Issue and Options 2023
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Q-S5.2 – Do you think the new settlements should be part of the overall strategy? New settlements that require a complete infrastructure package will, in all likelihood, take at least several years from the adopted of the SWLP to start to deliver housing. They must, therefore, be supplemented by other allocations. It is noted most of the new settlements are located on rail corridors and mainly not in the vicinity of existing stations. It would make more sense for development adjacent to existing train stations to be considered first as these are much more likely to deliver sustainable developments within the SMLP plan Period. Such a site is the land in which BDW has an interest at Wilmcote. The site is also of sufficient size to provide a primary school, employment land and significant areas of open space. Q-S8.1 – For the settlements that fall outside the chosen growth strategy, do you think a threshold approach is appropriate to allow more small scale development to come forward? No. There are a number of settlements that fall outside the identified Growth Options, with the exception of disbursed strategy. These should be capable of accommodating development relevant to their needs. This should be based on a case-by-case basis.
Q-H1-1 – The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014 based household projections toward a trends based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? Paragraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance, unless exceptional circumstances justify an alternative approach which reflects current and future demographic trends and market signals. In addition to the local housing needs figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts re 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868dpa are required in Stratford-on-Avon and 811dpa in Warwick District. Therefore moving towards a trends based approach would seem appropriate. In terms of the approach for the HEDNA, it is noted that Table 8.13 – Estimated Need for Social/Affordable Rented Housing by Local Authority, identifies a net annual need for 419 affordable dwellings in Stratford-on-Avon and 582 affordable dwellings in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. The PPG advises, at paragraph 2a-024, that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments. However, it is not realistic to generally expect housing allocations to deliver 67% or 52% affordable housing. There is, therefore, the possibility that there will be a shortfall of affordable housing provision during the course of the plan period. One way to overcome this would be to increase the total housing figures included in the SWLP. Consideration should, therefore, be given to uplift the housing requirement to ensure that an appropriate amount of affordable housing can be provided.
The most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above.
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The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. No reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.
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