Issue and Options 2023
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New searchQ-S1: Please select the option which is most appropriate for South Warwickshire Option S1b: Do not identify Green and Blue Corridors within the South Warwickshire Local Plan, and instead rely on the production of the Local Nature Recovery Strategy 2.16. While the Respondent does not object to the identification of Green and Blue Corridors in principle (in accordance with Paragraph 20 of the NPPF), they are not convinced that such designations can be robustly evidenced or justified in absence of the Councils’ Local Nature Recovery Strategy (LNRS). The Respondent would therefore err towards not identifying such areas at this stage. Q-S2: Please select all options which are appropriate for South Warwickshire Option 2c. Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. 2.17. Developers tend to err towards higher densities without the need for a planning policy requiring such. It is the inter-play of policy requirements and the input of stakeholders that tend to drive densities down rather than developer choice. 2.18. The Urban Capacity Study (October 2022), which forms part of the Issues and Options Evidence Base, identifies the biggest constraint to the maximisation of gross developable areas on sites as being the requirement to provide private and shared parking spaces (Urban Capacity Study, Section 3.3, Page 20). Should the Councils therefore wish to optimise densities, careful thought will need to be given to the implication of other policies and requirements on the ability for developers to build at higher densities. 2.19. With regard to Design Codes, while these can sometimes be helpful in providing clarity on the design approaches and standards that are likely to be acceptable, they are generally overly prescriptive and lack flexibility, which can do more harm than good from an urban design and density perspective. 2.20. Since developers tend to err towards maximising the efficiency of sites anyway, the preparation of a design code simply to support intensification would seem a disproportionate response to the issue at hand. It would be better if the Councils’ focus on the consideration of the wider implications of policies and standards contained in the plan which are known to drive densities down. Q-S3.1: Please add any comments you wish to make about the Urban Capacity Study. 2.21. The Urban Capacity Study identifies a potential baseline housing supply for the 2025-2050 plan period of 19,950 dwellings. Of this, 6,145 dwellings would be located within existing urban areas and the remainder located elsewhere (including new settlements). 2.22. The conclusion drawn at Section 4.6 of the Urban Capacity Study confirms that greenfield land must be released to meet South Warwickshire’s housing needs and states that: “….whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (Section 4.6, Page 37, own bold) 2.23. While the study indicates that the shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire this would seem highly unlikely given the significant programme of intervention and management that would be required for such capacity to be realised. The Respondent would also anticipate the likely yield from such sites to be considerably less than 3,400 dwellings and more likely towards the lower end of the range indicated (800 dwellings). 2.24. In the Respondent’s view, the inevitably of significant greenfield land being required adds considerably to the case for Green Belt release given that it is within the Green Belt that development can be most sustainably located. 2.25. It is agreed that to allow choice and competition in the market in accordance with National Planning Practice Guidance (NPPG) a buffer should be applied to the housing need as suggested in the Urban Capacity Study (Paragraph 4.6). Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. 2.26. While the Respondent recognises the importance of re-using Brownfield land, having considered the options presented in the Consultation Document, Option S3.2a is considered most appropriate in South Warwickshire, with Brownfield sites prioritised only where they are sustainably located and in line with the identified growth strategy. To do otherwise could result in unsustainable patterns of development that would conflict with the overarching vision and strategic objectives of the plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Y/N/DK 2.27. Yes. The Respondent agrees that growth of existing settlements should be part of the overall growth strategy for South Warwickshire. As opposed to new settlements, sustainable development at existing settlements has the benefit of being delivered without significant infrastructure investment and within a much shorter time frame. 2.28. Turning to Bishop’s Itchington, the Respondent’s site represents a sustainable and logical extension that is capable of being developed without technical impediment and would assist in supporting existing facilities and the vitality of the rural community in accordance with Paragraph 79 of the NPPF. Such matters are discussed in further detail in the site-specific representation at Section 3.0 of this Statement. Q-S5.2: Do you think new settlements should be part of the overall strategy? Y/N/DK 2.29. Broadly yes. The Respondent is generally supportive of the inclusion of new settlements in the overall growth strategy as they can be an effective way, at least in theory, of delivering new housing where there are barriers to the sustainable delivery of sufficient housing elsewhere. However, in reality, the physical implementation of new settlements is often complex and costly, which can significantly hamper their delivery. The Respondent would therefore caution against over reliance on new settlements in the preferred growth strategy. 2.30. Where new settlements are proposed the infrastructure requirements should be identified and robustly costed to ensure that delivery is viable. The Councils should also take a conservative approach regarding assumed capacity and likely build-out rates and avoid including housing completions from new settlements too early in the plan period. The Lichfield’s Start to Finish (Second Edition) 2020 report may be a helpful starting point in this regard, although any assumptions that are made will need to be fully evidenced having regard to site specific constraints and circumstances. 2.31. To improve choice and competition and help to mitigate the risk and implications of such sites not coming forward within the timescales envisaged it is recommended that a buffer is applied to the housing need, with a greater number of small-medium sites allocated at sustainable settlements to ensure adequate housing delivery in the short-medium term. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Y/N/DK 2.32. Yes. The Respondent considers it sensible to look to rail corridors as a preferred approach to the identification of potential locations. However, given the problems and delays that can often occur with the provision of new rail services and stations, it considered that the intensification of existing rail services should be considered before new ones. Q-S7.2: For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 2.33. Given the emphasis on mitigating the impacts of climate change and considering the evidence base prepared to date, the Respondent would agree that Option 2 (Rail and Bus Corridors) would appear to align best with the overall objective of mitigating the impacts of climate change and, on balance, considers this to be the most appropriate option for South Warwickshire. However, in the interests of maintaining the vitality of existing settlements there is also considered to be merit in Option 5 as a hybrid approach. 2.34. It is likely that even with Green Belt release the Councils will need to look beyond the initial list of settlements identified under Option 2 to meet South Warwickshire’s needs in full. On which basis it is recommended that the Councils also look to the next tier of settlements and locations, such as the Category 1 Service Villages identified in the Stratford-on-Avon Core Strategy (which includes Bishop’s Itchington). The benefit of such an approach being a more even distribution of housing across the plan period that strikes a better balance between prioritising development at the most sustainable settlements but also ensures the vitality of sustainable rural communities in accordance with Paragraph 79 of the NPPF. 2.35. For the avoidance of doubt, bearing in mind the accessibility of Bishops Itchington and the magnitude of the housing need to 2050 it is considered that the village could reasonably be included under any of the growth options as a potential location for new housing development (despite only currently being included under Options 5). Such matters are discussed in more detail in the site-specific representation at Section 3.0 of this Statement. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Y/N/DK 2.36. No. The sustainability of settlements falling outside of the chosen growth strategy will vary to a significant degree and should not therefore be treated as equal. 2.37. Settlements such as Bishop’s Itchington, which is defined as a Local Service Village under Policy CS15 of the current Stratford-on-Avon Core Strategy, have the potential to accommodate significantly more growth than is being suggested in the current Consultation Document and in the interests of maintaining the vitality and viability of such settlements should not be ignored in the development of a preferred strategy; particularly where they have a good range of facilities and access to public transport services. 2.38. Turning to Bishop’s Itchington specifically it is understood from the Bishop’s Itchington Neighbourhood Development Plan (BINDP) that 117 dwellings have been built in the parish and a further 370 approved in the period since 2011 against an indicative target of 112.5 new dwellings. It would therefore seem irrational, given the inherent sustainability, role and function of the settlement and the clear opportunities for further growth at the village that over the next 25 years development could be restricted to sites of 10 or fewer dwellings under the SWLP. 2.39. In the Respondent’s view, a comprehensive settlement audit should be undertaken for those settlements that fall outside the identified growth strategy to better understand their functionality and relative sustainability. The results of which can then be used to inform an appropriate distribution strategy across these settlements in a less arbitrary and more transparent way. To do otherwise would put at risk the vitality of such settlements in conflict with Paragraph 79 of the NPPF. 2.40. A site-specific representation in favour of the allocation of additional housing development at land off Station Road, Bishop’s Itchington is set out under Section 3.0 of this Statement. Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 2.41. Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. 2.42. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed under QP1.2.
2.43. Yes. Overall, the Respondent considers that the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, it should be noted that the level of future housing need stated in the HEDNA is a floor figure and does not include any unmet housing needs that may arise from other local authorities, which still needs to be established under the duty to cooperate. 2.44. In setting a housing requirement for the plan area it is suggested that the Councils look to allocate significantly more sites than may be required to meet the minimum housing need identified in the HEDNA to increase the supply of affordable housing and attempt to address the issue of affordability in both districts (discussed further under Question Q-H2-1 below). This could be reasonably achieved through the application of a reasonable buffer on top of the minimum housing need identified, which the Urban Capacity Study would also appear to recommend.
2.45. Fundamentally, the best way to increase the supply of affordable housing across South Warwickshire is to allocate more land for market housing (a proportion of which would be delivered as affordable). 2.46. The principal barrier to a housing development’s ability to deliver affordable housing is viability, which is particularly less assured on brownfield sites and in new settlement allocations hence why affordable housing provision is inevitably reduced on such sites. The Councils therefore need to carefully consider the impact of their preferred strategy, along with the financial implications that other policy requirements may have on the provision of affordable housing, for affordable housing provision to remain viable throughout the plan period and to boost supply. 2.47. While it is appreciated that building more houses does not necessarily bring the value of homes down, ensuring that more than enough land has been allocated to meet housing needs will greatly assist in the timely delivery of market housing which, assuming that other policy requirements are pitched correctly, will translate to the timely delivery of an increased quantum and range of affordable housing product.
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