Issue and Options 2023

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Form ID: 79633
Respondent: Barratt David Wilson Homes (Mercia)

Whilst the question is not posed under Issue S6 (Green Belt), there is a need to undertake a review of the Green Belt in order to inform the consideration of where the most suitable and sustainable sites are located and, if within the Green Belt, which areas of Green Belt can be released without significantly impairing the functions of the Green Belt within South Warwickshire. The planning system must make land available in the right places and for the right forms of development. The undertaking of a Green Belt Review is an essential part of the process of making developable land available in the most sustainable locations. NPPF paragraph 142 highlights that when drawing up or reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. In establishing the housing requirements for an area, particularly if affordability concerns are to be addressed at larger settlements surrounded by Green Belt, Green Belt cannot currently be used as: the sole justification to direct development elsewhere; or as the sole justification to artificially suppress housing delivery; or the rationale for distributing housing to less sustainable locations. The 300,000 homes a year target set by the Government, and the subsequent response to the consultation on housing numbers in December 2020, identifies Coventry and Birmingham as being two key areas for housing growth to meet the target. South Warwickshire is adjacent to the Coventry City Council administrative area. Whilst the evidence base to underpin the new Coventry Local Plan is not yet available it is expected that Coventry City Council will be unable to meet its housing needs in full and a contribution to this unmet need should be a key part of the strategy for the SWLP from the start of the Local Plan-making process. BDWH has undertaken a review of environmental and technical considerations relating to the residential development opportunity that it is promoting to the north west of Warwick Parkway Railway Station. It is concluded that the proposed quantum of development can be accommodated within the existing landscape context, bolstered by additional landscape planting, to avoid significant harm arising. This is set out further in a Vision Document that is being submitted in support of these representations.

Form ID: 79634
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Form ID: 79635
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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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? Yes (for South Warwickshire) The NPPF (paragraph 61) identifies that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method, unless exceptional circumstances justify the use of an alternative approach. Such an alternative approach should reflect current and future demographic trends. It is acknowledged that the ONS has highlighted that the 2014-based household projections gave rise to inconsistencies with the resultant housing need figure for Coventry. The South Warwickshire Councils are in a Housing Market Area (HMA) with Coventry. In this context this current Local Plan review process provides an opportunity to consider what the need for Stratford on Avon and Warwick District Councils might be if more up to date household formation figures are taken into account within the HMA. It is understood that the HEDNA approach seeks to achieve this. Whilst the output from the HEDNA results in a slight lowering of the overall HMA need on a dwelling per annum basis, it is noted that the trend-based figures identified for Warwick and Stratford-on Avon Districts represent an increase over and above the standard method based equivalents. This is influenced by the high levels of net migration projected for these Districts within the HEDNA. It is accordingly considered to be a sensible and robust approach for the SWLP to be planning for, and identifying allocations to meet, this higher figure in order to ensure that there is a sufficient supply of homes coming forward in this area, as a minimum. Due regard should also be given through the Local Plan process to the opportunity to increase provision against this figure to both ensure that there is a sufficient supply and variety of housing sites to enable the Government’s aim of significantly boosting the supply of housing (NPPF paragraph 60) to be met, but to also ensure that the issue of housing affordability within this area is also appropriately addressed. It should also be recognised that the unmet need arising from Coventry will not be crystallised until further evidence base reporting is published by Coventry City Council on the capacity of land within its administrative boundaries. There may therefore be a need for the SWLP to allocate additional land to assist with meeting any unmet need for Coventry, with appropriate regard given to the opportunity provided by land on the edge of existing large sustainable settlements in the SWLP boundary to assist with achieving this.

Form ID: 79636
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

Getting this mix of homes right will maximise the beneficial impact that the delivery of more homes can bring. It is essential that a mix is not prescriptive and is flexible and it should be recognised that not doing so will result in a mix that becomes redundant over time and harm the social outcomes it was designed to achieve. This will especially be the case over a long plan period, where flexibility will enable the mix to be best tailored to the needs of new communities across South Warwickshire The SWLP, and any associated CIL charging, needs to reflect the fact that the contributions and provisions expected from development arising from planning policy requirements should not cumulatively undermine the deliverability of the Local Plan. Robust regard should be given to this through the Local Plan viability assessment work when this is carried out. The unintended consequence of overloading development with additional technical, design and financial requirements could be that the amount of affordable housing being delivered ends up being reduced in order to make a development viable. Furthermore, the supply of affordable housing, and the affordability of housing in general, is also influenced by the overall supply of housing coming forward. The SWLP should accordingly be seeking to plan for the delivery of more than the minimum number of homes identified by the HEDNA to assist with this

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Form ID: 79637
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Q-H2-2: Option H2-2B: Separate affordable housing requirements for Stratford-on-Avon and Warwick Districts Separate affordable housing requirements for each District are likely to go most of the way towards reflecting local requirements and local viability calculations. Some large scale zoning might be appropriate within each Council’s area.

Form ID: 79638
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Form ID: 79639
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Q-H3: Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. It should be noted that across South Warwickshire there is a strong demand for new homes and these sell, despite the adopted Local Plan provisions in force not including policy requirements which bring in these additional Technical Standards. There is therefore not considered to be a need to introduce such standards in order to deliver homes that meet market demand. 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 PPG4 identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards, the PPG5 states that 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. 4 Planning practice Guidance Paragraph: 020 Reference ID: 56-020-20150327. 5 Planning practice Guidance Paragraph:007 Reference ID: 56-007-20150327.

Form ID: 79640
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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The housing need within the Greater Birmingham and Black Country HMA is still under review, following the halting of the joint Black Country Local Plan. The Black Country authorities are currently reconsidering their housing needs and how this will impact on the wider HMA. In light of this, the significant housing shortfall identified by Birmingham City Council, and the likelihood that Coventry will not be able to accommodate all of its housing needs (even at the reduced trend-based level of 1,964 homes per annum), the South Warwickshire authorities will need to meet some of the unmet need from these areas. It is noted that page 109 of the Issues and Options consultation document highlights that 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, or close to good transport connections to these areas. Particular emphasis should be placed on locations for this development that have sustainable connections to employment opportunities across the HMAs. There is a need for the South Warwickshire Councils to continue to monitor the housing capacity studies being undertaken in the Birmingham and Black Country HMA and by Coventry City Council to assist with identifying what appropriate contributions it might need to make to assist with meeting the unmet need.

Links with Coventry City arise through commuting patterns, as well as the physical location of Warwick District on the edge of the Coventry built up area. The relationship with the Birmingham and Black Country HMA is intrinsically linked to the migration / commuting patterns. Good connectivity with the primary transport infrastructure in both instances is important, notably in relation to the sustainable travel infrastructure to provide access to the relevant, employment, leisure and community facilities both within this external HMA and within the SWLP area. Sites for housing development should be located where this can be achieved. The appropriate Growth Options would be Growth Option 1 and 2. As identified in response to Issue 6 (Green Belt) under QS-10, and in response to the identified spatial growth options, a spatial distribution strategy which capitalises on opportunities provided by the existing sustainable transport network, as well as providing good connectivity between homes and employment opportunities in main towns, is important. Locations that can achieve this through existing sustainability credentials, or can be made more sustainable through additional development should be considered for allocation. This should include appropriately located land in the Green Belt. In this regard, sites should be allocated in close proximity to existing railway stations (notably including Warwick Parkway) in order to deliver residential development to meet the needs of the SWLP and / or any additional unmet need arising from outside of the SWLP boundary.

Form ID: 79641
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Form ID: 79642
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Savills

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Q-H5: Option H5c is appropriate for meeting any requirement arising during the Local Plan period. The requirement for custom and self-build housing plots need to be determined on a case by case basis. The very nature of self and custom build housing means that it is difficult to plan for precise locations of delivery. Such requirements should be based on local evidence such as the self and custom build register and local eligibility test6. 6 National Planning Policy Framework: Paragraph 125.

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