Issue and Options 2023
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New search2.1 No. 2.2 It is noted that under the heading ‘Meeting South Warwickshire’s Sustainable Development Needs’ there is an objective relating to ‘delivering homes that meet the needs of all our communities’. However, this objective only relates to addressing local housing need but does not include any reference to addressing development needs from neighbouring areas. This is despite the accepted position that South Warwickshire straddles two market areas; Greater Birmingham and the Black Country, and Coventry & Warwickshire. Both of these market areas have a history of unmet need which, in Birmingham’s case, has never been fully addressed and which is now worse (c. 78,000 dwellings) compared to the shortfall in the adopted Birmingham Development Plan (37,500). This is in addition to the unmet need arising from the Black Country, which currently stands at 28,239 dwellings up to 20391. 2.3 On this basis, RPS recommends that the objectives of the SWLP should be updated to reflect the emerging position regarding future (unmet) need across the wider market areas within which South Warwickshire is located and which make a clear commitment to assisting in addressing those needs. 2.4 In addition, the SWLP draft vision runs up to 2050. However, the base year date is not defined in the IO document. Paragraph 22 of the NPPF makes clear that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years) to take into account the likely timescale for delivery. In this case, the SWLP includes options for new settlements and significant extensions to existing urban areas, which fall into the paragraph 22 development categories. Assuming adoption of the SWLP is likely during 2025 at the earliest, 30 years from adoption would extend the plan period to 2055. Accordingly, RPS recommend that in line with the NPPF, the SWLP should look ahead to 2055 at the earliest). 1 Draft Black Country Plan 2020-2039, July 2021, Table 2
Issue I2: Infrastructure Requirements and delivery 3.1 In response to this question, RPS would point out that the over-arching approach in the SWLP is to take a two-part approach; Part 1 dealing with strategic policies and proposals; and part 2 addressing non-strategic policies and site allocations. 3.2 RPS is broadly supportive of a two-part approach, which decant non-strategic site to the part 2 stage. The site at Goose Lane would fall into this later stage. On this basis, any infrastructure requirements relating to this site were it to be allocated in the SWLP should be addressed at the part 2 stage. RPS supports option I2b. Issue I5: Viability and Deliverability Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.3 RPS would recommend that when considering individual site preferences, the Council should support sites that can be brought forward relatively quickly, and in locations which are already served by existing infrastructure, including the Goose Lane, Lower Quinton site. This reflects circumstances for example where sites that rely on funding for strategic infrastructure projects could be substantially delayed (i.e. South Western Relief Road and delivery of Long Marston Airfield).
Issue S2: Intensification Q-S2: Please select all options which are appropriate for South Warwickshire 3.4 Under this issue, the IO document does not pose any specific questions, but instead identifies three options for developing a policy to support the intensification of existing areas. 3.5 National policy provides advice on achieving appropriate densities as part of the overall objective to make efficient use of land 2 or for optimising the density of development in city and town centres and other locations that are well served by public transport 3. This includes taking into account the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change4, as well maintaining the viability of development5. It is also advised that it may be appropriate to set out a range of densities that reflect the accessibility and potential of different areas, rather than one broad density range 6. 3.6 In this context, it is clearly the case that some localities more central to existing built-up areas may be more predisposed to accommodate more intensive development than other locations. Nonetheless, delivering development at increasingly higher densities will inevitably lead to potential impacts on the prevailing character and setting of existing settlements. Therefore, whilst increasing densities could increase the supply of housing, this should not be seen as the only option. In this context, there is clearly a role for development that is brought forward on the edge of existing settlements that can be designed in order to integrate with existing areas but also help to create distinctive places in their own right. 3.7 Consequently, RPS recommends a design-led approach to establishing strategies on density. Density is a function of good design and there is no reason to take an alternative approach when devising local policy through the SWLP. On this basis, any policy approach should be informed by an assessment of the character of different areas because character is not uniform across the plan area. This is in preference to any blanket or an ‘in-principle’ approach. Similarly, there should not be any overarching priority to intensify or densify existing urban areas because other evidence, principally the Urban Capacity Study, shows that the development needs of the SW area will not be met through urban-focused / brownfield growth alone. This is discussed in the response to Issue S3 below. 3.8 RPS therefore would favour Option S2a, which would direct any policy response to localities where intensification is considered to be appropriate, but which recognises that density should be design-led informed by the local context. 2 NPPF2021, paragraph 124 3 Paragraph 108 4 Paragraph 124d 5 Paragraph 124b 6 Paragraph 125b
Issue S3: Using Brownfield Land for development Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study 3.9 An Urban Capacity Study for South Warwickshire dated October 2022 has recently been undertaken to inform the SWLP. Its purpose is to identify the potential for residential development on brownfield land within existing settlements across South Warwickshire. As pointed out in section 1.1 of the study report, a review of housing capacity has been undertaken in order to minimise the amount of development required outside existing urban areas. 3.10 The IO document goes on to state that the study has been undertaken as a theoretical exercise and is not intended to conclusively establish the urban capacity of South Warwickshire over the period to 2050, but rather to indicate potential untapped urban capacity within these identified settlements, subject to the application of policy and the conclusions of more detailed subsequent evidence work. That said, there are some important conclusions in the study that need to be emphasised at this stage as the study will form part of the evidence to underpin the development strategy in the SWLP. 3.11 The study has applied a number of important assumptions, as listed here: • The base date for the study and the conclusions around potential urban housing capacity is 1 April 2021 • The study assumes that all of the sites considered will be developed as ‘conventional’ dwellinghouses in Use Class C3 (not specialist housing i.e. student accommodation or older persons housing). • Capacity was measured on sites located in 23 settlements across the SW area, including Main Rural Centres defined in the Stratford-upon-Avon Core Strategy, and Growth Villages as defined in the Warwick Local Plan. This includes sites located in Southam. • The Urban Capacity Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice. 3.12 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 3.13 The study therefore identifies a significant shortfall in the potential for new housing to be accommodated on previously-developed land. The shortfall is currently 10,800 dwellings. This should be taken as a minimum shortfall, as not all sites with potential will actually be deliverable or developable once a full assessment has been carried out. 3.14 Based on these findings, the study concludes that: “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” 3.15 Furthermore, the shortfall is set against the standard method housing need figures (1,230 dpa across the whole area over 25 years). However, the IO document advocates for the use of an alternative ‘trend-based need for South Warwickshire, which gives a need for 1,679 dpa. Against this figure, the total need between 2025-2050 increases to 41,975 dwellings, thus increasing the shortfall to 22,025 dwellings. This clearly demonstrates that the focusing policy objectives on previously-developed land will not deliver anywhere close to the projected needs of the SW area, and therefore planning for development on greenfield land in sustainable locations must form part of development strategy for the SWLP. 3.16 The existing 2016 Stratford-upon-Avon Core Strategy identifies Lower Quinton as a Local Service Village under Policy CS15, which is also mirrored on the corresponding Key Diagram. This reflects the Council’s view of the settlement as a location for growth and development, and there is no logical reason why the settlement would be excluded from the nascent stages of plan making for the South Warwickshire Plan, as a spatial strategy has yet to be defined. RPS is unclear why Lower Quinton has been excluded both from the Plan and the supporting evidence base such as the Urban Capacity Study, a perverse position taken. 3.17 In terms of the evidence and the IO document, three options under this issue are presented. On the basis of the current evidence provided on housing capacity, RPS would recommend that development on previously-developed land is supported only where sites are shown to be viable and deliverable, as well as being sustainably located. Nonetheless, given the paucity of the overall supply from sites within urban areas, it is not considered reasonable to prioritise brownfield development ahead of other, greenfield locations as a matter of principle as this would put at grave risk the ability of the SWLP to meet the identified needs of the area up to 2050. Nonetheless, RPS would direct the Council to its response to Q-V3.1 above regarding the extension of the plan period. 3.18 On this basis, RPS supports Option S3.2c. In addition, given the fact the IO document and Urban Capacity Study has not reflected properly on the true scale of housing needed to be planned for across South Warwickshire or the current settlement hierarchy, Lower Quinton should be incorporated into a revised urban capacity study, and conclusions drawn on the ability of the settlement to accommodate additional growth within its built-up area.
3.27 Alongside the IO document, a ‘Settlement Analysis’ evidence base report (referred to here as ‘the report’) has been prepared to help identify opportunities and constraints to growth in and around the edges of a number of settlements and locations across South Warwickshire. The analysis in the report focuses on three factors; Connectivity, Accessibility, and Density. A primary purpose of the report, as stated at paragraph 2.1 of the report, is to aid understanding of the potential to achieve the ’20-minute neighbourhood’ concept in those settlements identified, and is designed to support the development of the spatial strategy for South Warwickshire. Page 44 of the IO document also points to ‘other factors’ outside the scope of this analysis relating to the potential for growth. However, the report does not identify those here or explain how these will be taken into account in determining where growth will be directed. RPS seeks further clarification on this as the SWLP moves forward. 3.28 The settlements included in the analysis are listed in Table 2 of the IO document. These, the IO document claims, have been selected based on their status in the existing Local Plans and those that fall within certain growth options. Section 3 of the report provides some commentary on the reasoning behind the selection process. 3.29 RPS would highlight the methodology used to select the sites within the Settlement Analysis has not been provided comprehensively. Where methodology has been provided, it has been unclear as to how to follow. In particular, RPS note in particular that the Lower Quinton along with other sustainable locations such as Local Service Villages have been omitted from the study. Whilst a number of these settlements conform to spatial options identified in the IO Plan, an assessment of character and capacity has not been undertaken, a notable flaw of the evidence base. 3.30 The current omission indicates that the Councils are not concerned with the growth of settlements beyond those tier 1 and tier 2 settlements. Whilst these higher order settlements are the most service rich, there remains a need to continue to allow all sustainable locations in the plan area to grow, and as currently drafted, the evidence base provides little certainty that these areas have been properly considered. 3.31 RPS expects that the Settlement Analysis should be updated through the development of the South Warwickshire Plan, to include a fuller list of settlements that can accommodate growth as part of the plan, making allocations where consistent with the spatial option progressed. 3.32 Consequently, the SWLP should extend its search to include other settlements which are currently acknowledged as being sustainable locations, notably Lower Quinton, that can create 20-minute neighbourhoods. On this basis, Lower Quinton should be incorporated into a revised version of the Settlement Analysis document.
Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.19 Yes. 3.20 There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire 3.21 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 3.22 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). However, in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements (see Issue S5).” 3.23 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites can deliver a steady quantum of development over a period of time in order to help maintain delivery against identified housing targets. This can be achieved at lower Quinton, including on Goose Lane, Lower Quinton site. 3.24 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives. 3.25 RPS also highlights that the growth that is required cannot be met solely within existing settlements identified in the IO document, as evidenced in the Urban Capacity Study. In this context, any 20-min neighbourhood policy should be worded with sufficient flexibility to consider the potential that sites can bring to create 20-min neighbourhoods, rather than only considering the existing situation as a constraint on the distribution of growth. 3.26 Consequently, the SWLP should extend its search to include other settlements which are currently acknowledged as being sustainable locations, notably Lower Quinton, that can create 20-minute neighbourhoods. On this basis, Lower Quinton should be incorporated into a revised version of the Settlement Analysis document.
Issue S5: The potential for new settlement(s) 3.33 The IO document now identifies a number of potential locations for new settlements across South Warwickshire. These have been derived from a two-part process; part 1 seeks to identify ‘areas of search’ based on existing or potential access to rail services outside existing urban areas. Based on the approach, seven areas (A-G) have been identified, illustrated on Figure 12 of the document. These comprise broad areas that do not specific sites or specific locations; part 2 applies a ‘very high-level assessment’ of the areas of search, from which seven potential new settlement locations have been identified. A summary of the assessment of each location is shown in Table 6 of the IO document. Each of these seven locations has also been subjected to Sustainability Appraisal (to RPS responses under Issue I1) and Climate Change Emissions Estimation modelling. 3.34 Whilst some assessment work has been undertaken to date, the IO document acknowledges that further detailed work is required before any preferences for any particular new settlement location can be made, or whether a new settlement is suitable, viable and deliverable in principle. RPS broadly agrees with this point. Q-S5.1: Please provide any comments you have on the emissions estimation modelling for the seven potential new settlement options 3.35 As part of the evidence to inform the Local Plan, an operational carbon model has been developed to assess carbon emissions at a strategic level and test how the development of the seven potential new settlement locations. RPS notes the model is based on current Government and existing Local Plan policies. Further information on the modelling work is set out in Estimation of emissions for proposed growth options and new settlements study dated November 2022. RPS has reviewed this study and wishes to raise a number of points on the approach. 3.36 Firstly, paragraph 1.1 of the study states that the options tested in the modelling all assume 35,000 dwellings will be delivered between 2025 to 2050. This differs from the level of growth assumed under the ‘trend-based’ projected need for South Warwickshire, which RPS calculates at 41,975 dwellings over this period (applying the 1,679 dpa taken from Table 9 of the IO document). It should, also be noted that if the plan period extended to 2055, this would further increase the scale of housing need across the Plan area. However, the study does not include any testing against the preferred housing need scenario, or the potentially higher growth based on a longer plan period. Whilst the projected emissions are likely to be sensitive to higher levels of growth, it is nevertheless important that there is consistency across the analysis to ensure the policy choices are properly informed. 3.37 And secondly, chapter 5 of the study provides some commentary on the methodology underpinning the modelling of the options. Sub-section 5.3.2 lists a number of ‘key inputs’ for the site related modelling. This includes specific reference to ‘Energy efficiency benchmarks such as Part L 2013, Interim Future Homes Standard 2021’ (RPS emphasis). However, as outlined by the Government7, from 2025 new homes built to the Future Homes Standard will have carbon dioxide emissions at least 75% lower than those built to current Building Regulations standards, and all homes will be ‘zero carbon ready’, becoming zero carbon homes over time as the electricity grid decarbonises, without the need for further costly retrofitting work. Whilst the study refers to current building regulations standards under interim changes to Part L introduced in 2021, the study will need to reflect on the further tightening of the regulations and the move to the full Future Homes and Future Buildings Standards that are expected in 2025. 3.38 The introduction of the 2025 Future Homes Standards is expected to improve energy efficiency, reducing the demand for energy and so reduce carbon emissions in residential buildings. RPS recommends that the study is updated to reflect projected reduction of emission by 75% compared to current (2012) regulations. 3.39 For these reasons, RPS recommends that the Climate Change Emissions study should be updated to properly reflect the growth aspirations for South Warwickshire as well as reflect the broad direction of travel on tackling carbon emissions regarding future changes to building regulations and the impending implementation of the Future Homes and Buildings standards. 7 The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings Summary of responses received and Government response, January 2021
