Issue and Options 2023
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New searchYes, MacMic Group consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities and MacMic Group consider it would be more appropriate to reference meeting unmet needs from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Greater Birmingham and Black Country Housing Market Area with a strong interrelationship and connectivity, and therefore should not be excluded.
The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF . 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. On the basis of the above, MacMic Group consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period, in accordance with the HEDNA and should therefore represent the minimum housing requirement for the SWLP. In relation to capacity, the UCS considers housing supply, including sites with planning permission and outstanding allocations without planning permission across South Warwickshire, and other sources of potential supply within the urban areas. As the UCS assumes a Plan period from 2025, it is only sites with planning permission and outstanding allocations without planning permission which are scheduled to deliver in the period from 2025 onwards in the respective Housing Trajectories (at April 2021) which are included within the supply. Given MacMic Group consider a more appropriate Plan period commencement date is 2022, and given the respective April 2022 Housing Trajectories are now available, 20,695 dwellings is considered the accurate figure to be incorporated (on account of taking into consideration an additional three years of supply). The UCS incorporates a non-implementation deduction to be applied to site with planning permission at 5%, which is considered appropriate. With regard to outstanding allocations without planning permission across South Warwickshire, a comprehensive review is required to ensure that such sites meet the definition of Developable as set out in the NPPF . One such outstanding allocation which requires review is Long Marston Airfield which is allocated in the adopted Stratford-on-Avon Core Strategy (July 2016) for circa 3,500 dwellings (2,100 in the Plan period to 2031) and associated development. There are known issues with the delivery of the south-western relief road required to support the delivery of the new settlement at Long Marston Airfield, which combined with other infrastructure requirements is likely to be mean there is a significant lead-in time before development commences. The UCS seeks to increase the level of supply on four outstanding allocations without planning permission in Warwick District at Kenilworth and Whitnash by 323 dwellings, however this is considered to be questionable. There is the potential for these outstanding allocations without planning permission to come forward delivering a higher number of dwellings than is set out in the adopted Warwick Local Plan (September 2017). However, until such a time as planning permission is granted, there is insufficient certainty to make assumptions around level of delivery. In addition, it is noted that the Warwick Housing Trajectory (at April 2022) already incorporates increases in projected delivery on some outstanding allocations without planning permission, and thus this could constitute double counting. The UCS also seeks to include within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas and are considered to be potentially suitable. It is noted that, to date, no formal assessment of these Call for Sites submissions has taken place in the emerging Housing and Economic Land Availability Assessment (HELAA). As such, the inclusion of these sites as potential supply in the UCS is unjust and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP. Further, the UCS identifies an additional five sites on vacant land in the urban areas across South Warwickshire which have not yet been submitted to the Call for Sites process, but are considered potentially suitable in the UCS for 328 dwellings. Clearly there is insufficient certainty around the availability and deliverability of these sites which brings into question their potential for residential development. Further, on assessment of these sites there are some serious concerns around the suitability of these sites in any case. One example is Jephson’s Farm which is located north of the railway and Griffin Road in Leamington Spa, and is identified in the UCS as potentially suitable with a capacity of 171 dwellings. This land forms one of the last remaining gaps between Leamington Spa and Warwick so development is unlikely to be desirable, and further the site is highly constrained by flood risk and access limitations. As such, these five sites should be removed from the potential supply in the UCS as no evidence of their availability or deliverability has been provided. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process, but are considered potentially suitable in the UCS, again raising concerns around availability and deliverability. Talisman Square is subject to a current planning application for 44 dwellings on a larger site than identified in the UCS, but Westgate House has no planning history. As such, the inclusion of these two sites as potential supply in the UCS is unjust, and these sites should be subject to formal assessment before being considered potentially suitable for allocation in the SWLP Finally, the UCS considers the level of windfall allowance to be included in the supply in the SWLP. An assessment is provided showing level of windfall allowance in the respective adopted Local Plans and level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the likely sources/types of windfall supply (based on past trends) nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is considered likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF .
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The SWLP Issues and Options consultation evidence base includes a Settlement Analysis which reviews existing settlement structures across South Warwickshire with a view to guiding future development, assessing connectivity, landforms, accessibility to local facilities and density. Kingswood is broken up into 12 Areas, with MacMic Group’s interest at Land at Station Lane, Kingswood forming a large proportion of Area 7. The assessment of Area 7 in the Settlement Analysis with associated commentary is provided below. Connectivity – Area 7 is graded B in recognition of its accessibility to key routes in the settlement, including Station Lane and the canal towpath. Area 7 is one of only four Areas in Kingswood graded B on connectivity, with the remainder achieving C, D or E. Landforms – Area 7 is clear of any constraints aside from Flood Zones 2 and 3 on the eastern boundary of the site, which can be appropriately avoided and indeed enhanced in bringing forward residential development on Land at Station Lane, Kingswood. Local Facilities – Area 7 scores 2 out of 5 with regard to accessibility to local facilities, being within 800m of categories: Places to Meet and Education. In terms of Retail, Jobs and Economy, it is recognised that Area 7 falls outside the 800m limit, however this is marginal with the convenience store, post office and other retail and employment generating uses falling around 850-900m of Area 7 and thus still considered generally accessible. With regard to Open Space, Leisure, Recreation – Wellbeing, the Concept Masterplan demonstrates how significant green infrastructure provision and associated access to the canal towpath is to be incorporated into the development. On Healthcare, it is recognised that Area 7 falls outside the 800m limit, however again this is marginal with the surgery falling within 1km and thus still considered generally accessible. Connections with local facilities are supported in the emerging Concept Masterplan through maximising existing links and providing additional accessibility where appropriate. Density – Kingswood is covered entirely by residential development classified as ‘Outer Suburb (approx. 20-40 dph)’. This has been taken account of in the emerging Concept Masterplan for Land at Station Lane, Kingswood, with residential development proposed at an average of 36 dph. In conclusion, Area 7 performs well in the Settlement Analysis for Kingswood, particularly with regard to Connectivity and Landforms. With regard to access to Local Facilities, whilst some of these fall outside of the 800m threshold, this is marginal and generally the range of facilities on offer in Kingswood are considered to be accessible. This will be supported through significant green infrastructure provision on Land at Station Lane, Kingswood, along with improved connectivity from the Site. The density mapping has been considered and is reflected in the Concept Masterplan for Land at Station Lane, Kingswood with residential development proposed at an average of 36 dph. MacMic Group consider that more weight should be afforded to accessibility to rail in the Settlement Analysis and indeed wider consideration of the development strategy and site selection.
MacMic Group are of the view that new settlements should not form part of the strategy for dealing with South Warwickshire’s development growth needs, due to concerns regarding lead-in terms, infrastructure requirements, viability and market attractiveness. However, the expansion of existing settlements where there are opportunities to capitalise on existing benefits that new settlements are striving for should be considered. This would need to be supported by the allocation of sites which are deliverable in the short-term in sustainable locations, such as adjacent to Kingswood. This will help maintain and enhance the vitality and sustainability of existing settlements and deliver the need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure within the towns and villages where such needs exist. With regard to the potential new settlement C1 south of Kingswood, it is considered that this site is too close to Lapworth Railway Station to warrant growth of 6,000 dwellings to facilitate a new Railway Station. Whilst potential new settlement C1 could come forward and deliver significant infrastructure including a Primary School and Secondary School, MacMic Group consider that a standalone new settlement south of Kingswood would not maximise the significant benefit that the existing Lapworth Railway Station has to offer. As such, MacMic Group consider that, should significant growth in this location be considered appropriate, the focus should be the existing settlement of Kingswood and a significant expansion of the village in order to maximise the offer of Lapworth Railway Station. This would allow the delivery of significant growth to meet the needs of South Warwickshire in a location well related to conurbation with unmet needs supported by the provision of significant new infrastructure, whilst maximising the potential and also sustaining the existing Lapworth Railway Station.
MacMic Group strongly agree with the proposal to review Green Belt boundaries, in order to ensure that the most sustainable growth strategy in South Warwickshire can be achieved. To avoid Green Belt release in the SWLP would limit the potential for growth of a number of South Warwickshire’s more sustainable settlements, including Kingswood. The SWLP should be supported by an up-to-date Green Belt Study which assesses individual land parcels and, in association with a development strategy which supports growth in the most sustainable locations including on the edge of sustainable settlements such as Kingswood, recommends removal of land currently within the Green Belt which least serves the five purposes of the Green Belt, and can define a defensible boundary.
Yes, the HEDNA evidence does provide a reasonable basis for identifying future levels of housing need across South Warwickshire. The provision of a sufficient level of housing growth in the SWLP is critical, in accordance with the NPPF. SWLP Issues and Options consultation evidence base includes the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). The HEDNA seeks to explore the housing and employment needs across Coventry and Warwickshire, and applies a trend-based approach to modelling housing need in order to establish the starting point for the respective Local Authorities in plan-making. The HEDNA applies the principles of the Standard Method calculation set out in national policy but utilises new demographic projections, supported by early data releases from the 2021 Census, to better reflect the needs of the respective and collective Local Authorities. The overall outcome for Coventry and Warwickshire is a decrease in annual housing need from 5,554 dwellings, derived from applying the Standard Method formula as set out in national policy, to 4,906 dwellings. Whilst there are decreases in annual housing need for some of the Local Authorities, and in particular Coventry (a considerable reduction from 3,188 dwellings per annum to 1,964 dwellings per annum), for South Warwickshire there is an overall increase. 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” . 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. Emerging Requirement and Capacity To summarise, MacMic Group consider that the basis for housing need in South Warwickshire should be the HENDA and that the Plan period should be assumed from 2022 onwards. As a result, MacMic Group consider the local housing need for the SWLP to be 47,012 dwellings over a 28 year plan period. In line with the NPPF , 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 guidance ; 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. 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 soundness , which is explored in further detail in response to Q-H4-1 below. With regard to capacity, MacMic Group consider that there are 14,360 dwellings with planning permission at 1st April 2022 which can be included as supply, applying a 5% lapse rate to the number of dwellings set out in the respective Housing Trajectories. There are also a further 5,579 dwellings on outstanding Local Plan allocations without planning permission which can be included in the supply, however it should be ensure that such sites can still be considered to be Developable in line with the NPPF . With regard to any windfall allowance, this should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF. Conclusion on Housing Requirement MacMic Group consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.
It is imperative that the 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 NPPF . It is recognised that national planning policy and legislation 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 imperative for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. MacMic Group consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Coventry and Warwickshire; and Greater Birmingham and Black Country. Coventry and Warwickshire 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 period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development outside the Green Belt. 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. 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 leaving a shortfall of some 22,000 dwellings to be met elsewhere. 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 releases , 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, as required by the still-extant Duty to Cooperate. Greater Birmingham and Black Country There are also significant unmet housing needs arising from the Greater Birmingham and Black Country Housing Market Area which require consideration. 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 – a shortfall of some 78,415 dwellings. 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 August to October 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. 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. The Councils will need to engage with Birmingham and the Black Country authorities to determine an appropriate level of unmet needs to be directed to South Warwickshire, but given the scale of such unmet needs and limited scope for such unmet needs to be met elsewhere, the importance of the SWLP taking account of this should not be underestimated. 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 MacMic Group consider this is likely to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process, as a working assumption for the level of unmet need to be accommodated, the figure should be at least 10,000 dwellings.
With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, MacMic Group consider that settlements with strong sustainable transport connections and a strong functional relationship to the conurbations where unmet housing needs are arising should be prioritised. This includes at Kingswood which has a strong functional relationship with the Greater Birmingham Housing Market Area, including benefiting from Lapworth Railway Station with direct connections to a number of urban conurbations including Birmingham, and a good highway network and is located within easy reach of the M42 and M40.
No, MacMic Group do not agree with the proposed approach. It is proposed that the SWLP will take the form of a Part 1 Local Plan to deal with the Vision and Strategic Objectives, Growth Strategy and Strategic Policies, followed up by a Part 2 Local Plan setting out detailed policies (in one or more Development Plan Documents) and Area Actions Plans. MacMic Group consider that this approach to plan-making in South Warwickshire is unnecessarily burdensome, and indeed likely to lead to greater uncertainty for stakeholders including local communities over a longer period of time. Whilst the production of a Part 1 Local Plan would initially support a more streamlined process to adoption, overall the time implications of producing a Part 1 Local Plan followed up by a Part 2 Local Plan are likely to be far more significant than the production of a single all-encompassing Local Plan. The implication of this is the potential for housing and employment growth in South Warwickshire to be inhibited, particularly as the SWLP is proposing to include the majority of strategic and non-strategic site allocations in the Part 2 Local Plan with only certain strategic site allocations and broad locations to be identified in the Part 1 Local Plan. This may result in the respective Councils not being able to demonstrate a positive Five Year Housing Land Supply position, and less sustainable sites than would otherwise be deemed appropriate for allocation may have to be looked upon favourably. MacMic Group raise specific concerns with how the SWLP is proposing to deal with Green Belt release, with suggestion in Tables 16 and 17 of the Issues and Options document that Green Belt boundaries will be amended in the Part 1 plan but non-strategic allocations saved for Part 2. This could lead to land being released from the Green Belt in Part 1, but non-strategic sites not allocated and thus not supported for development in principle until the Part 2 plan is adopted. This would be impractical given the basis for Green Belt release would be to allow sites currently in the Green Belt to come forward for development. Dealing with Green Belt release and non-strategic allocations in a single all-encompassing Local Plan would also support delivery of residential development in the early part of the SWLP period. As such, MacMic Group suggest that the Local Plan process being adopted by the SWLP is reconsidered, and a single all-encompassing Local Plan be produced from the outset.
