of the Retirement Housing Group (RHG) that the planning system can do more to reflect the aging population. A recent RHG report may provide a useful point of reference for the Council https://retirementhousinggroup.com/how-better-use-of-the-planning-system-can-increase-provision-of-specialist-housing-for-older-people/

Nothing chosen

Issue H4: Accommodating needs arising from outside South Warwickshire 56. The consultation explains that the total amount of housing that the Local Plan will also need to include the provision of an agreed proportion of any need from Greater Birmingham & the Black Country and from Coventry that cannot be accommodated within those areas. 57. As noted previously the HBF agrees that South Warwickshire Plan should include housing to meet the unmet needs of neighbouring authorities. To assist in the understanding of the calculations used, the HBF suggest that unmet needs of each area (Birmingham and Black Country and Coventry) should be considered separately. The quantum of unmet need from each area needs to be clearly set out. Where the unmet need arises from may affect how best that unmet need could be met. 58. The HBF notes the latest position statement on Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (Dec 2021). Although the HBF welcomes this work, it should result in a signed Statement of Common Ground (SoCG) which clearly sets out how the unmet of Birmingham and the Black Country will be redistributed. To ensure delivery of the housing needed the South Warwickshire Authorities will need ensure this engagement remains ongoing. It will be important to understand the level of unmet need that South Warwickshire is required to accommodate in order to properly consider how to meet this element of unmet need within the Plan. 59. Similarly, a signed statement of Common Ground will be needed that clearly sets out the unmet needs of Coventry and how this will be redistributed. As the adopted Coventry Local Plan covers only the period of 2011-2031 additional work will be needed to robustly evidence the level on unmet need in Coventry, and how this will be accommodated across the whole South Warwickshire plan period. It will be important for this information to be kept under review and for the most up to date data to be available for the Local Plan preparation as it progresses. 60. The HBF agrees that meeting unmet housing needs which occur neighbouring HMAs is a cross boundary matter. To fully meet the legal requirements of the Duty to Co-operate the Councils should engage in a constructive, active and on-going basis with their neighbouring authorities to maximise the effectiveness of plan making. One key outcome from co-operation between the neighbouring HMA authorities should be the meeting the full housing requirement for each HMA.

61. The meeting of unmet needs should be set out in a Statement of Common Ground signed by all respective HMA authorities. The HBF would suggest that the SoCG on Unmet Housing Need should confirm that: • Each authority will meet its own LHN and a defined amount of the unmet local housing need (LHN). • This cumulative figure will be the housing requirement figure for each authority respectively; and • The authorities acknowledge that additionality in HLS may be required to ensure deliverability and flexibility

selected

selected

selected

selected

selected

selected

Issue H2: Providing the right tenure and type of homes 40. The HEDNA considers the Coventry and Warwickshire Housing Market Area to be a coherent housing market area and a ‘best fit’ functional housing market area. This important when considering the link between new jobs and new housing the best fit for the HEDNA. The HBF views on the use of the trend-based housing need and requirement figures suggested by the HEDNA are detailed in the comments on the Sustainability Appraisal above. National Described Space Standards (NDSS) 41. If the Councils wish to apply the optional NDSS to all dwellings, then this should only be done in accordance with the NPPF (paragraph 130f & Footnote 49) which states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”. As set out in the NPPF, all policies should be underpinned by relevant and up to date evidence, which should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned. 42. PPG (Ref ID: 56-020-20150327) identifies the type of evidence required to introduce a policy on NDSS. It states that ‘where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions. 43. The Councils will need robust justifiable evidence to introduce the NDSS, based on the criteria set out above. The HBF considers that if the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional. 44. The HBF would also remind the Councils that there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. The policy approach should recognise that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Well-designed dwellings below NDSS can provided a good, functional home. Smaller dwellings play a valuable role in meeting specific needs for both open market and affordable home ownership housing. 45. An inflexible policy approach imposing NDSS on all housing removes the most affordable homes and denies lower income households from being able to afford homeownership. The introduction of the NDSS for all dwellings may mean customers purchasing larger homes in floorspace but with bedrooms less suited to their housing needs with the unintended consequences of potentially increasing overcrowding and reducing the quality of their living environment. The Council should focus on good design and usable space to ensure that dwellings are fit for purpose rather than focusing on NDSS. Issue H3: Providing the right size of homes 51. The consultation includes Table 12 which sets out suggested housing size mix as follows: Stratford-on-Avon Market Ownership • 1 bed 10% • 2 bed 35% • 3bed 40% • 4 bed 15% Warwick Market Ownership • 1 bed 10% • 2 bed 40% • 3bed 40% • 4 bed 10% Stratford-on-Avon Affordable Home Ownership • 1 bed 20% • 2 bed 45% • 3bed 25% • 4 bed 10% Warwick Affordable Home Ownership • 1 bed 20% • 2 bed 45% • 3bed 25% • 4 bed 10% Stratford-on-Avon Social/Affordable Rented • 1 bed 40% • 2 bed 35% • 3bed 20% • 4 bed 5% Warwick Social/Affordable Rented • 1 bed 40% • 2 bed 35% • 3bed 20% • 4 bed 5% 52. The HBF agrees with the HEDNA observations that these percentage figures should be used as a monitoring tool rather than being applied rigidly to all individual development sites. The HBF agrees that consideration should also be given to the existing house mix in the locality, site location and characteristics, local needs and market evidence. Any policy on housing type and mix should include flexibility that would allow for negotiations to consider viability and other site-specific considerations on a case by case basis if required to ensure delivery and/or viability of a particular scheme. 53. The requirements to meet Part M4(2) will be superseded by changes to residential Building Regulations. The Government response to ‘Raising accessibility standards for new homes’ states that the Government proposes to mandate the current M4(2) requirement in Building Regulations as a minimum for all new homes, with M4(1) applying in exceptional circumstances. This will be subject to a further consultation on the technical details and will be implemented in due course through the Building Regulations. The requirement to address this issue is planning policy is therefore unnecessary. 54. There is also a need to differentiate between Part a) and part b) of M4(3) technical standards. M43a sets out standards for wheelchair adaptable housing, where M43b relates to wheelchair accessible housing which can only be required on affordable housing where the Council has nomination rights. 55. The HBF notes the observations about the potential of bungalows. However, bungalows can impact on viability so robust testing of any policies will be needed to ensure housing schemes remain viable and deliverable. Any policy should also include the flexibility to allow for consideration of site any specific issues. Issue H5: Providing custom and self-build house plots 62. The HBF considers that a policy which encourages self and custom-build development and sets out where it will be supported in principle would be appropriate. The HBF considers that the Councils can play a key role in facilitating the provision of land as set in the PPG. This could be done, for example, by using the Councils’ own land for such purposes and/or allocating sites specifically for self and custom-build home builders- although this would need to be done through discussion and negotiation with landowners. The HBF does not consider that requiring major developments to provide for self-builders is appropriate.