Issue and Options 2023
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New searchWe have reviewed the Urban Capacity Study by Arup dated October 2022. Net of outstanding commitments and windfalls, it identifies an overall capacity of 1,231 dwellings. For the sake of comparison the Housing and Economic Development Needs Assessment (HEDNA) identifies a base annual housing need in South Warwickshire of 1,432 dwellings per annum (dpa). As such, even if all of these sites were to come forward at the assumed densities, their contribution to meeting housing need would be minimal. We also have concerns about the robustness of some of the sites identified as contributing towards urban capacity. For example, The Greens South of Alcester Road in Stratford-uponAvon is assumed to have a capacity of some 80 units when it was refused planning permission for 57 dwellings by the Council on heritage amongst other grounds. It is clear therefore that many of these sites will not proceed beyond the land availability assessment. We recognise that the Urban Capacity Study may not have looked at rural brownfield sites although given the sustainability challenges associated with such sites, they will likely make a negligible contribution. Accordingly, the evidence base shows that whilst brownfield development could always be prioritised, it will only make an at best marginal contribution towards meeting housing need on the council’s own evidence.
Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes. Sustainable settlements should accommodate growth not only to bring about a balanced and deliverable spatial strategy but also to ensure their continued viability and vitality. As the councils will be aware freestanding new settlements take a long time to commence development and are often reliant on funding entirely new infrastructure which can be challenging to realise in practice. In addition, the councils will need to identify sites that are capable of coming forward in the early years of the plan period to establish a five year housing land supply. Sites on the edge of existing settlements are best placed to meet this need provided they can mitigate their own impacts on local infrastructure. Q-S5.2: Do you think new settlements should be part of the overall strategy? No. We understand the rationale for and the benefits of new settlements where there is suitable and deliverable land available for them. For example, there was spatial logic to the Long Marston and Lighthorne Heath new settlements identified through the adopted Stratford District Council Core Strategy as one was partially previously developed land and the other near a strategic employment site. However, the new settlement options identified in the SWLP appear to lack such robust logic. Half are proposed to be located in the Green Belt and whilst we are generally supportive of releasing Green Belt land to meet development needs where there is a strong sustainability case to do so and where harm to the Green Belt can be minimised or mitigated, the creation of freestanding new communities within the Green Belt will have a considerable impact on its openness and the perception of its openness. The Green Belt new settlement options also happen to be the only locations which have existing train stations. The other options are reliant on new stations being built which is a considerable undertaking and there is no evidence to indicate, notwithstanding the size of any given potential new settlement, that these could be operationally accommodated within the existing network. We understand the rationale for focusing growth around railway stations and corridors to make best use of public transport options to address climate change, but we consider the same benefits could be achieved through more proportionate release of land around a greater number of existing settlements with rail and other public transport connections. We do not consider that a railway and public transport-led strategy must be weighted in favour of new settlements and there is a lack of evidence to indicate that this is a sustainable outcome. Issue S6: A review of Green Belt boundaries We support a review of Green Belt boundaries. We agree that avoiding the Green Belt entirely will not generate a sustainable pattern of growth and is impractical to deliver the ambitious scale of development envisaged by the SWLP. Many of South Warwickshire’s more sustainable settlements are located within the Green Belt and we consider that options to deliver new housing in these locations should be fully explored and acted upon. A comprehensive Green Belt review is key to achieving this.
We have the following comments to make: Alcester: • We welcome that the land north of Captain’s Hill has been deemed has having a fair connectivity grade and note that this contrasts with the west and south of the settlement which both have poorer connectivity grades. We consider this to be an accurate reflection of the situation on the ground where land to the east of the town, particularly to the northeast, benefits from nearer proximity to key services, facilities and the town’s main employment area. • We note the comment within the settlement design analysis which references ground levels and public rights of way. We consider that these constraints can be overcome by appropriate masterplanning that would see the public right of way effectively assimilated within any masterplan, which could be reinforced with green infrastructure and a more sensitive approach to the elevated parts of the site such as by adopting lower densities and/or storey heights. These constraints have been addressed by the FPCR development framework plan as attached at Enclosure 1 which was submitted to the call for sites. • Whilst we would note the Heritage and Settlement Sensitivity Assessment’s commentary about the heritage assets at Kinwarton and the need for a sensitive treatment to these, there is adequate land to the east of the town to allow for a sufficiently sympathetic masterplanning approach including green buffers. • We would note the positive assessment the site has received in Stratford District Council’s Strategic Housing Land Availability Assessment (SHLAA). Wootton Wawen • We welcome that the land north and south of Wawensmere Road and east of the train station is recognised as having good connectivity with the key services and facilities in the village and consider that this reflects the situation on the ground.
In part yes, but as per our response above, we consider that there should be a broad approach to co-locating development with existing railway infrastructure including proportionate growth on the edge of existing settlements which have these facilities, rather than concentrating all or most rail-focused growth on only a handful of locations. The larger towns such as Alcester also have a variety of services and facilities in close walking distance to their periphery as well as good bus services all of which reduce dependence on the private car and deliver the objective of reducing carbon emissions. The land north of Captain’s Hill also benefits from easy access to the town’s main employment area via sustainable means of travel. Such locations should not be discounted simply because they don’t have railway stations.
We note that the figures generated by the HEDNA for South Warwickshire are higher than the figures generated for the area by the Standard Method and the 2014-based household projections. Since a higher number is proposed for the area than the minimum suggested by the Standard Method, the question of whether to use the HEDNA or the Standard Method as far as the SWLP is concerned is largely academic, and we do not have any particular comments in this regard at the present time. We do, however, have broad comments about the general approach employed by the councils in this instance and the rationale for it as there are ramifications for the broader sub-region. The 2021 census data, as with household projection data post-dating 2014, suggests a lower housing need across England as a whole, hence the Standard Method for calculating housing need is still based on the 2014-based household projections as these fulfil the Government’s policy objective of delivering 300,000 homes annually. Rather than statistical rigor, this approach is about rectifying the housing crisis precipitated by drastically worsening affordability on a national basis, caused by decades of under-delivery. The Centre For Cities, for example, estimates that there is a backlog of approximately 4.3 million homes.1 We therefore regard the issues raised with the rigor of the Standard Method and its underpinning data to be largely trivial, technical points that do not undermine the validity of using the Standard Method generally, which is driven by the Government’s justifiable policy objective to build more houses. The above notwithstanding, the lower figures generated by the post-2014 household projections can be explained at least in part by lower household formation caused by a lack of housing availability. We acknowledge this is not the case across the board, however. For example, Lichfields states that the 2021 Census shows that despite Coventry have one of the highest rates of housing growth in the Midlands and the North between 2011 and 2021, its population growth was lower than expected which may support the argument that housing need in Coventry is over-stated. By that same token, Lichfields also states that Coventry remains one of the more affordable housing markets seeing only a modest worsening of its affordability ratio in the last decade, with a much lower increase in its affordability ratio than most of its neighbours.2 The conclusion to be drawn is that by “pulling up the drawbridge” and providing fewer homes than were previously anticipated across Warwickshire as a whole will result in worsening affordability, lower levels of homeownership and, potentially, suppressed population growth which will lead to more of the same. We do not consider this to be a desirable outcome.
We consider that in order for the SWLP to be positively prepared and legally compliant it must consider accommodating unmet need arising outside of South Warwickshire. We acknowledge that national planning policy and the law has the potential to change during the course of the SWLP’s preparation and for the Duty to Cooperate to be replaced with an “alignment policy.” However, there is no suggestion that the need for local authorities to address unmet needs should be removed generally and we would encourage the councils to continue dialogue and cooperation with their neighbours to address sub-regional issues including unmet hosuingneed arising from surrounding urban areas. Birmingham City Council has published a Local Plan Issues and Options Consultation document in October 2022, which identifies a shortfall of some 78,415 dwellings to 2042. Many of Birmingham’s neighbouring authorities such as the Black Country authorities are constrained by the Green Belt, extensive urban areas and have unmet needs of their own. It is clear that many of the areas with the closest functional relationship to Birmingham, including those within South Warwickshire, are also constrained by the Green Belt and we consider a robust Green Belt review in those areas to be key to accommodating unmet housing need across the wider sub-region. It is also unlikely that Coventry will be able to its housing need as identified in the Warwcikshirewide HEDNA noting that the adopted Coventry Local Plan identified a shortfall of some 22,000 dwellings to be met elsewhere. We would anticipate similar shortfalls arising over the period to 2050 and given the close functional relationship between South Warwickshire and Coventry we would expect a good proportion of the unmet need to be directed accordingly.
As to the location for accommodating the shortfalls from other areas we would note that the parts of the plan area closest to Coventry and Birmingham are within the Green Belt and also contain many of South Warwickshire’s most sustainable settlements. As such, a Green Belt review is fundamental to accommodating any identified shortfalls in a sustainable manner to the extent they reasonably can be.
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Issue E4: Sustaining a Rural Economy Q-E4.2: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land prefers Option E4.2a: Include a policy supporting small-scale employment opportunities in rural areas for the reasons given in the consultation paper. It will encourage the growth of small scale businesses in rural areas, support local communities, and reduce the need for many to travel. Issue E7: Core Opportunity Area and Major Investment Sites Q-E7.1: Please select the option which is most appropriate for South Warwickshire Rosconn Strategic Land prefers Option E7.1b: Do not include a policy directing employment to the Core Opportunity Area. The creation of a Core Opportunity Area may have a negative effect, taking potential businesses away from the District. Potential employers may see the policy as preventing economic development elsewhere, and it may unnecessarily raise land value in the Core Opportunity Area making it less affordable to smaller occupiers. Current employment policies are generally seen as successful but there needs to be more support for employment opportunities in rural areas which could cut commuting distances. Issue E10: Tourism Q-E10: Do you agree that Tourism should be addressed in Part 2 of the South Warwickshire Local Plan? Rosconn Strategic Land considers that a policy promoting and supporting tourism, which isan important element of the local economy, is an essential part of the emerging Local Plan. Rosconn Strategic Land would prefer the two authorities to prepare a single combined plan including all policies and covering all aspects of development.
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