Issue and Options 2023

Introduction 1.1 Turley is instructed by Taylor Wimpey Strategic Land (Taylor Wimpey) to represent its interests in relation to the South Warwickshire Local Plan (SWLP) and to formally respond to the consultation on the Issues & Options dated January 2023. 1.2 Taylor Wimpey is promoting approximately 14 hectares of land north and east of Hampton Magna, which represents a new sustainable and deliverable residential neighbourhood. 1.3 The site was submitted via the Call for Sites exercise in June 2021 and identified by the following site reference 573. Additionally, Taylor Wimpey submitted representations to the Scoping Paper in June 2021. 1.4 These representations should be read in conjunction with the following suite of sitespecific evidence, which is supported in support of these representations: • Appendix 1 – Vision Document • Appendix 2 – Heritage Assessment 1.5 Section 2 of this statement provides a summary of the site and the opportunity that the neighbourhood presents for South Warwickshire. Section 3 sets out Taylor Wimpey’s representations in response to each relevant issue and option, including: • Issue S4: Growth of existing settlements • Issue S7: Refined Spatial Growth Options • Issue S9: Settlement Boundaries and Infill Development • Issue H1: Providing the right number of new homes • Issue H2: Providing the right tenure and type of homes • Issue H3: Providing the right size of homes • Issue H4: Accommodating housing needs arising from outside of South Warwickshire • Issue C3: Carbon sequestration • Issue C9: Mitigating biodiversity loss • Issue D3: Designing adaptable, diverse and flexible places • Issue D5: Protecting and enhancing heritage assets • Issue W4: Public open space for leisure and informal recreation • Issue T1: 20-minute neighbourhoods 1.6 Section 4 of this statement summarises and concludes the representations. 2. The site and the opportunity 2.1 This section describes the opportunity of the site in terms of its geography and its prospects for delivering a new neighbourhood at Hampton Magna. Description of the site 2.2 The site is located south of Warwick Parkway and lies to the north and east of Hampton Magna within the Green Belt. 2.3 It extends to approximately 14 hectares and is made up of 3 agricultural fields, varying in size and shape. Each of the field parcels are divided by well-established hedgerows and individual mature trees. 2.4 The northern boundary is predominately defined by mature hedgerows running alongside a farm track. A farmstead with a cluster of buildings sits centrally on the northern boundary. Immediately north is Warwick Parkway which provides services to London and Birmingham. 2.5 A small field and the dense mature tree belt associated with the A46/Warwick Bypass delineate the eastern boundary. The southern boundary is again defined by mature hedgerow, beyond which are further agricultural fields. 2.6 The western boundary is defined by the village of Hampton Magna. Old Budbrooke Road outlines the most northern part of the western boundary and the rear gardens of residential properties on Blandford Way, Arras Boulevard, Gould Road and Clinton Avenue define the central part of the western boundary. 2.7 Land to the south-west is currently under construction for new homes – homes allocated under sites H27 and H51 in the Warwick Local Plan (September 2017) and subsequently subject to approval of planning permissions W/19/0691 and W/19/2112 for a combined total of 267 new homes. 2.8 Historically, the existing settlement of Hampton Magna was formally used as the army barracks of the Royal Warwickshire Regiment from 1877 which remained in use until the mid-1960’s. In the late 1960’s and early 1970’s, the barracks were re-developed as part of the post-war housing boom. The opportunity 2.9 The site has the capacity to deliver between circa 300 and 350 new homes based on a density of between 35 and 40 dwellings per hectare on an 8.6 hectare developable area. The neighbourhood will comprise a mix of different house types, tenures and sizes. 2.10 The non-developable area will comprise access routes, a hierarchy of streets to facilitate safe pedestrian and cycling movement and be knitted together by 5 hectares of public open space and 1,200m² of play space. 2.11 In planning terms, the site is deliverable for new homes subject to its removal from the Green Belt. This is on the basis of the explanation below: Available 2.12 The site is available for residential development based on the following: • There are no legal or ownership impediments to development. • The land is in single ownership. • The land is subject to an option with an intent to develop. • Taylor Wimpey has an excellent delivery record in South Warwickshire. • The site is not subject to a history of unimplemented permissions. Suitability 2.13 The site is suitable for residential development because of the following factors: • It is not subject to any technical constraints which cannot be avoided or mitigated. • There are no international and/or national environmental designations. • Its neighbouring use is also residential. • The market attractiveness of the geography is high. Achievability 2.14 The site is achievable for residential development because: • New homes can start to be delivered within five years following permission. • It is currently economically viable subject to planning obligations. • Taylor Wimpey has the capacity to complete and sell new homes early in the plan period. 2.15 The full constraints and opportunities are described in the accompanying Vision Document (Appendix 1) and an illustrated development framework is provided to visually express how the new neighbourhood will be a place for living and playing. Question S7.2: 8 The appropriate strategy for South Warwickshire is a mix of the identified growth options i.e. a blended approach. Hampton Magna options in the SA 3.19 This blended approach should include growth at Hampton Magna (with Warwick Parkway) as it performs well in all growth options. 3.20 In particular, Hampton Magna is assessed favourably in rail-led and sustainable travelled options, which have the fewest assessed minor adverse impacts against the SA objectives. 3.21 The spatial pattern of growth around key public transport nodes results in a major positive impact on the SA11 ‘Accessibility’ objective. These options are also the best performing growth options in respect of SA6 ‘Environmental Pollution’ and SA7‘Natural Resources’ objectives. 3.22 The SA concludes that sustainable travel-led development is likely to align most closely with development that will most effectively mitigate against climate change. The opportunity of Warwick Parkway 3.23 The delivery of new housing growth at Hampton Magna is not reliant on a new or reopened railway station. It benefits from its close proximity to Warwick Parkway as an existing means of sustainable transport, particularly to jobs. 3.24 Warwick Parkway provides services to Birmingham Moor Street and Birmingham Snow Hill approximately every 30 minutes. Journeys to these stations take 20 minutes and 30-40 minutes respectively. Services to London Marylebone, via Warwick and Leamington Spa, are also offered approximately every 30 minutes. Meanwhile,journeys to Warwick and Leamington Spa are 3 minutes and 7 minutes respectively. The station provides regular services to regional centres providing access to appropriate services and facilities. 3.25 Between April 2021 and March 2022, there were an estimated 270,714 passengers travelling either to or from the Warwick Parkway station1 . This figure increased fivefold from the previous year – numbers in Warwick and Leamington Spa approximately tripled in this time. 3.26 Although the Covid-19 pandemic will have influenced the scale of growth in number of passengers travelling to or from stations, as well as the absolute number of passengers, it is evident that proportionally Warwick Parkway has seen the biggest growth in passengers over the last 12 months.In summary, Hampton Magna is an existing settlement with strong rail and bus infrastructure that provides or enables connections at local, regional, national and international scales. There is capacity for greater use of the station, which makes the settlement an appropriate location for strategic housing development as part of the SWLP. Question S9: Please select the option which is most appropriate for South Warwickshire • Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. • Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.28 Option S9b is the most appropriate option for South Warwickshire as there will undoubtably be a need to review and alter some existing settlement boundaries to accommodate the housing requirement up to 2050 on land adjoining existing sustainable settlements, including Hampton Magna. 3.29 Option S9b is consistent with paragraph 73 of the NPPF in that it will allow for the supply of large numbers of new homes to be delivered by significant extensions to existing villages and towns “provided these are well located and designed, and supported by the necessary infrastructure and facilities”. 3.30 Option S9a will preclude the SWLP from being positively prepared and consistent with national policy as existing settlement boundaries were formed on out-of-date evidence on development need and sustainable patterns of growth. This is inconsistent with paragraph 31 of the NPPF. Summary and Conclusion 4.1 This section summarises and concludes the representations made by Taylor Wimpey in relation to land north and east of Hampton Magna and the issues which need to be addressed to deliver sustainable development in South Warwickshire. Summary of representations 4.2 To deliver sustainable development, the SWLP should pursue the following options: (i) Allocate new homes on land around existing settlements such as Hampton Magna. (ii) The spatial distribution of new homes should be guided by a blend of the five growth options. (iii) Existing settlement boundaries should be reviewed and altered to allocate new homes, including at Hampton Magna. (iv) Utilise a trend-based approach using the 2021 census data for calculating local housing need. (v) Accommodate an appropriate proportion of the emerging GBBCHMA and CWHMA housing shortfalls. (vi) Increase the housing requirement to ensure that sufficient affordable homes will be delivered. (vii) Select strategic sites which can provide climate change adaptation and climate change mitigation. (viii) Afford flexibility on biodiversity net gain so it can be achieved on-site, offsite or through a combination of on-site and off-site measures. (ix) Identify appropriate density ranges for different locations/areas based upon accessibility and potential accessibility of these places. (x) Continue with the approach to include a high-level strategic policy on protecting and enhancing heritage assets (xi) Include reference to the principles of a 20-minute neighbourhood within a broader overarching policy. Next steps 4.3 Taylor Wimpey trusts these representations and the supporting Vision Document will be analysed to inform the SWLP Preferred Options. 4.4 Taylor Wimpey welcomes a meeting with WDC and SOADC to discuss the refinement of the growth options and the spatial distribution of housing growth to Hampton Magna.

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Q-S4.1: Yes, Taylor Wimpey agrees with the statement made in the Issues & Options that: “… 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” 3.3 The growth of some existing settlements offers the realistic prospect of meeting local housing needs and achieving the delivery of sustainable development. Hampton Magna is such an existing settlement that is capable of accommodating housing growth over the plan period. This is evident by Hampton Magna (in combination with Warwick Parkway) being identified as a potential existing settlement for growth within each growth option. 3.4 This assertion is based on a review of the existing evidence base supporting the Issue & Options, which concludes the following for Hampton Magna: Bus Accessibility Mapping 3.5 It is between a 0-15 minute bus travel time of major towns, employment centres, GPs, dentists and pharmacies and secondary schools and colleges, and is between a 15-30 minute bus travel time of major and minor towns and hospitals Sustainability Appraisal (SA) Issues and Options Stage (November 2022) 3.6 It is identified as a Small Settlement Location (SSL) for intermediate scale where housing development of between 50 and 500 homes in any one location can be brought forward using the principles of the 20-minute neighbourhood concept. 3.7 It is the highest scoring SSL, with minor positive impact scores against SA2 Flood Risk and major positive impact scores against SA9 Housing and SA11 Accessibility. The settlement either performs equal to or better than other existing settlements for every other objective. This is exemplified in Table 5.1 of the SA Issues & Options, which is set out below (red outline our emphasis): Paragraph 32 of the National Planning Policy Framework (NPPF) (July 2021) is clear that local plans should be “informed” by a sustainability appraisal to document how the SWLP (in this instance) has addressed relevant economic, social and environmental objectives. 3.9 Therefore, as Hampton Magna is the best performing existing settlement in sustainability terms (i.e. it limits the most significant adverse impacts on the objectives via being avoided, reduced or eliminated), a suitable amount of housing growth should be directed to the settlement up to 2050. Settlement Design Analysis (January 2023) 3.10 It is does not have any significant barriers to connectivity which would be difficult or impossible to overcome and all ‘edges’ can at least connect to: green route, loops or cul-de-sacs only, with limited or no potential to connect these into new red route; and limited or no potential active links e.g. via green / blue infrastructure or other active links. The eastern edges of the settlement are flat without Flood Zone 2 and 3 or green infrastructure constraints. Therefore, there are no significant gradients that have the potential to impact on the ability and/or likelihood of using active modes of travel for some trips nor are there areas at risk of flooding which have the potential to impact movement and route options. 3.12 It has all required local facilities within 800m walking distance including those relating to retail, jobs and economy; places to meet; open space, leisure, recreation – wellbeing; healthcare; education. 3.13 Its existing density is characterised as ‘outer suburbs’ providing between 20 and 40 dwellings per hectare with few apartments and a less varied mix of land uses. Question S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on 3.14 The settlement analysis does not consider the full extent of Hampton Magna. It currently excludes the committed and now under construction allocations H51 and H27 in the adopted Warwick Local Plan (September 2017). 3.15 Each allocation is subject to approved detailed site layouts, so there is sufficient information in the public domain to analyse how the new residential development to the east and south of Hampton Magna contributes to and supports improvements to connectivity, accessibility and density in Hampton Magna. 3.16 Paragraph 31 of the NPPF states the preparation of all policies should be underpinned by relevant and up-to-date evidence. It is in this context, that the approved detailed site layout information for adopted allocations H51 and H27 should be considered in the plan-making process to ensure a sustainable pattern of housing growth is achieved at Hampton Magna. 3.17 Finally, and separately, Table 1 of the settlement analysis identifies Hampton Magna in silo and only in a ‘dispersed’ growth scenario. This is inconsistent with the identification and assessment of Hampton Magna in combination with Warwick Parkway in the Issues & Options. It is recommended Hampton Magna is coupled with Warwick Parkway as in combination the location performs well in each spatial growth option – as documented in the Issues & Options.

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Question H1.1: Taylor Wimpey generally support 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. 3.32 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.

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. 3.34 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. 3.35 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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Issue H3: Providing the right size of homes Question H3: Please select all options which are appropriate for South Warwickshire • Option H3a: Do not seek to include minimum space standards in a policy in the SWLP • Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence • Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards • Option H3d: None of these 3.36 The provision of minimum space standards for housing should be a standard requirement for new development in South Warwickshire. 3.37 However, in this instance, Option H3a is the most appropriate option for the SWLP as minimum space standards is not a strategic priority which warrants to be included in SWLP Part 1. 3.38 The requirement for minimum space standards for housing is a development management matter which can be included in SWLP Part 2 unless it is centrally prescribed by national development management policies as proposed by the Levelling Up and Regeneration Bill (LURB).

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WDC and SOADC 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. 3.40 Taylor Wimpey considers 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. 3.41 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 for2 . Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s Local 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. 3.42 This also needs to be considered in the context of unmet needs from other GBBCHMA 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 West Midlands Combined Authority 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. 3.43 At this stage, Taylor Wimpey 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: • Review 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. Review 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). 3.44 Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and Leicester & Leicestershire HMA’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.

The overall contribution to any shortfall should be based on functional relationships, for example between Warwick district and Coventry, and between Stratford district and Birmingham. 3.46 Once this principle has been determined, growth should be distributed to the most sustainable locations within South Warwickshire. 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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Climate change adaptation and climate change mitigation are core threads of the NPPF via the delivery of sustainable development. 3.48 In this context, the five overarching principles of the SWLP are welcomed and supported, in particular those that relate to climate resilience, net zero, biodiversity and environmental resilience in South Warwickshire. 3.49 Taylor Wimpey published its Environment Strategy (Appendix 3) in 2021 which established objectives and targets for climate change, nature, resource consumption and waste generation up to 2030 on new developments. 3.50 The Environmental Strategy aligns with the emerging vision, objectives and principles for the SWLP and in summary Taylor Wimpey is committed to the following targets: (i) Reduce operational carbon emissions intensity by 36% by 2025 from a 2019 baseline. (ii) Reduce carbon emissions intensity from its supply chain and customer homes by 24% by 2030 from a 2019 baseline. (iii) Increase natural habitat by 10% on new sites from 2023 and include priority wildlife enhancements from 2021. (iv) Cut waste intensity by 15% by 2025 and use more recycled materials. 3.51 Taylor Wimpey has formed several partnerships with nature organisations including Hedgehog Street and Buglife to protect and enhance natural habitats in new neighbourhoods. 3.52 It is recommended that the site selection process is informed by those strategic sites which can provide climate change adaptation and climate change mitigation as referred to in National Planning Practice Guidance (PPG) [Paragraph 003 Reference ID: 6-003-20140612 and Paragraph 007 Reference ID: 6-007-20140306].