Issue and Options 2023

1.0 INTRODUCTION 1.1 This submission is made on behalf of L&Q Estates, in relation to their interests at land east of Banbury Road, Southam (hereafter referred to as ‘the Site’). L&Q Estates welcome the opportunity to be involved in the preparation of the South Warwickshire Local Plan (SWLP), and it is within this context that they wish to make representations to the Regulation 18 Issues and Options Consultation. 1.2 On behalf of L&Q Estates, we have previously submitted the Site to the SWLP Scoping Consultation (2021) and the Site was submitted in response to the Call for Sites exercise in 2021. 1.3 The Site is shown outlined in red on Drawing Edp2535_d067c (Appendix 1) and is located to the southern edge of Southam. It extends to 11.68 ha (28.86 acres) and has potential to deliver a residential scheme of up to 200 dwellings, in addition to public open space, a community orchard and allotments. 1.4 The site is deliverable, available and suitable to deliver a high-quality residential development that will significantly assist in meeting South Warwickshire’s identified housing need as well as the unmet need from Coventry and from Greater Birmingham and the Black Country.

Yes

The Vision 2.1 We support the vision in principle, which seeks to create a prosperous, stronger and sustainable South Warwickshire. The vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8. Strategic Objectives 2.2 We are supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Stratford on Avon Core Strategy was adopted in 2016. We consider that the Site [land east of Banbury Road, Southam], which has the potential to deliver up to 200 new homes in Southam as well as significant open space, a community orchard and allotments in a sustainable location, would assist the South Warwickshire Authorities in achieving these objectives.

3.1 NPPF Paragraph 32 states: ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 3.2 It is noted that in the conclusion for the Sustainability Appraisal it states, at paragraph 7.15.11: ‘High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.’ [emphasis added] 3.3 Furthermore, the following technical assessments are currently being undertaken to help inform later stages of the plan: • Transport Assessment • Climate Change Impact Assessment • Biodiversity and Green Infrastructure Assessment • Landscape Character Assessment • Health Impact Assessment • Green Belt Study • Heritage Assessment 3.4 The Issues and Options SA is, by its own admission, heavily caveated and no mitigation has been considered. We therefore reserve the right to comment further at a later stage, once the Sustainability Assessment has advanced following the outcome of key evidence base documents.

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Issue S1: Green & Blue Corridors 3.5 As shown on the Vision Document (Appendix 2) and Illustrative Masterplan for Land east of Banbury Road, Southam, it is proposed to retain and enhance the majority of the existing landscape features, including hedgerows. The proposals will deliver a number of landscape benefits, including new Public Open Space, recreational routes and a community orchard. 3.6 SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall. 3.7 Therefore, the proposals for land east of Banbury Road, Southam demonstrate that green and blue infrastructure can be incorporated into development in many forms. It would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposals for the Site. Therefore, Option S1a would be preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined.

Yes

No answer given

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.8 Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 3.9 South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-on- Stour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. 3.10 Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements. 3.11 Southam is categorised as a ‘Main Rural Centre’ in Policy CS.15 of the adopted Stratfordon- Avon Core Strategy. The settlement hierarchy is defined below: 1. Main Town: Stratford-upon-Avon 2. Main Rural Centres (including Southam) 3. New Settlements 4. Local Service Villages 5. Large Rural Brownfield Sites 6. All other settlements 7. Local Needs Schemes 3.12 Therefore, Southam is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-upon-Avon district. 3.13 Southam town centre contains a range of shops, commercial activities such as banks, local services and facilities and pubs. Other services in the town include primary and secondary schools, a leisure centre, library, medical centres, police station and post office. There are good public transport services to the towns of Leamington Spa and Rugby, as well as community transport services that connect the town with nearby villages. 3.14 There is an established employment area on Kineton Road that provides a range of jobs. This has seen a significant expansion in recent years and comprises a traditional industrial estate. The town has been successful in attracting a number of large companies. 3.15 Paragraph 6.7.6 of the Core Strategy acknowledges that Southam functions as a service centre for much of the eastern part of the District, stating: ‘A large number of rural communities look to the town for their everyday needs. Some of these are quite sizeable, such as Harbury, Long Itchington, Napton and Stockton. Southam College strengthens the town’s role due to its extensive catchment which includes neighbouring parts of Rugby Borough.’ 3.16 Southam is one of the largest rural centres in the District and is a focal point of shops, services and jobs for a sizeable rural catchment. Indeed, paragraph 6.7.9 of the Core Strategy concludes that: ‘it is reasonable for the town to be considered suitable for additional housing and business development.’ 3.17 These paragraphs and conclusions remain broadly valid. It is consistent with national planning policy and basic sustainability principles to ensure that housing is focused in existing settlements, such as Southam, where there are existing services and where there is a need to ensure vitality. 3.18 Land east of Banbury Road, Southam immediately adjoins the built-up area boundary of Southam and existing residential development to the north and west. Southam has been subject to a number of residential planning applications. A residential development of 47 dwellings (LPA Ref. 14/00503/OUT and 16/02091/REM) has recently been constructed, filling in a square parcel of land to the immediate west of Land east of Banbury Road, Southam. Furthermore, an application for 236 residential properties (Ref. 13/00809/FUL) and redevelopment of Southam United Football Club to a community sports hub has extended the settlement boundary further south along the A423 Banbury Road, opposite the Site [land east of Banbury Road, Southam]. 3.19 The promotion site would reinforce the established built form at the southern edge of Southam and would form an enduring definition to the built-up area boundary. Indeed, the site is contained by hedgerows along its southern boundary which act as a green buffer and sensitive transition between the town and surrounding landscape. 3.20 The promotion site would be well connected to the built-up area of Southam and would constitute sustainable development. Indeed, it is considered that the new homes at Land east of Banbury Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Southam’s services and facilities. 3.21 Given the pressing need for additional housing within the Stratford-on-Avon District, Southam is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.

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Appropriate strategy

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Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 4.1 It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. 4.2 The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. 4.3 However, it is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. 4.4 For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). 4.5 Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. 4.6 We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 4.7 Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.