Issue and Options 2023
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New searchIssue I5 Green and Blue Corridors Q-S1 – Option S1a We consider that the SWLP should identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced. However, this should be based upon proportionate evidence, which must be up to date. The SWLP refers to the Warwickshire Coventry and Solihull Sub regional green infrastructure study being used to inform policies, however this study dates back to 2013, and is therefore some 10 years old. This should be updated if it is to be used for the purposes of policy making, and included in the forthcoming suite of additional evidence base documents which can be commented upon as part of the plan making process in Stratford and Warwick. Issue S2: Intensification Please select all options appropriate Option S2c – Do not have a policy which encourages intensification. Each site should be considered on its own merits to take account of site-specific constraints and opportunities. A blanket approach to a policy with an ‘in principle ‘support for intensification or even the identification of sites which are considered to be particularly suitable could be counterproductive. Whilst it is acknowledged that the current Framework promotes the effective use of land in meeting the needs for homes, this should not be at the expense of healthy living spaces, or, as advised in footnote 47, “except where this would conflict with other policies in the Framework.” Any proposed intensification, per se could run contrary to the achievement of “well-designed or beautiful places” advocated by the Framework, which places great emphasis on “the creation of high quality, beautiful and sustainable buildings and places”. Furthermore, we are concerned that higher anticipated yields from such sites resulting from an intensification policy approach could result in the allocation of fewer sustainable green field sites – which could ultimately result in failure of the plan to deliver its requirement over the plan period because of the reliance on the yield from the intensification of the site, which may, in due course not be supported due to adverse impact on living conditions for future occupiers or character/appearance reasons and so on. Issue S3 Using Brownfield Land for development Q-S3.1-Option S3.2c We do not consider that a policy should be included in the SWLP to prioritise the use of brownfield land for development. There is no such policy imperative set out within the NPPF, and as result were the SWLP to prioritise brownfield land over greenfield development it would be inconsistent with national policy and fail the tests of soundness. By way of context, it is important to note that prior to the publication of the NPPF in 2012 the concept of sustainable development was largely based upon the delivery of previously developed land, with an express sequential approach set out in PPG3 (latterly PPS3) and PPG1 (latterly PPS1). This sequential approach was specifically removed from national policy, and a more nuanced approach to sustainable development set out. There is no indication that a sequential approach is to be brought back in, despite the various revisions to the NPPF which have been published since 2012. This is because utilising brownfield land does not automatically render a proposal sustainable; and to prioritise brownfield land would be to bring forward development that does not meet the three pillars of sustainability and potentially unbalance plan strategy and plan delivery, since development would only be brought forward where brownfield land exists, not where the plan making process determined development should be. Policy can make clear that the emphasis should be on utilising brownfield land for development, but this must not be expressed as a sequential approach nor applied as such through the development management function. Issue S4: Growth of existing settlements Q-S4.2: Yes, we agree that some of the existing settlements should be part of the overall strategy, particularly Southam. The SA has explored a number of alternative options for growth at existing settlements. The importance of considering the potential for growth around the edges of existing settlements is acknowledged. The growth of all existing settlements (proportionate to their size) could also assist the council to secure benefits associated with the 20-minute neighbourhood principle – the settlement analysis undertaken as part of the evidence base identifies settlements which are considered to be suitable for growth – based on connectivity, accessibility and density analysis. Issue S5: The potential for new settlements Q-S5.3 Do you think new settlements should be part of the overall strategy? No. We are of the view that new settlements should not be part of the overall strategy for the following reasons; • Due to the level of infrastructure required, new settlements can take years to come forward before housing can be delivered. This can seriously jeopordise the ability of the local plan to deliver both open market and affordable homes across the District for which there is a critical need. A study by Lichfields entitled “Start to Finish” (2016) highlights the problems associated with large scale development and compares them against delivery times for smaller developments. It highlights several examples of new settlements (2,000-3000 dwellings at Cambridge University). On average it took 10 years for the final schemes to be approved following allocation in the Local Plan (following outline and various reserved matters applications). The report did not go on to consider discharge of conditions applications/variations which actually may also delay the ability deliver the approved dwellings. This compares to smaller scale schemes which on average took 8 years. • The report states that large sites, which are not likely to deliver quickly, are also unlikely to be contributing to five year housing land supply calculations. The strategy should include small and medium sites which the Framework acknowledges can make an important contribution to meeting the housing requirement. • The reliance on new settlements within the strategy will also result in an inherently inflexible plan – which relies on the delivery of fewer but larger sites with multiple land owners. Coming to agreement over land value and sequencing of delivery are likely to be other factors which can delay the scheme which ultimately may result in developers having to contribute more to the infrastructure (drainage/highways etc) which will impact on viability, potentially at the expense of affordable housing provision. • It is for these reasons that several plans relying on large new settlements have failed – Uttlesford DC withdrew their plan due to the Inspector not being persuaded that evidence demonstrate the Garden Communities and overall spatial strategy had been justified. North Essex had similar problems with their proposed Garden Communities, which had to be removed from the Joint Local Plan before the Inspector found the Plan sound Issue S8: Small scale development outside of the chosen spatial growth option Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold development approach is appropriate, to allow more small-scale developments to come forward? Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap. Issue S9: Settlement Boundaries and infill development Q-S9 – It is our preference for Part 1 of the Plan to review and define all settlement boundaries across the combined district. This would achieve a consistent approach and allow smaller settlements to take more proportionate growth to enhance the vitality of rural communities.
Affordable housing is a significant issue for the SWLP. It is firstly important to have in mind that delivering housing to meet identified needs will assist in keeping affordability ratios in check, since demand will meet need and will avoid housing prices rising due to elasticity of supply issues. Even in circumstances where housing need is being identified and met, there is an acute need for affordable housing in South Warwickshire. The public sector is unable to deal with this issue, it is therefore for the private sector to deliver necessary affordable housing provision. Exception type housing will deliver a proportion of affordable provision, this however will be very low. The most effective way of delivering affordable housing is via allocations and windfall development over the plan period, by way of an appropriate – viability tested – threshold and percentage delivery requirement. The SWLP should maximise the delivery of market housing delivery, so as to correspondingly maximise the opportunity to deliver affordable housing. This is singularly the only way in which meaningful quantities of affordable housing will come forward in the plan period.
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Issue H4: Accommodating housing needs arising from outside of South Warwickshire Q-H4-1:Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon? Yes. South Warwickshire is inextricably linked with three wider housing market areas; Birmingham, Coventry and the Black Country. For Birmingham, the latest evidenced position is that unmet need is in excess of 78,000 houses. This is a materially worsening position, and it is likely that the actual unmet need will be substantially greater at the point of SWLP examination and adoption. Coventry has a significant housing requirement, which it too cannot meet in full. The precise unmet need is being determined, once known this too will need to be factored in. The Black Country is a third HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline. Q-H4-2 Please add any comments The Black Country is a HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline.
The extent of the shortfall from the wider HMA’s is so significant that by ring fencing its delivery there risks a plan strategy which is driven by HMA issues rather than being developed in the context of sustainable development. Thus, whilst the temptation will be to accommodate housing to serve the wider HMA’s at the northern edge of the SWLP plan area, we consider that the approach should be to a) identify the overall housing requirement for the SWLP having regard to ‘internal’ housing requirements and HMA unmet need; and then b) develop a plan strategy to deliver all of this housing in full. This avoids any form of ring fencing within the SWLP area. It also avoids the complex trigger mechanisms set out in the draft SAP which are, in practice, difficult to apply in a development management context.
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Issue H2: Providing the right tenure and type of homes Q-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. This would allow the requirement to be applied consistently across both Districts. Issue H3: Providing the right size of homes Q-H3a. We would support option H3a – which does not seek to include minimum space standards in a policy. We would agree that this is not of strategic importance across South Warwickshire and so could be considered in Part 2 of the plan, and assessed against evidence provided that it is a requirement within the District that would not impact on the affordability of properties. Issue H5: Providing custom and self-build plots Q-H5a and c The Self-build and Custom Housebuilding Act 2015 (as amended) places duty on Councils to keep a register of individuals and associations of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. They are also required to have regard to this register and grant enough development permissions to serviced plots of land to meet the identified demand, where the demand is dictated by the number of entries on the Council’s Self-build register within each base period. The Planning Policy Guidance (PPG) states that self-build or custom builds helps to diversify the housing market and increase consumer choice. In such types of projects, the initial homeowners choose the design and layout of their home, allowing for innovative creativity. On this basis, we consider that the Council should give proper consideration to the identification of a range of specific sites on the edge of existing settlements to be developed for self and custom build homes. This is preferable to requiring large developments (over 100 dwellings) to provide a proportion within the overall site. This would not be appealing to most national house builders and difficult to implement in policy terms. Wyre Forest’s recently adopted Local Plan (SP12) includes a specific policy requiring major development schemes of 50 or more dwellings to “take into consideration the demand shown in the Self-Build and Custom- Build register and where possible provide suitable plots.” Where plots are made available and marketed for at least 12 months, and there is no demand – they may be built out by the developer.
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Issue C3 Carbon Sequestration Q-C3.1 A carbon off-setting approach to new developments could be supported in principle, if it was demonstrated that it is not possible to achieve net carbon zero requirements on a particular site. Further information is required on this subject and presumably this will be included in subsequent consultations.
