Issue and Options 2023

Q-S7.2: Refined Spatial Growth Options 36. HLM consider a mixture of options will be required to best deliver the growth needs of South Warwickshire for the reasons as set out below. 37. Firstly, the results of the high level testing of the five growth options in the supporting Sustainability Appraisal demonstrates that the options perform differently in different areas, with no one option standing out as the best performing option across all areas. 38. Secondly, it is important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 39. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below), this is unlikely to be met sustainably or efficiently through a single growth strategy. 40. HLM also have the following comments on the Options. 41. HLM query why growth at Southam does not appear in the Sustainable Travel (2) Option. As a town with a population of over 8,000, and a sizeable employment area, the town should continue to receive investment in high quality public transport connections to Royal Leamington Spa, Coventry, Rugby, and Daventry. The frequency and quality of services can be improved with investment and increased patronage that strategic growth can deliver. 42. If the aim for the Plan is to deliver a well-connected South Warwickshire, then a town the size of Southam needs to have investment in its public transport connections to 2050. Q-S10: Other Development Strategy Issues 43. More generally, Southam was identified in the Sustainability Appraisal to the adopted Core Strategy as the most appropriate location for additional strategic growth amongst the Main Rural Centres based on the availability of suitable sites, lack of overriding infrastructure constraints, and the opportunity to support the existing facilities provided in the town. To deny any further growth of Southam in the SWLP to 2050, would not be consistent with the adopted Core Strategy or provisions of the NPPF. 44. HLM have set out a Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions and be more climate responsive. This Vision can sit within and inform a wider Vision for the area, and HLM would be happy to meet to discuss this further with the Councils.

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46. Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, HLM reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. 47. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”4. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. 48. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. 49. As set out in the appended South Warwickshire Housing Need Evidence Base Review Technical Report commissioned by HLM, whilst HLM support the housing need figures for South Warwickshire set out in the HEDNA, HLM have some concerns with the approach taken in the HEDNA to economic growth and affordable housing need. 50. On economic growth, whilst HLM agree with the demographic modelling assumptions used to calculate economic-led housing need in the HEDNA, the job growth assumptions require updating for the following reasons:  The 2022 HEDNA’s Cambridge Econometrics (CE) job forecast is outdated (March 2021) and was generated during strict Covid-19 measures in the UK;  CE are a robust source of job forecasts but a more recent forecast should be used;  Assumed GDP informing the HEDNA’s job growth forecasts has now been shown to be an underestimate of growth by the Office for National Statistics;  The higher GDP for 2021 and 2022 indicates job growth forecasts would be higher than those used by the HEDNA;  Furthermore, job growth experienced in Warwick District and Stratford-on-Avon District during 2011 to 2019 significantly exceeded the CE forecast used to calculate economic-led housing need for the 2022-2043 period;  It is unclear from the HEDNA whether economic growth on a number of sites within South Warwickshire are taken account of by the CE baseline projections. If not, these developments should be taken account of;  The Council should consider job growth forecasts from Oxford Economics and Experian Economics alongside those from the CE. 51. HLM also consider that the significant level of unmet affordable housing needs across South Warwickshire should be taken into account in determining the housing requirement. The submitted analysis finds that the minimum housing need would be 1,609 dwellings per annum in Stratford-on-Avon District and 2,872 dwellings per annum to meet affordable housing needs based on past net delivery. Whilst it is recognised that this is significantly greater than the level of housing need set out in the HEDNA and is possibly unsustainable to deliver, this should influence the housing requirement through an appropriate uplift. 52. The enclosed analysis should be given consideration as the SWLP emerges, to ensure a sufficient level of housing is planned for across South Warwickshire. 53. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. 54. On the basis of the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. 55. In line with the NPPF5, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance6; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. 56. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness7, which is explored in further detail in response to Issue H4 below. 57. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, HLM consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings. Table – SWLP Housing Requirement and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years) --- 47,012 dwellings Uplift to Minimum Housing Need --- TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country --- TBC – engagement with Birmingham/Black Country and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement --- 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied) --- 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022 --- 5,579 dwellings Windfall Allowance --- TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply --- 24,779 dwellings Indicative Housing Requirement to be found by the Plan --- 43,000 dwellings + 4 Paragraph 61 of the National Planning Policy Framework (July 2021) 5 Paragraph 61 of the National Planning Policy Framework (July 2021) 6 Paragraph 010 Reference ID 2a-010-20201216 of National Guidance 7 Paragraph 35 a) of the National Planning Policy Framework (July 2021)

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58. It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF8. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. 59. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country 60. There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. 61. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. 62. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. 63. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. 64. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. 65. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above HLM consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire 66. Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. 67. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. 68. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. 69. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases9, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated. 8 Paragraph 35 a) of the National Planning Policy Framework (July 2021)

70. With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Southam. 9 How the population changed where you live, Census 2021 - ONS https://www.ons.gov.uk/visualisations/censuspopulationchange/

Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure is within the towns and villages. Those needs are best met sustainably adjacent to the larger sustainable settlements.

Yes, growth of existing settlements in South Warwickshire is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure are all generated within the existing settlements. Those needs are best met sustainably adjacent to the settlements, rather than in new settlements.

Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure are all generated within the existing settlements. Those needs are best met sustainably adjacent to the settlements, rather than in new settlements.

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Vision 2.2 In overall terms the suggested Vision is unobjectionable. However, some minor redrafting would strengthen it as a statement of intent: The vision is to meet South Warwickshire’s development needs to 2050 in a sustainable manner and responding to climate change. The local plan will ensure that sufficient homes are built for current and future residents and land is provided for new jobs to boost and diversify the local economy, in suitable locations, at the right time. New infrastructure will be provided to support new growth. 2.3 The five overarching principles are equally unobjectionable when seen in the context of the Vision as a whole and the supporting strategic objectives. Strategic Objectives 2.4 The Strategic Objectives are important in providing a greater level of understanding as to how the Vision will be delivered. In other words, what is the practical effect of having this Vision. 2.5 We agree with the breadth of the Strategic Objectives and in particular those associated with “Meeting South Warwickshire’s Sustainable Development Needs”. 2.6 This will require planning policies and proposals that ensure a sufficient number and range of homes are provided to meet the needs of present and future generations. In this context Sustainability Objective 9 concerning Housing is important. Where policies and proposals are shown to contribute a positive beneficial effect, these should be cornerstones of the Local Plan. 2.7 This is particularly germane to considerations as to the overall amount of new housing to be provided and where in the plan area which we discuss in later sections of our response.

South Warwickshire’s Development Requirements 3.2 We agree with the premise that the Local Plan’s primary role is to promote a sustainable pattern of development that seeks to meet the needs of South Warwickshire, align growth and infrastructure, improve the environment, mitigate climate change and adapt to its effects. 3.3 This inevitably requires a number of considerations to be balanced alongside and together in order to arrive at an overall strategy and plan. This will include a degree of prioritisation and choice. It is symptomatic of this stage of the plan making process that the overall strategy is dependent on the selection of individual sites and vice versa; in other words this is an iterative process. 3.4 However, this needs to be guided by high level principles; a commitment at the outset to provide sufficient land for the overall amount of new development that is forecast, a spatial strategy that is aimed at achieving the most sustainable pattern of development; and avoiding and minimizing unacceptable environmental effects whilst achieving environmental benefits wherever possible. 3.5 Our representations have been prepared in this context, albeit we comment specifically in relation to the scale of housing required in response to Matter 5. Development Distribution Strategy for South Warwickshire 3.6 A fundamental part of the Local Plan will be to ensure that the future development requirements are distributed in a manner that achieves the most sustainable pattern of development. This concept has different interpretations and requires a balanced approach, but the underlying premise of situating new development at and adjacent to the main urban areas must be the starting point in order to capitalize to the fullest extent on the sustainable pattern of development this will achieve. 3.7 It is an unavoidable fact that the main settlements in the plan area – Stratford-upon-Avon, Leamington Spa, Warwick – are those locations that have services and facilities commensurate with their role and function. In hierarchical terms, these settlements are pre-eminent locations. This is borne out by the evidence of the Spatial Options background paper and the Sustainability Appraisal. In this regard, only Stratford-upon-Avon features as a settlement consistent with each of the Spatial Options. 3.8 It is evident that the favored spatial options are those that afford a priority to accessibility to services and facilities, enabling movement by active travel and public transport, and supporting economic growth, whilst protecting areas with important environmental attributes. In effect this points towards a blended strategy, or the hybrid strategy referred to in the consultation document. 3.9 The consultation document refers to this approach as providing a balance of growth at existing main settlements, some growth at new settlement scale on the rail lines, and more modest growth in smaller settlements, which can contribute to enhancing the viability of village centres and provide affordable housing. 3.10 In developing this blended spatial strategy to guide the location of new development, it is unarguable that Stratford-upon-Avon will be a cornerstone of whatever strategy is chosen. In this regard, the fundamental objective is to ensure Stratford-upon-Avon best contributes to the overall strategy. To achieve this requires the overall contribution of development land at Stratford-upon-Avon to be the building block in the first instance so that, as a suitable location, it can maximise its influence on the blended strategy that effectively follows. 3.11 This approach would have the following benefits: - Align with the objective of reducing carbon emissions; the greater the degree of concentration at main settlements the lesser the carbon emissions (Figure 2 refers); - Capitalise on the availability of services and facilities and the promotion of active travel; - Contribute to the vitality and viability of the town centre; - Support labour supply in the “Core Opportunity Area” in the context of an ageing population overall; - Maintain the West Midlands Green Belt in the north of the plan area; - Limit development in the Area of Outstanding Natural Beauty in the south of the Plan area - Avoid the negative effects of the dispersal strategy illustrated in the Sustainability Appraisal (Table 7.1 refers) 3.12 A strategy that promotes large scale development adjacent to Stratford-upon-Avon’s existing urban area could also achieve a commensurate scale of nature based solutions and investment in renewable and low carbon energy generation to mitigate the effects of and adapt to climate change. 3.13 Whilst the blended strategy described above refers to new settlements, as a matter of approach, this can only represent part of a development strategy in the longer term; experience from elsewhere in the country suggests lead in times from policy formulation to development and build out being a great many years. As such, a new settlement cannot represent a means of meeting short and medium term needs. This Option would inevitably need to be complementary to development at existing settlements which are suitable in the first instance as a matter of principle. Direction of growth at Stratford-upon-Avon – the South East of the town 3.14 In the preceding paragraphs we have set out how the spatial strategy should afford a role to Stratford-upon-Avon as a focus for new development. Although there is no consultation question in relation to directions of growth at Stratford-upon-Avon, the evidence base is particularly instructive as to the advantages of development to the south-east of the town. 3.15 The Evaluation of Broad Locations in the Sustainability Appraisal alights upon this location as the best performing of those around the town. It is the most suitable in terms: - Planning for anticipated levels of climate change (i.e., flood risk) - Protecting, enhancing and managing the quality and character of landscapes and townscapes; - Mitigating adverse impacts from existing air, water, soil and noise pollution and avoiding generating further pollution; and 3.16 The graphic overleaf illustrates the inescapable relative overall and “strong” performance of this location. [see submission document for graphic] Accessibility and Permeability 3.17 The Settlement Analysis similarity affords a positive view of south east of the town. In terms of permeability or conversely the absence of barriers to integration, none of the town’s urban edges are Categorised as A, so whilst areas 6, 7, 8 and 9 in the south east of the Town, which correspond to Trinity Way and Banbury Road, are Categorised as B, this is the highest ranking across the settlement as a whole. 3.18 In conjunction with a permeable edge, three of these four locations score the highest in terms of accessibility to services and facilities within 800m. Whilst a small number of locations exhibit this degree of accessibility, none of the other urban edges around the Town achieve a combination score of B and 5 together. In these terms, areas 7, 8 and 9 in the south east area are especially well related, and perform better than the area of land (6) identified as a proposed allocation in the Stratford-on-Avon Site Allocations DPD. Heritage 3.19 Of note from the written analysis is that the eastern area is said to have heritage constraints that reduce its performance for this environmental consideration. However, what is referenced is East Tiddington Roman Settlement which is some distance away from the likely development areas centred on Trinity Way and Banbury Road, and would not represent a genuine constraint to new development in those locations. 3.20 The Heritage Sensitivity Assessment records on page 198 the following in relation to the south east part of the town: This area runs from the southern edge of Tiddington round to the eastern side of Shipston Road. Extensive modern development on the western side means that the historic core is less sensitive to change in this area. A single group of Listed Buildings are located at Alveston Hill Farm and their rural setting would need to be considered in any development. However, this area may be able to accommodate development. 3.21 In the RAG analysis that follows the following points are made alongside a green score: The south east area only contains a single group of designated assets and does not impinge on any of the conservation area boundaries. The rural setting of these designated assets will need to be considered in any planning proposals. This area may be able to accommodate development.” 3.22 The diagrams on page 201 and 202 of the Heritage Sensitivity Assessment illustrate the comparative extent of designated and undesignated heritage assets around the town, with relatively few located in the south east. 3.23 For all of these reasons a considered view of the south eastern area indicates that cultural heritage is not a constraint to new development in the location. Landscape 3.24 We note that a Landscape Assessment for the plan area as a whole is being prepared and is not available at the present time. We expect such an assessment to acknowledge that land south of Trinity Way is not designated for its landscape or historic importance; it does not fall within a Special Landscape Area, or Conservation Area and; it does not form the setting of any listed buildings. 3.25 The character of Stratford-upon-Avon, to the south east of the town, is suburban, comprising post war housing with some modern infill. The interface between the urban and rural area is typically abrupt, with existing housing turning its back to Trinity Way behind hedge and fenced boundaries. Whilst the Site itself is not unattractive, it is not considered to be remarkable or exceptional. The field structure is poorly defined, the edge of the town exerts an urbanising influence over the area, and its intensive arable uses result in a site with a medium aesthetic appeal and/or amenity value. Green Belt 3.26 We recognise that certain of the assessment work has been undertaken with a “policy off” position applied to the Green Belt designation that extends long the northern edge of the town. However, Green Belt policy in the NPPF only permits the amendment of the Green Belt where exceptional circumstances exist (para 140 refers). For exceptional circumstances to be justified, it is necessary to examine fully all other options for meeting the identified need for development. This requires an assessment of Green Belt and non-Green Belt locations. 3.27 In this instance, development to the south-east of the town can be seen to perform better than Green Belt locations and, on this basis, the exceptional circumstances would not be justified. In the context of the great importance afforded to Green Belt, locations subject to that designation would need to exhibit characteristics that are materially better than non Green Belt locations in order to be preferred as future development locations. That plainly is not the case at Stratford-upon-Avon and those non Green Belt locations should form the identified allocations in the first instance.

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Providing the right number of new homes 4.2 Stratford-on-Avon and Warwick are the least affordable areas in the Coventry and Warwickshire sub-area.1 It is imperative therefore that this characteristic is attributed a particular importance in determining the right number of new homes to be provided. The affordability problem will simply be compounded if the Local Plan provides too few houses, either by a deliberate policy choice not to meet the objectively assessed level of housing need in full at the outset, or by an embedded housing land strategy that isn’t sufficiently robust to ensure those needs are met. 4.3 It is instructive that the Housing and Employment Development Needs Assessment has illustrated that a higher housing requirement is generated for Stratford-on-Avon and Warwick in the context of the evidenced demographic characteristics. These factors and the associated analysis is described in section 5 of the HEDNA. 4.4 The effect of this analysis is to identify an overall housing requirement for the Local Plan area greater than that derived from the output of the Government’s Standard Method. This is shown in Table 9 of the consultation document and summarised below: --------------------------------- Standard Method 2014 based household projections --- Standard Method using revised demographic projections Stratford-on-Avon (dpa)---564---------------------------------------------------------------------868 Warwick (dpa)---------------674---------------------------------------------------------------------811 Plan Area (dpa)-------------1238-------------------------------------------------------------------1679 Plan Area (25 years)------30,950-----------------------------------------------------------------41,975 4.5 We agree with the view expressed in the consultation document that “whilst it may be tempting to want to apply the 2014-based figures because they are lower for South Warwickshire, given that Coventry looks unable to accommodate all of its own housing needs, it would most likely fall to South Warwickshire to accommodate a significant quantum of that need. The outcome would then most likely be similar levels of housing as shown in the 10-year trend-based projection”. It would be wrong therefore to develop a Local Plan that was not based on the scale of housing which the adjusted figures above imply. On this basis, the housing requirement should be the higher of the two figures suggested above. 4.6 Based on the evidence of potential existing housing supply in the Urban Capacity study this would suggest a residual need for some 22,000 new homes to be provided over the plan period. 4.7 In this regard, if in due course the housing number is for some reason considered to be less, the Local Plan would simply have identified a strategy and associated supply of housing land that would endure for several more years after the end date of the plan. No disadvantage arises from this because it is inevitable logic that the need for development land wont simply cease at 2050. Consultation on the NPPF 4.8 We are aware that the Government are currently consulting on potential revisions to the NPPF which concern, inter alia, the approach to meeting housing needs. In our view, none of those potential alterations represent a fundamental change to the plan making process in this instance. 4.9 It remains the case that the cornerstone of the planning system is to contribute to the achievement of sustainable development, including the provision of homes and other forms of development, including supporting infrastructure in a sustainable manner (§2). 4.10 The social dimension of sustainable development is still as drafted previously: to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations. 5 Summary 5.1 This response to the South Warwickshire Local Plan Issues and Options has been prepared on behalf of Hallam Land Management Limited. 5.2 We have identified that, irrespective of the current consultation relating to the NPPF, it is firmly the case that Local Plans should continue to provide a sufficient supply of housing land to meet identified needs. In this regard, we agree that the housing requirement should be based on the HEDNA exercise which indicates a need over the plan period of some 40,000 new homes. 5.3 Based on the evidence of potential existing housing supply this would suggest a residual need for some 22,000 new homes to be provided over the plan period. This is going to require new land allocations. Having already prioritised previously developed land, the allocation of greenfield land is a legitimate proposition in order to meet the identified needs. If follows that the Spatial Strategy will need to guide those new land allocations to sustainable locations. 5.4 The Spatial Strategy is likely to require a hybrid approach which directs new development to those locations which are the most accessible, which are commensurate with existing centres that have an established range of services and facilities and where future economic growth is likely to be greatest. This approach clearly favours new development being directed to Stratford-upon-Avon, which was the only settlement to appear in each of the Options considered. 5.5 Although there is no consultation question in relation to directions of growth at Stratford-upon-Avon, the evidence base is particularly instructive as to the advantages of development to the south-east of the town. 5.6 The accompanying submission regarding the land controlled by Hallam Land Management Limited at Trinity Way illustrates further the many advantages of new development in this location. 5.7 In preparing the next version of the Local Plan, we would propose that land at Trinity Way is allocated for a housing-led mixed use development. 1 Table 5.1 of the HEDNA