Issue and Options 2023

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Q V3.1: Do you agree that the vision and strategic objectives are appropriate. Yes, IM Land agrees with and supports the overall vision and strategic objectives for the SWLP. In order to meet the ambitious vision set out in the Issues and Options document, it will be important to ensure growth is located in the most sustainable locations and aligns with the vision as closely as possible. This includes focusing growth around railway stations such as Earlswood (a point emphasised by NPPF para 105), as reflected in proposed option 1 (rail corridors) of the consultation paper. Whilst this option is supported, it is not clear why land off Rumbush Lane has not been considered as a reasonable alternative by the Sustainability Appraisal (SA), which we discuss further in response to Q I1 below.

As currently drafted the SA has not considered all reasonable alternatives (section 3), particularly in terms of ‘small settlements’ (section 5 and Appendix C) new settlement locations (section 6 and Appendix D). Land off Rumbush Lane, Earlswood has not been considered, despite its sustainability credentials and excellent location adjacent to Earlswood station. Based on the consultation document and the previously promoted scale of development, it would appear that the site has perhaps fallen between the ‘new settlements’ category of sites proposing a minimum of 6,000 new homes, and ‘smaller settlements’ comprising 50-500 homes. The plan provides no justification as to why sites between 500 and 6,000 new homes have not been considered, particularly as IM Land’s previous proposals for circa 750 new homes at the site is proportionally no more significant in terms of infrastructure requirements than sites for 500 homes. This is also despite the Council’s own evidence base, the Greater Birmingham and Black Country HMA (GBBCHMA) Strategic Growth Study (2017) (which we discuss further in response to Q S10 below) identifying the site as a broad area with the potential for a new settlement. Notwithstanding the above, IM Land’s proposals for the site are now 500 homes, therefore they would represent a ‘small settlement’. Going forward the Council must consider IM Land’s proposals as a reasonable alternative as a ‘small settlement’ proposition.

Appropriate strategy

Appropriate strategy

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Q S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: IM Land consider it would reasonable and logical to consider a range of growth options underpinning a blended spatial strategy, specifically due to the quantum of development that is required throughout the plan period. The level of growth proposed will require the plan to ‘turn on all taps of supply’ to ensure sufficient delivery in sustainable locations across the entire plan period. Land off Rumbush Lane, Earlswood logically falls within Option 1 (Rail Corridors) and Option 2 (Sustainable Travel), two options which should be included in any emerging spatial strategy. It is considered that locating development adjacent to railway stations can ensure that growth is focused on the most sustainable locations, where facilities and connections are already available. It represents an opportunity to maximise existing transport infrastructure and ensure there is a genuine choice of transport modes offered (NPPF para 104 and 105). It is expected that the SWLP area will not be able to meet its needs solely from brownfield or non-Green Belt land, therefore exceptional circumstances will be demonstrated to alter Green Belt boundaries to meet hosing needs. In this context NPPF para 138 states that:“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well-served by public transport”. Indeed the Councils’ own evidence base supports locating growth at land off Rumbush Lane, Earlswood. The GBBCHMA commissioned Strategic Growth Study (2017) identified opportunity areas where growth could be located to meet the housing needs of the wider HMA. An area ‘South of Birmingham’, a broad, non-specific area of land between Birmingham and Stratford upon Avon (location NS5) was identified as having potential for a new settlement. Land at Rumbush Lane, Earlswood is located within the ‘South of Birmingham’ opportunity area. It states that the methodology was “applied to rail corridors where there is sufficient land such that development would not result in the physical coalescence between the new settlement and an existing town”. Q S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire. M Land generally support the broad vision and strategic objectives for the distribution of development set out in the Issues and Options document. However, to meet this vision, it is important to ensure that growth is distributed towards the most sustainable locations. As per our response to Q S7.2, any spatial strategy must include Options 1 (Rail Corridors) and 2 (Sustainable Travel), as they represent appropriate locations for growth adjacent to existing railway stations. Land off Rumbush Lane, Earlswood is a sustainable, deliverable opportunity which fits within both options.

Yes

IM Land generally support the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. It will be important that the Coventry and Warwickshire Housing Market Area (CWHMA) authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.

IM Land considers that there is an opportunity to increase the overall housing requirement for the plan period to help deliver a higher amount of affordable housing. Table 8.45 of the HEDNA states that Warwick District and Stratford-on-Avon District have a combined affordable annual need of 1,386 dwellings per year, this is a significant need and would justify a higher overall housing requirement to ensure that sufficient affordable homes are being provided throughout the plan period. It is also relevant to note that constraints on the release of land for residential development, and in turn the provision of houses on that land (for sale or as affordable provision), can lead to increased house prices in an area. The Plan should therefore be focused on creating a policy environment that does not place undue constraints on sites that are allocated, thereby maintaining a supply that will in turn address issues of affordability.

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Warwick District and Stratford-on-Avon District should accommodate an appropriate proportion of the emerging GBBCHMA housing shortfall to 2040 and, once established, also accommodate an appropriate proportion of the emerging CWHMA housing shortfall. IM Land consider that that the approach to the previous CWHMA shortfall up to 2031 was dealt with successfully through the preparation of a Memorandum of Understanding (MoU) agreed upon by each of the authorities. The MoU agreed the housing need for each authority between 2011 and 2031 and that an unmet need of 17,800 homes arose from Coventry. The MoU agreed how this unmet need was to be split between the seven authorities based on functional relationships, commuting patterns and the balance of jobs. This approach enabled all the LPAs within the CWHMA to progress their Local Plans, with the last plan adopted in June 2019. In comparison, the approach to date by the GBBCHMA authorities has resulted in a substantial amount of Birmingham City Council’s shortfall identified in the 2017 Birmingham Development Plan (BDP) up to 2031, amounting to circa 6,000 homes remaining unaccounted for. Indeed, the current approach has impacted timescales for plan making elsewhere in the GBBCHMA. Since Birmingham’s plan was adopted in 2017 only one authority within the GBBCHMA has adopted a plan identifying any housing to meet Birmingham’s unmet needs – North Warwickshire in September 2021. The certainty provided by a strategy agreed early on by all authorities will therefore ensure that plan making can continue without delay across the GBBCHMA. This also needs to be considered in the context of unmet needs from other HMA authorities, including the Black Country. Although the Black Country Plan has now been abandoned, the most recent version of that plan established a shortfall of circa 28,000 homes up to 2039, this shortfall is robustly evidenced through the four councils’ Urban Capacity Study Update (December 2019) and tested through the WMCA Brownfield Land Study. This shortfall is based on brownfield delivery and includes Green Belt release. If there were to be no Green Belt release, the unmet need would total circa 39,000 homes. At this stage we do not intend to propose a model for how any unmet needs should be distributed, this is for the SWLP and HMA authorities (both CWHMA and GBBCHMA) to determine in due course, following a number of matters being resolved in the first instance. The Association of Black Country Authorities (ABCA) letter to the wider GBBCHMA authorities on 26 April 2022 sets out a very useful starting point for the GBBCHMA authorities in order to commence preparing a SoCG and it is considered that this approach would be suitable for the CWHMA too: • Reviewing the extent of the HMA in order to understand if it represents the most appropriate geography for considering unmet needs – this is pertinent given plans from outside the HMA (i.e., Shropshire and Stafford Borough) are offering contributions to the GBBCHMA’s unmet needs. • Confirm the scale of the housing shortfall across the entire HMA over a period of at least 15 years to inform the approach to be taken. This needs to consider the remaining unmet needs from other authorities, such as the Black Country, as it may be some of the unmet need has already been met by other GBBCHMA Councils. • Reviewing the 2018 Growth Study to understand if it remains appropriate and if there are new growth areas. This is likely to require a new study. • Review of governance arrangements between the GBBCHMA authorities in order to prepare a SoCG (an initial draft of which has been published as part of papers to Bromsgrove’s Full Council). Whilst reviewing the 2018 Growth Study would be a useful part of any SoCG evidence base, we are of the view this must be a fresh study that goes beyond the scope of the previous report and, similarly to the CWHMA and LLHMA’s approaches, consider a model for distributing the unmet needs that goes beyond identifying growth areas. This must include detailed analysis and consideration of other models used by other HMA geographies for distributing unmet needs.

The overall contribution to any shortfall should be based on functional relationships, for example with Warwick District and Coventry, and between Stratford and Birmingham. Once this principle has been determined, growth should then be located in the most sustainable locations within Warwick District and Stratford-on-Avon District. It is considered that by virtue of the functional relationships that exist at a strategic level, all key settlements and sustainable growth options will have strong links to the source of this shortfall.

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IM Land supports the Council’s overall goal of tackling climate change and achieving Net Zero Carbon. It is considered that directing growth to sustainable locations will assist the Councils in their endeavours to transition to a zero-carbon economy and would avoid the need for development to be brought forward in less sustainable locations elsewhere in the Districts. The 2019 Spring Statement included a commitment that by 2025 the Government will introduce a Future Homes Standard for new build homes to be future-proofed with low carbon heating and ‘world-leading levels of energy efficiency’. The Consultation document (October 2019) highlighted that changes to Part L, Part 6 and Part F of the Building Regulations are anticipated to come into force by mid/late 2020. The Future Buildings Standard consultation (January 2021), which relates to non-domestic buildings and existing dwellings, provided an update on the implementation of the changes to Part L, Part 6 and Part F of the Buildings Regulations will now come into force in 2021.Therefore, Building Regulations will require housebuilders to build more resilient homes to assist the Council in achieving their targets. Any policies that are contained in the Local Plan should be sufficiently flexible to allow for a continued evolution of these policies during the Plan period.

Yes

IM Land generally agree that the range of topics set out is appropriate for a strategic design policy. It is important to consider that a ‘well-designed place’ refers to the place as a whole, and should therefore include built form but also landscaping and planting.