Issue and Options 2023
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Issue H1: Providing the right number of new homes 4.1 Catesby Estates praises the Consultation Document for recognising that ‘England is experiencing a housing crisis’ and that there ‘has been a failure in the supply of affordable homes to achieve the Government’s target of 300,000 homes annually’. Catesby Estates also supports and echoes the issues identified through the previous consultation and summarised within the Consultation Document, including that there is an affordability issue within South Warwickshire. We are clear in our view that the only way of addressing this is by increasing supply of housing overall, which will also help to deliver affordable housing. 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 towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 4.2 The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. 4.3 The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. 4.4 Barton Willmore, now Stantec has not reviewed the methodology utilised by the HEDNA and therefore cannot comment on its appropriateness. 4.5 The HEDNA nonetheless suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford -on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1,679 dwellings per year (440 dwellings pear year / 35.5% increase). 4.6 The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not include any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any addition homes that may be planned for to meet other socio economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). 4.7 Should the authorities choose to pursue the trend-based alternative, they must accept that the housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Coventry whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method. Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Option H2-2a – A single South Warwickshire wide affordable housing requirement Option H2-2b – Separate affordable housing requirements for Stratford On Avon and Warwick Districts Option H2-2c – A more localised approach with separate affordable housing requirements for different localities across South Warwickshire 4.12 Catesby Estates acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by the Councils. Given that market conditions and housing need (both market and affordable) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement. Similar to CIL, it is important the two District’s keep their affordable housing requirements separate, as their housing figures remain separate and therefore ensures this overall figure for each district is achievable. In addition, separate affordable housing requirements takes into account items such as geographical location and therefore the difference in land values, it also provides the opportunity for each District to target their own specific affordable housing need. This is supported by Paragraph 0041 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. 4.13 However, regardless of the affordable housing requirements proposed, the Council need to ensure that Policy is flexible in wording, allowing for viability to be taken in account and demonstrated where required to do so. 4.14 Furthermore, the proposed affordable housing policy is a strategic policy, which should be set out by establishing and understanding the need requirement, therefore the policy should be informed by evidence. 4.15 This is supported by Paragraph 0042 (Reference ID: 23b-004-20190901) which sets out that planning obligations policies should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability. Consequently, there is potential that the two local authorities have different needs, and therefore the Policy should be addressed in accordance. However, Catesby Estates cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.16 Option H2-2c should not be considered as it would result in affordable housing requirements being unclear and potentially unknown, therefore introducing risk, impacting upon bringing sites forward and ultimately delivering the required housing figures. 1 Planning Policy Guidance: Where should policy on seeking policy obligations be set out? 2 Planning Policy Guidance: Where should policy on seeking policy obligations be set out? Q-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 4.17 As set out under Paragraph 1.4 of the Issues and Options Report, the purpose of Part 1 of the Local Plan is to establish a robust and flexible framework to set out where and how much development should take place across South Warwickshire. Consequently, the introduction of minimum space standards is not appropriate for Part 1 as it is not a strategic consideration, thus none of the above options are the correct or suitable approach. Consequently, Option H3a should be pursued on the basis of not including minimum space standards in a policy within Part 1 of the Local Plan. 4.18 However, if the Council wish to include this, sufficient evidence should be presented as per PPG Paragraph 0023 (Reference ID: 56-002-20160519) which sets out that in order to set minimum space standards within local planning policy, local authorities need to gather evidence to determine where there is need for additional standards in that area, to justify appropriate policies. The importance of this guidance cannot be understated. It is clear that the onus is on local authorities to demonstrate why standards are needed in that area i.e., the absence of such standards is consistently resulting in the provision of under -sized homes within Warwick and Stratford Districts. 4.19 However, it is also worth noting that in order to achieve Minimum Space Standards, larger plots will be required and therefore appropriate densities for allocated sites and what is deemed as suitable densities will need to be considered. Overall, having a Minimum Space Standard requirement may then impact upon achieving the overall housing need, therefore Catesby Estates suggests the local authorities allocate more sites, above the HEDNA requirement in order to take account for Minimum Space Standards, ensuring the Standards can be met without impacting upon density and housing numbers, thus deliverability. Issue H5: Providing custom and self-build housing plots Q-H5: Please select all options which are appropriate for South Warwickshire Option 5a – Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. Option 5b – Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. Option 5c – Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. 4.29 Catesby Estates acknowledges the need for self and custom build homes, however the viability of such plots need to be considered when establishing planning policy. Option 5b has potential to be an option, where self and custom build homes will be encouraged/required on larger developments, however the Council will need to test via their viability assessment the amount required against different sized sites. 4.30 However, where Option 5b states ‘over 100 dwellings,’ this threshold needs to be viability tested and justified. In addition, the Policy should be caveated to ensure that it allows developers flexibility, for where it can be demonstrated that the provision of self build and custom plots are not viable as part of the wider scheme, that is acceptable from a policy perspective. This needs to be taken into consideration based upon a site’s location and associated constraints. 4.31 In addition, the Council need to ensure sufficient evidence is present and demonstrated to show need and demand for self and custom built. At present, there is no evidence to show that there is a need for this within South Warwickshire, and if it can be demonstrated, a realistic and achievable consideration should be had when deciding the required amount to underpin the policy. In addition, the Policy should include wording to states that if after 12 months of marketing, there is no demand, the plots/houses can be marketed. 4.32 Option 5c should also be amalgamated into policy, whereby each site should be assessed on its’ own merits and consideration is had if deliverability isn’t possible, or at the required level, specifically on sustainable urban extensions. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire 4.33 It is crucial that the Councils undertake more evidence, to create a wider, more detailed evidence base to inform the next stage of the South Warwickshire Local Plan. It is detrimental to the potential Growth Options to not have fully evidenced reports, such as a Green Belt Review, review of the Call For Sites submissions, engagement with other authorities within the HMA, the creation/update of the HELAA and viability testing. 4.34 Without this evidence, it is difficult to fully appreciate whether the housing need for South Warwickshire can be accommodated, where it could be accommodated, what sites are physically available for development, and the viability associated with other policies in relation to the delivery of residential sites. Therefore, Catesby Estates strongly advises the Council undertakes further evidence and engages further, prior to the formulation of any future iteration of the Local Plan.
4.8 Table 8.45 of the HEDNA (reproduced at Table 10 of the Consultation Document) identifies that there is a total annual affordable housing need of 547 dwellings in Stratford and 839 dwellings in Warwick (totalling 1,386 homes per year). This need is significant and, in the case of Stratford, is in excess of the trend-based alternative figure for overall housing provision that is also suggested by the HEDNA (868 dwellings per annum). 4.9 Catesby Estates submits that the only way to realistically deliver affordable housing at a level that is anywhere close to the level of identified need would be for both Councils to allocate a significantly greater number of sites to deliver market housing over and above the minimum need identified by the HEDNA (either Standard Method or trend-based alternative). Such development would include a portion of affordable housing, in line with the relevant Local Plan policy. 4.10 At present, there is a policy requirement for 35% of proposed residential dwellings to be affordable homes in the Stratford District and 40% in the Warwick District. 4.11 As such, if the total trend-based alternative need figure (1,679 dwellings) was provided annually, and even if assuming affordable housing was provided at 40%, this would result in the provision of 671.6 affordable homes per year; 714.4 dwellings per year less than the identified annual affordable housing need. Clearly, it would be challenging to deliver the and meet the affordable need in full, but the Local Plan should do all it can to tackle the affordability issue by identifying additional sites for housing.
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Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.20 Catesby Estates supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. Catesby Estates also supports the recognition that, even if the trend-based alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum.) Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.21 In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.22 The Consultation Document identifies that, for the purposes of the accompanying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.23 Catesby Estates broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.24 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
4.25 As acknowledged within the Consultation Document, there is a strong argument that, if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel. 4.26 As such, sites along the railway corridors and near the M40 are likely t o help accommodate unmet need from Birmingham and the Black Country, whilst sites south of Coventry can be identified and serve the wider housing shortfall of Coventry. 4.27 However, these is a credible argument that the focus should be on delivering growth across the Districts in line with the chosen spatial strategy which achieves the desired objectives including proximity to public transport and services and addressing affordability; rather than solely its proximity to the source of the unmet need. 4.28 Lastly, linked with our responses to Questions S3-1 and H1-1, the meeting of additional unmet need from neighbouring authorities is likely to necessitate the development of greenfield land.
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Issue C3: Carbon Sequestration Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? 5.1 A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to ensure sufficient viability testing has been carried out to support the Policy.
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Issue C6: Whole Life-Cycle carbon emission assessments Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C6.1a – Include a Policy that requires new developments to have a whole lifecycle emissions assessment, with a target for 100% reduction in embodied emissions compared to a business as usual approach to construction? Option C6.1b – Include a Policy that has different whole lifecycle reduction targets for different scales and types of developments and for different time periods. Option C6.1c – None of these. 5.4 Catesby Estates acknowledges that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. 5.5 Option C6.1a could have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions could undermine the other objectivges of the plan including delivery of much needed housing. 5.6 We would emphaise the need for the policy to be supported by robust viability work. Q-C6.2: If a phased approach is used, what dates and thresholds should be used? 5.7 The dates and thresholds should be realistic and justified but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.
