Issue and Options 2023
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New searchThe South Warwickshire Urban Capacity Study is a useful document that confirms the indicative capacity of the settlements within the plan area. However, its conclusions must be treated with caution. In the first instance, it should not be assumed that all brownfield sites within the existing settlements could be brought forward for residential development. A number of these sites may be better suited for alternative uses such as employment or retail. l. In addition, a number of brownfield sites may not be suitable for residential development on viability grounds, or will be unable to support a “normal” S.106 package and result in reduced contributions towards affordable housing. This could be exacerbated by the introduction of NDSS standard housing and the other requirements of the emerging plan. Furthermore, the study does not consider the capacity of existing infrastructure to accommodate development, for example education and health. There may be infrastructure constraints that prevent some sites being developed, or a lack of service and facilities nearby that make sites unsustainable locations for residential development. There is currently insufficient information available to establish the role brownfield sites can play in help meeting the Plan’s housing requirement. If there is evidence to suggest that there are specific sites that warrant an allocation in the emerging plan, that is an appropriate approach. However, all other opportunities of this nature should be treated as windfall sites and included in the Plan’s windfall allowance.
We support the identification of Salford Priors in the Settlement Analysis. It is a sustainable location capable of accommodating housing allocations in the SWLP.
Q-S5.2: New settlements that require a complete infrastructure package will take several years to deliver following adoption of the SWLP. They must, therefore, be supplemented by other allocations, especially for the early delivery of new homes. Q-S5.3: Growth Option 1 – Rail Corridors, is an effective Growth Option that will enable South Warwickshire to both deliver new housing and which will meet the SWLP’s sustainability aspirations. Its effectiveness in delivering sustainable development would be enhanced when considered in combination with other growth scenarios, including bus services and the provision of employment. Development is required at the larger villages in the Plan area, such as Salford Priors, to meet their growth requirements and to support their services and facilities. Q-S9: If reviewing the settlement boundaries is delayed until the part two plan it will stifle housing delivery in sustainable locations to the detriment of the plan’s strategy. As a consequence, any part one plan should clearly indicate the settlements that will be expected to accommodate additional growth and a broad indication of the level of the growth.
Paragraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance, unless exceptional circumstances justify an alternative approach which reflects current and future demographic trends and market signals. In addition to the local housing needs figure, 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. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts are 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868dpa are required in Stratford-on-Avon and 811dpa in Warwick District. Therefore moving towards a trends based approach would seem appropriate. In terms of the approach for the HEDNA, it is noted that Table 8.13 – Estimated Need for Social/Affordable Rented Housing by Local Authority, identifies a net annual need for 419 affordable dwellings in Stratford-on-Avon and 582 affordable dwellings in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. The PPG advises, at paragraph 2a-024, that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments. However, it is not realistic to generally expect housing allocations to deliver 67% or 52% affordable housing. There is, therefore, the possibility that there will be a shortfall of affordable housing provision during the course of the plan period. One way to overcome this would be to increase the total housing figures included in the SWLP Consideration should, therefore, be given to uplift the housing requirement to ensure that an appropriate amount of affordable housing can be provided.
The most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above.
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Q-H3: The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that at this point in the plan process the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy.
