Issue and Options 2023

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Form ID: 85833
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

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Form ID: 85834
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

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Form ID: 85835
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

No

Form ID: 85836
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

Q-E10: No. As mentioned in the previous Knight Frank response (ref. 2102), tourism plays an important role for South Warwickshire and is integral for the vitality of town centres and is therefore a strategically important policy. Policies should be included to support tourism linked development that will enhance the provision and vitality of other services on offer. This should include additional support for the provision of additional guest accommodation in appropriate locations, as this will contribute to strengthening the economy. Furthermore, the NPPF paras 84 and 85 support the role of sustainable rural tourism and leisure development that benefits businesses in rural areas, communities and visitors, and which respect the character of the countryside. Therefore, supporting policies for facilities linked to tourism, including guest accommodation, should be included in Part 1. Q-E11: Delivering economic growth is a priority for the government and local authorities and is a core objective of the NPPF. Policies should develop a clear economic vision and understand the requirements for employment space. The local plan should adopt a flexible approach in terms of employment uses to be able to consider current market trends and requirements.

Form ID: 85837
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

Yes

Yes. The HEDNA is considered to accord with NPPF para 61, whereby it provides evidence that exceptional circumstances justify the use of an alternative approach (trend-based) to determine the minimum number of homes needed, rather than utilising the 2014-based household projections due to its evident inconsistencies with the resulting housing need figure for Coventry. Given that the South Warwickshire councils share a Housing Market Area (HMA) with Coventry and the neighbouring councils North Warwickshire, Nuneaton and Bedworth and Rugby, the South Warwickshire Local Plan provides an opportunity to consider the local housing needs in consideration of the up-to-date household figures within the HMA. It is noted that the trend-based figures identified in the HEDNA result in a higher local housing need than the standard method based on the 2014 household projections. The council should ensure that a sufficient supply of housing sites, including affordable, is provided, in line with the Government’s aim of significantly boosting the housing land supply in accordance with NPPF para 60. However, consideration should be given to the unmet needs from Birmingham, given the overlap of the HMA with the Birmingham HMA, Further evidence should be provided to understand the population movements and projections within the wider housing market. The Greater Birmingham HMA Strategic Growth Study (GL Hearn, February 2018), which built on the Birmingham Strategic Growth Study 2 Report (PBA 2014) and Strategic Housing Needs Study (PBA, 2015), notes that Birmingham’s functional HMA extends to include the Black Country, parts of Worcestershire, Staffordshire and Warwickshire, which is also confirmed within the 2022 Birmingham HEDNA. The Birmingham HMA includes part of Stratford-on-Avon district and given the overlap between Birmingham and Coventry/Warwickshire HMA. NPPF (2021) para 61 states that “any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”. It is therefore considered essential that the joint evidence provided from neighbouring authorities within overlapping HMAs should be taken into account when making provision to meet the wider HMA housing needs. The HEDNA should therefore be expanded to consider the wider HMA. In particular, the assumed split of in-migration from the overlapping Birmingham HMA, based on past trends, should be considered. The Birmingham HEDNA demonstrates that on average, there were between approximately 7,000 to 10,500 net moves per annum from Birmingham to the wider HMA between 2015 to 2020. Therefore, additional evidence should be provided to take account of internal migration flows from Birmingham. The Birmingham HMA Strategic Growth Study states that the evidence points to a baseline / minimum level of housing need for 205,000 to 264,600 homes from 2011 to 2031 and between 256,000 and 310,000 to 2036 (2011 baseline) in the Birmingham HMA, which extends into Warwickshire. The report notes that Stratford-on-Avon is contributing 2,020 dwellings to 2031, extending to 3,600 until 2036 if measured on a pro-rata basis. With consideration of the land supply to 2031 (179,829) and 2036 (197,618), the minimum shortfall in the HMA to 2031 and 2036 is 28,150 and 60,855 respectively. The report notes that Stratford’s Core S trategy is making provision for 5,440 dwellings to meet unmet needs of other areas, of which 50% contributes to meeting unmet needs in the Coventry and Warwickshire HMA and Birmingham HMA respectively. The evidence provided, particularly the trend-based approach based on 2021 projections, as opposed to the 2014 projections, appears to provide a reasonable basis in light of the evident issues with Coventry based figures. However, a further analysis of the wider housing market area (HMA), including the Birmingham HMA, and the likely movements from the wider HMA into Stratford-on-Avon and Warwick is necessary to address the local housing need. Additionally, given that evidence of Coventry’s level of unmet need may not be available within the timescales of the South Warwickshire local plan process, there may be a need for the provision of additional housing land supply to ensure the unmet needs from Coventry can be met. It is understood that the South Warwickshire Councils are currently engaging with Birmingham City Council to seek agreement on a Memorandum of Understanding to ensure that unmet needs can be met. We would welcome the agreement to form part of the evidence base for the next stage in the local plan to provide certainty of the local housing needs. We expect that South Warwickshire will need to take on some of the unmet needs of the Birmingham HMA, given their significant shortfall.

Form ID: 85838
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

As mentioned in the previous Knight Frank response (ref. 2102), principal contributions to affordable stock arise predominantly through the delivery of greenfield sites. In particular, large-scale mixed-use developments, such as the proposed site at Copham’s Hill, Stratford-upon-Avon (ref. ID 385), are best placed to provide an important amount of affordable housing. Therefore, positively worded supporting policies would likely lead to an increase in affordable housing. Local planning authorities can also improve the delivery of affordable housing through the creative use of their own resources, including land within its ownership and working effectively with other providers of affordable stock. Consideration should be given to alternative approaches such as the conversion of existing stock or vacant housing, further accelerating the delivery of social and intermediate housing. The provision of affordable housing should not exceed the technical housing standards, particularly the set national standards (Nationally Described Space Standards).

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No answer given

Form ID: 85839
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

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Form ID: 85840
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

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Q-H3: It should be noted that NPPF footnote 49 states that policies may also make use of the nationally described space standard (NDSS), where the need for an internal space standard can be justified. In relation to the NDSS the PPG (Paragraph: 020 Reference ID: 56-020-20150327) identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards the PPG (Paragraph: 007 Reference ID: 56-007-20150327) there is a need for LPAs to give regard to: the likely future need for housing for older and disabled people (including wheelchair user dwellings); size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes); the accessibility and adaptability of existing housing stock; how needs vary across different housing tenures; and the overall impact on viability. The evidence base needs to be made available to clearly justify inclusion of these additional technical standards.

Form ID: 85841
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

Yes

The local plan needs to seek to accommodate some unmet need from the Birmingham and Black Country HMA. However, as noted in Q.H1.1, further evidence should be provided relating to migration within or between HMAs, particularly movements from Birmingham to more rural areas within South Warwickshire. The unmet needs arising from within Birmingham should be agreed via a Memorandum of Understanding and allocations made to meet the unmet needs within Part 1 of the Local Plan dealing with strategic policies. 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, or close to good transport connections to these areas. Particular emphasis should be placed on locations for development to service the needs of Birmingham and Coventry that have sustainable connections to these cities. If South Warwickshire are to accept a substantial shortfall arising from within Birmingham and the Black Country, then there should be an expectation that those local authorities have accommodated growth within the Green Belt falling within their own administrative areas.

Additional housing to meet the shortfalls from neighbouring authorities should be located on public transport corridors, i.e. Growth Options 1 (rail corridors) and 2 (sustainable travel) in order that residents of the new housing can utilise existing sustainable transport options to commute to work. The Greater Birmingham HMA (GL Hearn, 2018) includes three sites within Stratford-on-Avon within its area of search for potential sites, one of which is directly related to Stratford-upon-Avon. In consideration of the rail infrastructure between Stratford-upon-Avon and Birmingham City, the site a Copham’s Hill, Stratford-upon-Avon, is one such site that can deliver sustainable housing that would contribute to the shortfalls.

Form ID: 85842
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

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