Issue and Options 2023

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2.1 Issue H1 of the Consultation Document sets out the SWLP approach to addressing housing needs across the plan area. It recognises in the first paragraph that England is experiencing a housing crisis and that planning and Local Plans are an important tool for addressing the crisis. This recognition is welcomed. 2.2 The Consultation Document goes on to set out that local housing need for South Warwickshire has been assessed in a Housing and Economic Development Needs Assessment (HEDNA). 2.3 The HEDNA has been prepared on behalf of all the Warwickshire districts plus Coventry and therefore presents a comprehensive approach to the calculation of need for the wider area. The NPPF 2021 is clear that local plans should assess local housing needs using the standard methodology for assessing local housing needs as a starting point, and should only deviate from using the standard methodology in ‘exceptional circumstances’. Furthermore, the NPPF 2021 sets out that any alternative method of calculating housing need must reflect current and future demographic trends (including migration) and market signals. 2.4 The HEDNA sets out that across Coventry and Warwickshire there have been historic problems with establishing population change in Coventry since 2001, and that these issues have been acknowledged by the ONS and the Statistics Regulator. The problems have led to significant over-estimates of population growth in Coventry which have in turn led to projections of population and housing growth which have been in excess of what has actually been needed. The latest results of the 2021 Census issued in June 2022 have again confirmed the existence of these issues. 2.5 The problems represent an exceptional circumstance that justifies moving away from the Standard Methodology. The HEDNA therefore proposes using alternative projections of household growth instead of the 2014 based Household Projections required by the Standard Methodology. These revised projections lead to a reduced local housing need for Coventry and Warwickshire of 4,906 new homes a year – down from 5,554 homes a year calculated using the Standard Methodology. The local housing need based on the new demographic projections is therefore 88% of the figure suggested using the Standard Methodology. 2.6 This headline figure masks changes within the constituent districts. With regard to Stratford-on-Avon and Warwick Districts, the new approach set out in the HEDNA results in significant increases in housing need – from 564 dpa to 868 dpa in Stratford-on-Avon, and from 675 dpa to 811 dpa in Warwick. In terms of the SWLP, the change from the Standard Methodology leads to an increase in housing need of 440 homes to be delivered each year. 2.7 We consider that this analysis set out in the HEDNA does represent a reasonable basis for identifying local housing need for South Warwickshire. It is helpful that the HEDNA undertakes the analysis across Warwickshire, and therefore picks up on demographic relationships that stretch across local government boundaries. This aspect of the analysis means that the assessment of need has greater legitimacy. It is also noted that the pattern of housing need falling dramatically in Coventry and rising in more rural areas matches national trends which have been seen strongly since the pandemic, but which existed prior to then and which reflect wider demographic changes. 2.8 Additionally, the Stratford-on-Avon Core Strategy sets out in Policy CS.16 a housing requirement of 14,600 new homes to be provided between 2011 and 2031 – an annual requirement of 730 dwellings a year. Clearly, this requirement is already significantly higher than the housing need suggested by the standard methodology. Stratford-on-Avon also reports a 5 year housing land supply position of 10.2 years’ supply of deliverable land for housing, and a housing delivery test result showing it has delivered 240% of its requirement (therefore over twice the level of new homes expected measured against the standard methodology). It seems very likely that Stratford-on-Avon district alone is more than capable of delivering new homes at the level suggested by the alternative method set out in the HEDNA, if not somewhat higher. 2.9 We therefore support the approach being suggested in the Consultation Document, but make the following points: a. In many respects, the assessment of housing need clarifies a position that has been apparent in policy – which is that Coventry is unable to meet its needs in full within its boundaries, and therefore neighbouring authorities within its HMA are asked to meet its unmet need and to agree a position through the Duty to Cooperate. The new assessment, by reducing Coventry’s need but increasing needs in some rural districts, simply makes the position clear in a demographic analysis. If a decision were made to revert to the Standard Methodology calculation, that decision would clearly need to made across Warwickshire and would have to include Coventry. The higher levels of need in Coventry would again lead to a significant level of unmet need, some of which would need to be accommodated in the SWLP area. It would therefore be likely that similar levels of need would be established in any case. Using the alternative local housing need methodology makes the situation clearer and easier to plan for and should be commended. b. It is noted, however that the establishment of a housing need figure for the SWLP is simply the first step in establishing a housing requirement to be met by the local plan. The Consultation Document does not set out a housing requirement for South Warwickshire, simply stating that the levels of need do not include an assessment of whether those levels of need can be met by a local authority. This assessment will be an important step to be taken and the results set out in the next iteration of the SWLP, but we would note that if the Councils were to set out a position suggesting that they were unable to meet the need now clearly set out in the HEDNA, it would be necessary to set out why that need could not be accommodated (including looking at all potential strategies for distributing need across the plan area and all potential sites for meeting that need) and also to show where any unmet need would then be met. We would suggest that the level of need is capable of being met within the SWLP area and that there are suitable sites available and deliverable to contribute to meeting that need, such as the land at Rogers Lane, Ettington.

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2.10 The SWLP area sits alongside other HMAs, most notably the Birmingham and Black Country HMA. As is set out under Issue H4 Birmingham has commenced work on a new Local Plan and the housing needs work has suggested a shortfall of 78,415 homes. In addition, it is noted that the Black Country authorities recently announced that they were abandoning the joint working that had taken place on the Black Country Core Strategy and would now pursue individual local plans. It seems likely that this work will also reveal a shortfall in housing land to meet needs of those authorities. As set out above, it would seem likely that the scale of need now to be met in Coventry would lead to much reduced levels of unmet need, if at all. 2.11 The Consultation Document makes clear that the SWLP is likely to be able to make provision for some of the unmet need from Birmingham and the Black Country. Given the lack of constraints in parts of the plan area this approach is supported. Clearly the level of unmet need arising in Birmingham and the Black Country is yet to be crystallised through their respective plan making processes, and the amount of unmet need that the SWLP may be asked to accommodate cannot be known. The approach taken of testing 5000 – 10000 new homes to be accommodated by 2050 therefore seems to be a reasonable approach to understanding the implications of accommodating unmet need. 2.12 We would, however, note that it is not possible to say at the current time whether this level of unmet need bears any resemblance to what may be required. Given that the SWLP plan period seems to be 2021 – 2050 – a timespan of 29 years – the level of unmet need being tested amounts to 172 dpa – 344 dpa. These are significant increases but without an agreement with the Birmingham and the Black Country authorities, and the other LPAs in the HMA it is not possible to know whether this level is sufficient over time. Therefore, we will reserve a position on whether this is an appropriate response until later plan making stages.

2.13 In response to Q-H4-3, we would simply say that whatever spatial strategy is chosen to distribute housing across the SWLP area, should be capable of accommodating housing needs in a sustainable manner which ensures that the needs of communities across the plan area are met. If the spatial strategy cannot accommodate the plan requirement, including any element of unmet need, the spatial strategy will need to be re-thought to ensure that the requirement can be met in full. In order to make this judgement, it will be necessary for the SWLP Parts 1 and 2 to bring forward sustainable sites for housing development that can contribute to the sustainability and vitality of communities, and we would suggest that the land at Roger’s Lane, Ettington is one such site.

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Q-S2: Please select all options which are appropriate for South Warwickshire Option S2a: Identify areas considered particularly suited to intensification development, and develop a design code for each character area. Have a policy supporting intensification within these identified areas where it complies with the relevant design code. The Consultation Document makes the case for encouraging intensification of development in South Warwickshire. Intensification is taken to equate to building at higher densities, but also to include factors such as re-using brownfield sites, converting upper floors or building additional storeys to existing buildings, and infill development on existing street frontages. These principles are worthwhile and will contribute to maximising the number of new homes in suitable locations. However, not all locations will be suitable for higher densities or for the other elements of intensification described in the Consultation Document. Much of the plan area is rural and characterised by villages and smaller towns characterised by lower density built form and although there may be opportunities in such locations for intensification, it is likely that design guides and design codes will require a form of development more complementary to the existing. Additionally, higher density developments of the kinds described will create new homes in more urban areas – but these are not likely to meet the needs of all groups in society across South Warwickshire, and will be mostly located in existing larger towns therefore not meeting the needs of residents of rural areas. A blanket approach to intensification across South Warwickshire would be likely to lead to an unbalanced spatial strategy not able to meet identified needs of all groups in society. However, an approach which identifies where intensification could take place as part of a balanced spatial strategy, with a carefully constructed design code to guide the form of development could be very successful, and this option is therefore supported. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: The Consultation Document sets out Spatial Growth options. These set out high level broad approaches to accommodating growth across South Warwickshire which are also subject to analysis in the Sustainability Appraisal. Each of these options, alongside the issue set out at Issue S5 which examines the potential for new settlements, seem appropriate options for approaches the SWLP could adopt to develop a strategic approach to accommodating growth. Using any of the approaches as a strategic principle for accommodating significant levels of new housing to meet needs would seem to have merit – the determining factors would clearly come down to whether sufficient sites could be found under each option to accommodate the identified levels of housing need – as set out above. It is unfortunate that the Consultation Document seems to offer these options as ‘either/or’ choices, with the Q-S7.2 question asking whether each option is an appropriate strategy. We would suggest that each option is an appropriate strategy, but that it seems unlikely that any one option in isolation will be able to accommodate all housing needs and also represent a sustainable spatial strategy that will achieve the strategic objectives set out earlier in the Consultation Document. A spatial strategy which combines several of the approaches set out in Options 1 – 5 would seem to be the most appropriate solution to take forwards. For example, it would seem sensible that an approach based on new settlements, could also then look to accommodate strategic growth at locations well served by sustainable transport options and close to existing and future employment opportunities. Such an approach could also include an element of a dispersed strategy, picking up on the opportunities outlined earlier to create networks of rural villages which could provide services for the more dispersed population of South Warwickshire and provide limited opportunities for growth in appropriate villages. In particular, Option 5 looking at dispersed development should not be dismissed. As a stand-alone strategy, it would seem right that such an approach would not be able to accommodate the levels of growth required without significant sustainability issues as set out in the accompanying Sustainability Appraisal. However, as part of a spatial strategy which sought to accommodate strategic levels of growth in new settlements and at existing, well connected larger settlements, and which also directed an element of growth at rural villages with a level of services which enabled them to form sustainable rural networks – an element of dispersal could work effectively to support rural communities. Such an approach would simply build upon and evolve the principle set out in the Stratford-on-Avon Core Strategy of directing a certain amount of hew housing to Category 3 settlements such as Ettington – to enable them to grow sustainably and continue to provide facilities to the surrounding rural population. Issue S9: Settlement Boundaries and infill development The Consultation Document sets out that both the Stratford-on-Avon Core Strategy and the Warwick Local Plan set out settlement boundaries for some or all of the settlements in their area, and that they establish where new non-strategic small-scale development may be appropriate within the confines of existing settlements. Two options are proposed, offering two different approaches to setting settlement boundaries in the SWLP. It is unfortunate that there is not an option for removing settlement boundaries altogether and using a more nuanced and sensitive approach to assessing the appropriate-ness of development within and adjoining settlements in South Warwickshire. Settlement boundaries are inevitably drawn tight to the built form of settlements and are set out as an absolute limit to development, with any proposals beyond the boundary assessed as being in open countryside, even if the site is contiguous with the settlement, close to existing facilities and represents clear rounding off. In these circumstances, perfectly sustainable proposals for development may be assessed as inappropriate simply by virtue of being on the wrong side of an arbitrary line. In the most unfortunate examples, a settlement’s opportunity for modest growth which would sustain services and enable local people to find homes in their community can be thwarted by a settlement boundary. We would suggest that settlement boundaries are not carried forward into the SWLP. Other policy approaches are used in other parts of England which enable judgements to be made on a case-bycase basis, with reference to the status of a settlement in the settlement hierarchy – which we note is already in existence for Stratford-on-Avon as set out in the Core Strategy Policy CS.15. An example of an approach which would be very successful in South Warwickshire can in fact be found in the Local Plan of the neighbouring West Oxfordshire District Council, which applies an infill and rounding off policy to its settlement hierarchy without reliance on settlement boundaries. This approach has allowed for a nuanced approach to village development in very sensitive landscape settings, which has led to highly successful developments in appropriate locations for many years and has been continued in successive local plans.

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The Consultation Document at the start of this section notes that “South Warwickshire has a dispersed settlement pattern and is home to a significant number of existing settlements of varying sizes.” The Consultation Document goes on to note that as well as the 9 identified main towns, South Warwickshire has 82 villages and hundreds of hamlets. It is stated that the SWLP will seek to maximise the capacity of existing urban areas to meet development needs to 2050, and this aim is entirely in compliance with the NPPF and is supported. However, given the dispersed settlement pattern of the area it must also be true that a significant number of residents of South Warwickshire live and work in these rural settlements, and therefore the spatial strategy must also have recognition of the needs of these places to see some development to sustain these communities into the future. The Consultation Document goes on to discuss the concept of 20-minute neighbourhoods as a tool for the creation of sustainable communities, but notes that: “In rural areas, the implementation of the 20-minute neighbourhood poses a different set of challenges, including poor broadband and mobile phone coverage, inferior public transport provision and road transport, and a poor variety of employment opportunities. Housing affordability and isolation from and access to services are other issues facing many rural areas.” The solutions suggested are either that market towns become 20-minute neighbourhoods to which residents of smaller villages must travel to access services, or the creation of rural networks of villages which develop services that people need accessible by local public transport. With greater numbers of people working from home and looking to live in more rural areas, it is suggested that the option of concentrating services only in the larger market towns will simply lead to more trips to these locations, predominantly by car, to access day to day services, and the associated depletion of services in smaller settlements without a critical mass of people using them to sustain viability. We would argue that there is an opportunity to develop networks of rural settlements, sustained by accessibility to homes, jobs and services, with the larger market towns accessed when residents need to access higher level services that are more efficiently provided in the larger towns. Such an approach could complement the maximisation of the use of existing urban areas to accommodate strategic growth, but would enable rural settlements to accommodate modest growth and sustainable patterns of development. To take Ettington as an example, the Stratford-on-Avon Core Strategy identifies Ettington as a Category 3 Local Service Village. It is identified as such based on its size and the range of facilities available including a Spar shop, Primary School, pub, employment opportunities including the Ettington Hall Hotel and bus routes leading to Stratford and Banbury. The Core Strategy identified that Category 3 settlements should be able to accommodate 450 dwellings towards the total plan requirement. We consider that the SWLP could take a similar approach to the role that settlements such as Ettington could play, forming part of a network of rural service centres joined by public transport and improvements to other modes of travel including cycling and walking. These settlements could therefore be locations for modest growth complementing their role as rural service centres and carrying forwards the strategy set out in the Stratford-on-Avon Core Strategy.

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Q-T1: Please select all options which are appropriate for South Warwickshire: Response: The Consultation Document sets out the principles of ’20-minute neighbourhoods’ – ie the concept that opportunities for people to meet their day to day needs within a 20 minute journey from home (10 minutes there and 10 minutes back) using walking and cycling as a realistic alternative to the private car. Issue T1 looks at how the SWLP could use this concept in policy to create sustainable patterns of development. As discussed above, the concept has merit when looking at the creation of sustainable neighbourhoods and sustainable rural networks of villages and smaller settlements. It is a useful aspiration and guide that can inform the design of new communities and new neighbourhoods and the use of 20-minute neighbourhoods to guide development design is supported. However, we would have reservations about a policy approach which required the principles of 20-minute neighbourhoods to be delivered in all development proposals. We would therefore support option T1b, which referenced the principles in a broader policy setting out picking up the sustainable characteristics of new development. Clearly, we would reserve a position to be able to comment on the detail of such a policy in a draft SWLP.

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Q-B3: Please select the option which is most appropriate for South Warwickshire The Consultation Document sets out the approach taken in the Stratford-on-Avon Core Strategy to Special Landscape Areas. These are local landscape designations which are based on a 2012 evidence base which is now out of date, and which were intended to put in place a layer of protection for high quality landscapes that also contained historic or cultural features. As noted in the Consultation Document, local landscape designations are not supported by national policy. Nevertheless, some local authorities still use them. Many other local authorities, however, use a more nuanced policy approach which enables a judgement to be made on individual proposals based upon landscape character assessments and Landscape Value Impact Assessments (LVIA). This is the approach taken in the Warwick Local Plan, and is an approach we have seen used very effectively across England. Policy CS.12 of the Stratford-on-Avon Core Strategy simply sets out where the SLAs are designated and gives broad guidance on how to assess development in these areas. It does not set out the detail of the considerations that are to be applied, and therefore a planning application in the SLAs would still need to produce a LVIA with no policy guidance about what particular unique factors should be assessed. We would therefore suggest that the SLA policy is not carried forward into the SWLP, and instead a stronger policy framework for assessing landscape considerations across the plan area is introduced. In this way, it would be easier to draw out the factors most applicable to any given landscape, and the approach would be strengthened for the whole plan area, as landscape considerations would apply to any location, with or without a formal designation.

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Strategic Housing Land Availability Assessments Our client’s site, Land south of Rogers Lane (middle) (ref. ETT.11) has been assessed through several iterations of Stratford-on-Avon’s Strategic Housing Land Availability Assessment. The most recent iteration of the SHLAA is dated September 2011. This SHLAA gives a red, amber, and green rating for each site against a number of indicators. In terms of the final assessment of our client’s site, the SHLAA states: “Need to restrict development to northern part of site with extensive landscaping to effectively mitigate impact on setting of village. A detailed heritage assessment will be used to decide whether impact on heritage assets is too substantial to be mitigated effectively.” The site is given an amber rating for deliverability, meaning it is ‘likely to be deliverable’. Two other sites in Ettington are rated as amber, with the remaining 14 sites shown as red – i.e., not deliverable. The SHLAA is therefore highlighting that the only constraint which could mitigate against development of our client’s land is impact on heritage assets. This point is discussed in more detail below. Land at Rogers Lane, Ettington: Ettington is classified in the Stratford-on-Avon Core Strategy as a Category 3 “Local Service Village”. Out of the 10 Category 3 Local Service Villages, Ettington is one of the top settlements providing access to a Primary School, pub, general store, and employment opportunities. It has the largest population and the second largest number of existing dwellings (taken from the 2011 Census) when compared against the other Category 3 settlements. In addition, Ettington is a 10-minute bus journey from Stratford-on-Avon which provides access to a wider range of services, facilities and economic potential/ employment opportunities, and provides the opportunity for ’20-minute neighbourhood’ principles to be developed. Category 2 Settlements are still considered to be Local Service Villages, but they are larger. The average population size for a Category 2 settlement is 939 residents and 434 dwellings. Ettington is home to 1,039 residents and 424 dwellings (all figures based on Census 2011 data). Ettington is therefore of a similar scale when compared to the current Category 2 settlements which are identified to accommodate higher growth levels set in the Stratford-on-Avon Core Strategy.