Issue and Options 2023

Question S10: 3.36 Aligned with our responses set out above, a mix of strategic approaches is needed to deliver the development needs of South Warwickshire. This should include focusing development around existing settlements to ensure suitable future growth, particularly in the most sustainable locations such as Royal Leamington Spa. A review of existing settlement boundaries and Green Belt is needed to accommodate this growth. 3.37 Land North of Leamington presents a suitable strategic scale opportunity to significantly deliver South Warwickshire’s housing and employment needs. This will include social, economic and environmental benefits centred around the five design principles for the site, as set out above and in the Vision Document (Appendix 3), alongside any appropriate mitigation measures deemed necessary.

3.38 The Housing and Economic Needs Assessment (‘HEDNA’) (November 2022) sets out the economic and employment land needs for Coventry and Warwickshire from 2021 to 2050. In summary, the HEDNA forecasts overall economic growth and significant need for additional employment land to 2050. Overall, a total need for 345.3 hectares of employment land exists in South Warwickshire between 2021-2050 (248.1ha in Stratford District and 97.2ha in Warwick District). 3.39 Strategic sites can make a significant contribution and opportunity for delivering these economic and employment land needs, including as part of residential-led mixed use proposals, delivering self-sufficient and sustainable neighbourhoods. This approach towards such mixed-use strategic sites should be taken to assist in delivering the ambitions for employment growth in South Warwickshire. 3.40 Specifically, this should be considered through support for strategic mixed-use proposals such as Land North of Leamington. Sites such as Land at North of Leamington can make a notable contribution towards South Warwickshire’s economic needs, in the most sustainable location and where the need would be the greatest, in the immediate vicinity alongside residential development.

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Question H1.1: 3.41 Taylor Wimpey generally supports the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. 3.42 It will be important that the CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.

3.43 Taylor Wimpey considers that there is an opportunity to increase the overall housing requirement for the plan period to help deliver a higher amount of affordable housing. 3.44 Table 8.45 of the HEDNA states that WDC and SDC have a combined affordable annual need of 1,386 dwellings per year, this is a significant need and would justify a higher overall housing requirement to ensure that sufficient affordable homes are being provided throughout the plan period. 3.45 It is also relevant to note that constraints on the release of land for residential development, and in turn the provision of houses on that land (for sale or as affordable provision), can lead to increased house prices in an area. The SWLP should therefore be focused on creating a policy environment that does not place undue constraints on sites that are allocated, thereby maintaining a supply that will in turn address issues of affordability.

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Question H2.2: 3.46 Whilst a single affordable housing policy for the SWLP should be considered as the most straightforward and universal approach, as set out at Option H2-2a, any policy requirement must allow for suitable viability testing on a site-by-site basis.

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Question H3: Option H3a: 3.47 Space standards are not a strategic matter and should therefore be dealt with in any Part 2 Plan. As set out in Paragraph 002 of the NPPG Chapter ‘Housing: optional technical standards’, any proposed space standards will need to be sufficiently evidenced, to justify a local need for exceeding the minimum standards required by Building Regulations and an optional nationally described space standard.

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3.48 WDC and SDC should accommodate an appropriate proportion of the emerging GBBCHMA housing shortfall to 2040 and, once established, also accommodate an appropriate proportion of the emerging CWHMA housing shortfall. 3.49 Taylor Wimpey consider that that the approach to the previous CWHMA shortfall up to 2031 was dealt with successfully through the preparation of a Memorandum of Understanding (MoU) agreed upon by each of the authorities. The MoU agreed the housing need for each authority between 2011 and 2031 and that an unmet need of 17,800 homes arose from Coventry. The MoU agreed how this unmet need was to be split between the seven authorities based on functional relationships, commuting patterns and the balance of jobs. This approach enabled all the LPAs within the CWHMA to progress their Local Plans, with the last plan adopted in June 2019. 3.50 In comparison, the approach to date by the GBBCHMA authorities has resulted in a substantial amount of Birmingham City Council’s shortfall identified in the 2017 Birmingham Development Plan (BDP) up to 2031, amounting to circa 6,000 homes remaining unaccounted for. Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s plan was adopted in 2017 only one authority within the GBBCHMA has adopted a plan identifying any housing to meet Birmingham’s unmet needs – North Warwickshire in September 2021. The certainty provided by a strategy agreed early on by all authorities will therefore ensure that plan making can continue without delay across the GBBCHMA. 3.51 This also needs to be considered in the context of unmet needs from other HMA authorities, including the Black Country. Although the Black Country Plan has now been abandoned, the most recent version of that plan established a shortfall of circa 28,000 homes up to 2039, this shortfall is robustly evidenced through the four councils’ Urban Capacity Study Update (December 2019) and tested through the WMCA Brownfield Land Study. This shortfall is based on brownfield delivery and includes Green Belt release. If there were to be no Green Belt release, the unmet need would total circa 39,000 homes. 3.52 At this stage we do not intend to propose a model for how any unmet needs should be distributed, this is for the SWLP and HMA authorities (both CWHMA and GBBCHMA) to determine in due course, following a number of matters being resolved in the first instance. The Association of Black Country Authorities (ABCA) letter to the wider GBBCHMA authorities on 26 April 2022 sets out a very useful starting point for the GBBCHMA authorities in order to commence preparing a SoCG and it is considered that this approach would be suitable for the CWHMA too: • Reviewing the extent of the HMA in order to understand if it represents the most appropriate geography for considering unmet needs – this is pertinent given plans from outside the HMA (i.e., Shropshire and Stafford Borough) are offering contributions to the GBBCHMA’s unmet needs. • Confirm the scale of the housing shortfall across the entire HMA over a period of at least 15 years to inform the approach to be taken. This needs to consider the remaining unmet needs from other authorities, such as the Black Country, as it may be some of the unmet need has already been met by other GBBCHMA Councils. • Reviewing the 2018 Growth Study to understand if it remains appropriate and if there are new growth areas. This is likely to require a new study. • Review of governance arrangements between the GBBCHMA authorities in order to prepare a SoCG (an initial draft of which has been published as part of papers to Bromsgrove’s Full Council). 3.53 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, we are of the view this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and LLHMA’s approaches, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This must include detailed analysis and consideration of other models used by other HMA geographies for distributing unmet needs.

3.54 The overall contribution to any shortfall should be based on functional relationships, for example with WDC and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within WDC and SDC. It is considered that by virtue of the functional relationships that exist at a strategic level, all key settlements and sustainable growth options will have strong links to the source of this shortfall.

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Question H5: 3.55 Setting a requirement or standards for all large-scale sites to deliver an element of custom built homes can cause significant difficulties. Alternatively, custom build plots would be more appropriate to specific smaller scale sites, which can be included in the SWLP Part 2 or as part of neighbourhood planning.