Issue and Options 2023

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Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate? Subsequent to the 2021 Scoping Options consultation, St Philips supports the changes to the overarching vision in regard to making clearer the role of housing and jobs to play within South Warwickshire. St Philips also welcomes the acknowledgement of the need to accommodate the unmet needs of surrounding authorities as stated within the vision. This is considered to be legally compliant in accordance with National Planning Policy Framework (NPPF) paragraph 24 which states: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” As discussed in detail below, there is a large quantum of development required throughout South Warwickshire in order to meet both the social and economic needs of the administrative area as well as the neighbouring authorities, such as Coventry and Birmingham. Therefore, St Philips recommends that a suitable quantity of land should be assessed to ensure that the development needs can be met in the most sustainable locations. This would accord with NPPF paragraph 8b in terms of achieving the social objective of sustainable development, which states the following: “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; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. Additionally, in terms of the presumption in favour of sustainable development, NPPF paragraph 11b states that: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” In consideration, St Philips also supports the strategic objective that seeks to deliver the right quantity of homes in order to “meet the needs of all of our communities”. With regard to the Duty to Cooperate and the unmet needs identified within Birmingham and Coventry, St Philips considers that reference should also be made within this strategic objective towards meeting the unmet needs of neighbouring authorities. Although, it has been acknowledged and welcomed that the overarching vision makes reference to meeting the unmet needs within surrounding authorities.

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Q-S3.2 Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these St Philips considers that the SWAs priority should be to direct development to the most sustainable locations. St Philips recognises that the NPPF places emphasis on the need to make as much use of brownfield land as possible, with paragraph 119 stating that: “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” Paragraph 120 of the NPPF continues by stating that “Planning policies and decisions should: • give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land; and • promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively.” However, it should be noted that whilst the use of brownfield sites is emphasised, there is a need to consider the NPPF as a whole. Paragraph 11a of the NPPF is clear that “all plans should promote a sustainable pattern of development”. In this regard, whilst suitable brownfield sites will often naturally emerge as sustainable locations for development, it is possible for greenfield land to provide a more sustainable location for development than unsuitable brownfield land. St Philips also notes that the SWLP ‘Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its development needs solely through the use of previously developed land.1 Therefore, regardless of the approach taken by the SWLP, there will still be a need to identify significant amounts of suitable greenfield land for development. 2.10 In this context, St Philips believes the Councils approach should emphasise sustainability, rather than arbitrarily prioritising brownfield sites over more sustainable greenfield locations. St Philips would therefore support the effective reuse of brownfield land alongside the release of greenfield land in sustainable locations as directed by the Settlement Hierarchy or through the delivery of a new settlement (subject to consideration of the delivery of core facilities and accessibility). Q-S5.2 Do you think new settlements should be part of the overall strategy? Yes As stated, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 73). Importantly, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b), and should identify specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan (Para 68b). However, for a plan to be found ‘sound’, it must set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). 2.17 In this regard, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 68). 2.18 The Planning Practise Guidance (PPG) provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large scale developments can come forward. In particular, this should include a realistic assessment about the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales. 2.19 St Philips therefore does not consider that new settlements are the panacea for housing delivery. Whilst the proposed SWLP plan period would extend up to 2050, and conceivably enable sufficient time for a new settlement to fully deliver, there are still legitimate issues regarding this type of housing delivery and the evidence required to successfully underpin a proposed allocation – notwithstanding that SOADC secured the allocation of Long Marston Airfield. In this regard, St Philips welcomes the Issues and Options’ (IO) recognition that whilst new settlements can be an effective way of delivering housing growth, further detailed assessment of the identified potential new settlement locations is required. The IO rightly acknowledges that “there is the possibility once these detailed assessments have taken place and in light of any comments received to the Issues and Options consultation, none of the potential locations are deemed suitable” (IO, page 49). 2.20 It is particularly important that, where new settlements are intended to be a large proportion of areas housing needs, there should be a robust – and proportionate – evidence base demonstrating that the site is deliverable. In the absence of this, there is a very real risk that a Local Plan could be found ‘unsound’ at examination. 2.21 Indeed, the examination of the North Essex Authorities’ [NEA] Section 1 Local Plan highlights the above issues. In particular, to meet housing needs over the 2013-2033 plan period, it proposed the allocation of three garden communities. However, the Inspector concluded that two of these proposed settlements should be deleted in order for the plan to proceed as they weren’t deliverable, on viability and infrastructure grounds. 2.22 Furthermore, at the examination of Hart District Council’s ‘Hart Local Plan (Strategy and Sites) 2032’, the Inspector’s concern was that the new settlement was being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. The Inspector also noted that “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership” [IR63]. 2.23 In any event, the NPPF is clear that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed” (Para 60). As discussed, the NPPF emphasizes the importance of small-medium sites, stating that small and medium-sized sites can make an important contribution to meeting the housing requirement of an area, and are built out relatively quickly (Para 69). In this context, notwithstanding St Philips position on issues associated with pursuing New Settlements, the SWLP will need to allocate a variety of small-medium sized sites to deliver housing in the first 5-15 years of the plan period. Q-S7.2: For each growth option, please indicate whetheryou feel it is an appropriate strategy for South Warwickshire? The IO document states that development needs up until 2050 should be provided for within the most suitable and sustainable places. Key factors include the ability of new residents to integrate into existing communities with the ability to “access employment, education and the services they need; live healthy lives; and minimise dependence on the private car” (Page 57). In this context, the Issues and Options Consultation sets out five spatial Growth Options, comprising: a Option 1: Rail Corridors b Option 2: Sustainable Travel c Option 3: Economy d Option 4: Sustainable Travel and Economy e Option 5: Dispersed 2.25 The growth options listed above consists of individual but interconnected strategies which determine how much development will be directed towards the different settlements within South Warwickshire. The Issues and Options document states that “the strategy needs to be robust and flexible, in order to be of value for the whole plan period.” 2.26 In consideration of the above, St Philips believes that the spatial strategy must not entail a particular growth option (i.e. developing in close proximity of rail corridors). It is considered that the five growth options interconnect and in order to achieve the development needs within and beyond South Warwickshire up until 2050, a mix of options must be adopted. This would ensure a flexible and robust strategy that would disperse the benefits of growth between all of the settlements within the settlement hierarchy opposed to those that are considered to be the most sustainable in the eyes of a particular growth option. In this context, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across the area and align with the sustainability aspirations that are set out in the NPPF. 2.28 Some of the proposed spatial growth options have been brought forward from the Scoping Consultation, whilst others are hybrids of the previous options. St Philips considers that the current options should, in theory, allow the Issues and Options Consultation to consider how South Warwickshire could accommodate housing growth to meet its own housing needs, and a proportion of the C&WHMA and GBBHCMA’s unmet housing needs. 2.29 Nevertheless, St Philips considers that a mixed growth strategy, which combines severalgrowth options, will prove to be the best growth strategy for South Warwickshire. In this regard, St Philips notes that the ‘Sustainability Appraisal of the South Warwickshire Local Plan November 2022’ [“SA”] evaluates the 5 spatial growth options and concludes the following: “An overall best performing option is hard to identify. Option 5 is the worst performing option whilst Option 2 is likely to align most closely with development that will ultimately seek the most effective mitigation against climate change” (Para 7.15.2). The SA goes on to acknowledge that different options perform better for certain SA Objectives than others. St Philips also notes that the SA does not consider the potential for mitigation when evaluating the growth options, and that the scores are “strictly a guide and do not represent a diagnostic analysis” (Para 7.15.1). St Philips therefore considers that the SA is inconclusive regarding which of the growth options performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option. It is considered that the five growth options interconnect, and in order to achieve the development needs within and beyond South Warwickshire up until 2050 a mixed strategy should be adopted. This would ensure a flexible and robust approach that would disperse the benefits of growth between all settlements within the South Warwickshire. Regardless of which growth strategy the Council pursues, St Philips considers that some development will likely need to be dispersed to ensure that the entirety of South Warwickshire benefits from housing growth. This is acknowledged within the ‘Evolving the Spatial Growth Options Topic Paper August 2022’ which sets out how the 7 high level spatial growth options presented in the Scoping Consultation evolved into the 5 options presented within the IO. The Topic Paper acknowledges in relation to Option 5 that “even if this option were not taken forward, some limited growth might still need to occur in some smaller settlements to support the overall sustainability of these places” (Appendix 2). Therefore, although Option 5 does not perform comparatively well within the SA and Estimation of Emissions Study, St Philips considers that it will be necessary to disperse some growth to support the sustainability of smaller settlements. On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across South Warwickshire and aligns with the sustainability aspirations that are set out in the NPPF. Whilst greater levels of development may need to be focussed on sustainable transport corridors, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the Council to capitalise on opportunities presented by existing or planned infrastructure when considering options for large scale new residential developments, in accordance with paragraph 73a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent paragraphs 141 and 142 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well-served by public transport (Paragraph 142); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area close in proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions). However, whilst the IO Consultation notes that many locations feature in more than one option, St Philips is concerned that Hockley Heath has been excluded from all Growth Options, including Growth Option 5. Whilst it is noted that Hockley Heath predominantly falls within Solihull Metropolitan Borough Council’s [SMBCs] administrative area, the edge of the settlement falls within WDC’s administrative area. Moreover, Hockley Heath is of a similar size and scale to Bishops Tachbrook – which is included in Growth Option 5 – and offers a similar variety of services and facilities. It should therefore not be excluded from consideration. Whilst the settlement is located on the edge of WDC’s administrative boundary, its role within South Warwickshire’s approach to meeting the Greater Birmingham and Black Country Housing Market Area’s (GBBCHMA) and Coventry’s unmet housing needs should nevertheless not be disregarded. Whilst there is no ‘unmet need’ in spatial planning terms to be accommodated from this neighbouring local authority, Solihull is nevertheless a core part of the GBBCHMA. There is a strong and cogent argument to meet the unmet housing needs of neighbouring authorities in area in close proximity to where these unmet needs have arisen. Hockley Heath lends itself well to this approach. This is because the settlements on the edge of WDC and SMBC, by virtue of their location and links, are generally ‘Solihull-facing’, rather than ‘South Warwickshire-facing’ (e.g. residents will look to Solihull for higher-order shops, services and facilities, as well as commuting to Solihull for work). This serves to highlight that parts of the SWLP area, particularly along the edge of SMBC, have stronger and more direct links to Solihull, and that capitalising on these links to address the GBBCHMA’s unmet housing needs is an entirely logical spatial approach to meet this challenge. At present, the Issues and Option’s proposed approach to Growth Option 5 disregards the role that Solihull’s ‘higher-order’ services have for the residents of settlements along South Warwickshire’s boundary. It therefore does not give adequate consideration to potential allocations sited at the edge of Solihull which would be expected to perform relatively well against most key sustainability criteria – such as Hockley Heath. 2.37 In addition to growth option 5, St Philips considers that Hockley Heath should also be included within growth option 2 (sustainable travel) given the settlement’s strategic location in relation to the bus and rail transport networks. As stated within the IO, growth option 2 is a hybrid of the rail corridor and main bus corridor options presented in the 2021 Scoping Consultation. As stated within the IO, option 2 will support and build on the strengths of growth option 1 (rail corridors) whilst recognising that in many parts of South Warwickshire, bus travel is the only accessible and viable option of sustainable transport. 2.38 In this respect, Hockley Heath provides the opportunity to achieve development which is suitably positioned to support the strategic bus network and encourage the use of sustainable modes of transport. As acknowledged by South Warwickshire during the 2021 Scoping Options Consultation, one of the main bus corridors passes through Henley-inArden travelling north over the M40 and through Hockley Heath, providing further opportunity to access larger settlements such as Solihull. This is presented by the figure below: This demonstrates that Hockley Heath is suitably located to distribute growth around a ‘main bus corridor’ and encourage the use of sustainable modes of travel. Hockley Heath should therefore be given sufficient consideration for inclusion within Growth Option 2. Additionally, Dorridge Train Station can be accessed from Hockley Heath within 13 minutes via bike, 7 minutes via the A8 bus service and 5 minutes by car. Dorridge Train Station provides a direct route into Solihull (8 minutes) providing residents with suitable access to additional services, amenities, and employment opportunities. In consideration, Hockley Heath is well positioned in relation to both the strategic bus and rail networks strengthening the case for inclusion within Growth Option 2. In addition to Growth Option 5, Bishop’s Tachbrook is also listed as a potential settlement which can meet the requirements of Growth Option 2. As previously acknowledged, this settlement is of a similar scale to Hockley Heath and provides a similar mix of services and facilities. In this regard, Hockley Heath should not be disregarded from growth options 2 and 5. Indeed, the NPPF is clear that, “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” (Para 59). It is also clear that the supply of large numbers of new homes can often be best achieved through sustainable urban extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (Para 72). In this context, paragraph 78 of the NPPF also states that: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.” St Philips therefore considers that the development on the edge of Hockley Heath lends itself well to achieving these objectives discussed, particularly given the fact that the site is well-located in order for residents to access a range of key local amenities and facilities. In addition, the settlement is well positioned in terms of the strategic transport network being in close proximity of the M40 and the M42, as well as the strategic rail and bus networks offering an optimal opportunity for achieving sustainable development. Stratford Road, Hockley Heath 2.43 As set out in Section 1.0 of these representations, St Philips is promoting land at Stratford Road, Hockley Heath, for residential development. Whilst part of the site falls within SMBC’s administrative area, the majority of the site lies within the administrative boundary of WDC. The site comprises 30ha of land and is located directly to the north east of Hockley Heath, in the Green Belt. Aylesbury Road (B4101) lies to the south of the site and Stratford Road (A3400) to the west. Bus stops on Stratford and Aylesbury Road, provide regular bus services that provide connections to key regional destinations including Birmingham, Stratford upon Avon and Solihull. The settlement benefits from a range of key local amenities and facilities, including the Hockley Heath village centre convenience store, a Post Office, Dental Surgery and Primary School. Development Potential 2.44 In terms of development within rural areas, paragraph 79 of the NPPF states: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.” 2.45 St Philips wishes to confirm the site’s status as being ‘suitable, available and achievable’. The site could provide approximately 28.3 ha of residential development, equating to approximately 280 new homes. The Vision Document, submitted in support of the Call for Sites form, demonstrates that the site could deliver an urban extension to Hockley Heath, a sustainable location for growth. The proposed development will not extend beyond the limits of this current development, and can provide visual buffer planting along the northern site edge to create a defensible boundary. 2.46 St Philips considers that the site presents an excellent location to deliver up to 280 dwellings, including up to 112 affordable dwellings. The scheme would sensitively respond to its surroundings; this would include measures to enable the protection and enhancement of the strong Green Infrastructure network. Connectivity through the site and to the village and surroundings would be emphasised to encourage sustainable travel. Green Belt Performance 2.47 As noted above, the site falls within the designated Green Belt. The NPPF is clear that the assessment of whether a site should be removed from the Green Belt is subject to a site's performance against the five purposes of the Green Belt (Para 138). To inform the Vision Document, St Philips has undertaken this analysis. The Vision Document demonstrates the site’s performance as follows: 1 Purpose 1: to check the unrestricted sprawl of large built-up areas – There is existing development to the south of the site in the form of residential properties that form ribbon development along Aylesbury Road and Stratford Road. The proposed development will not extend beyond the limits of this current development, and will provide visual buffer planting along the northern site edge to create a defensible boundary. The release of the land would not cause unrestricted sprawl towards Dorridge or cause westward sprawl. The site would therefore not make a major contribution to Purpose 1; 2 Purpose 2: to prevent neighbouring towns merging into one another – The nearest neighbouring settlement to the site and Hockley Heath is Dorridge to the northeast. Although the development would extend Hockley Heath in this direction, the permanent physical features bounding the site would not cause the gap between Dorridge and Hockley Heath to be adversely compromised. Indeed, it would still be a distance of over 1km. As such, the release of the Site would not cause Hockley Heath to merge with Dorridge; and 3 Purpose 3: to assist in safeguarding the countryside from encroachment – The development of the wider site would be a natural extension to the existing built-up area of Hockley Heath and is contained by permanent physical features, which would prevent encroachment into the wider countryside. As such, the new and proposed Green Belt boundary would not cause significant encroachment into the countryside. 2.48 In summary, the site is in a lower-performing area of Green Belt land which does not significantly contribute to the purposes of the Green Belt. A new Green Belt boundary could be established that would provide a visual buffer along the northern site edge. As such, St Philips consider that the release of the site from the Green Belt would be suitable and would accord with the NPPF. 2.49 In addition to the above, St Philips note that the NPPF does not require only the release of sites which perform the worst against the Green Belt purposes (i.e. low Green Belt harm). There is a need to consider the broader Green Belt policies in the NPPF as a whole. In this context, when reviewing sites within the Green Belt, the SWAs should have regard to whether the site would contribute towards the promotion of sustainable patterns of development, whether it has good access to public transport, whether compensatory improvements could offset the harm from its removal (Para 142), and the consistency of the Green Belt with the emerging Local Plan strategy. It is, therefore, an essential part of the exceptional circumstances test that Green Belt land that fulfils poor to moderate Green Belt purposes can be released if it is consistent with the Local Plan strategy for meeting requirements for sustainable development, for example, to secure more sustainable patterns of development. 2.50 In this regard, the site is located on the edge of Hockley Heath, a settlement which provides a range of services and facilities, which is located c.5 miles from Solihull, with a regular bus service running through the settlement providing connections to both Solihull and Stratford upon Avon. As a part of the development proposals, it is envisaged that that the existing semi-natural habitats within the site would be retained and the open space and Country Park could be delivered. This provides opportunities to enhance local biodiversity. 2.51 In consideration of identifying a suitable quantity of sites for meeting the development needs of South Warwickshire and the wider area, St Philips acknowledges that the Issues and Options document states the following: “Future capacity will have regard to both identified and windfall sites, and work is ongoing to assess the sites submitted in the 2021 ‘Call for Sites’ exercise in order to consider their availability, suitability and deliverability as part of the Housing and Economic Land Availability Assessment (HELAA).” 2.52 The Issues and Options document continues by stating: “From this it will be possible to identify the supply of specific sites and broad locations between years 1-5, 6-10 and where possible later years of the plan.” 2.53 St Philips considers that land at Stratford Road, Hockley Heath is a suitable and sustainable option for housing development and urges the Council to consider this site for development. A Call for Sites form was submitted in regard to land at Stratford Road, Hockley Heath during the 2021 consultation and as already stated, St Philips would like to highlight the site as being achievable, deliverable and available within the upcoming plan period. 2.54 In essence, the site is a highly sustainable location for growth, with access to services and facilities and public transport. It is also well placed to meet the GBBCHMA’s unmet needs in close proximity to where they arise, given its proximity to Solihull. The delivery of environmental enhancements on-site, which would be achieved as part of the development, would ensure that any harm arising as a result of the removal of the site from the Green Belt could be offset.

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St Philips considers that the growth of existing settlements should form an important part of the overall strategy. The NPPF emphasises importance “on the need to support economic growth and productivity” (Para 81) and St Philips is concerned that overlooking existing settlements would constrain economic growth in these locations. The growth of existing settlements would support local services and facilities and would also direct development to sustainable locations in line with the NPPF (Para 11a). Existing settlements often have access to education, healthcare, retail, jobs, and public transport, and should therefore be considered as ideal locations for growth. 2.12 In this context, St Philips is promoting the land at Hockley Heath for residential development. Development on the edge of Hockley Heath lends itself well to achieving a proportion of the required development, particularly given the fact that the site is welllocated in order for residents to access a range of key local amenities and facilities. Additionally, Hockley Heath is well connected to the strategic transport network and is accessible via public and private methods of transport offering the opportunity to achieve sustainable development. 2.13 Whilst part of the site falls within SMBC’s administrative area, the majority of the site lies within the administrative boundary of WDC. In consideration, St Philips considers that directing growth towards Hockley Heath would be a suitable and sustainable strategy and would like to confirm the site’s status as being ‘suitable, available and achievable’. 2.14 Allocations that support the growth of Hockley Heath would be highly sustainable and would support existing local services and facilities. In this regard, the NPPF is clear that: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services” (Para 79). 2.15 St Philips therefore welcomes that the IO recognises the importance of considering the potential for growth around the edges of existing settlements, alongside or in combination with options such as new settlements. Whilst the NPPF recognises that “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements” (Para 72), it is equally clear that small-medium sized sites can make a valuable contribution to meeting the housing requirement of an area (Para 69). Therefore, regardless of whether a new settlement is pursued, the SWLP will need to allocate a variety of small-medium sized sites. St Philips considers that the proportionate growth of existing settlements will play a key role in fulfilling this requirement.

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The NPPF is clear that: 2.56 “Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” (Para 11b) (Emphasis added). 2.57 It also states that: 2.58 “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…” (Para 61) 2.59 In this context, it is noted that the 2021 Scoping Consultation set out the housing need context for the SWLP, highlighting that the SWLP housing requirement is underpinned by the Local Housing Need (LHN) figure generated by the Standard Method. For the SWLP area, on the whole, the Scoping Consultation stated that the SWLP will need to deliver a minimum of 1,230 new homes each year, or c.35,000 dwellings over the 30-year plan period. St Philips considers that the Council’s proposed strategy is acceptable in principle and that the deviation from the Standard Method is enabled by the NPPF and PPG. As acknowledged above, NPPF paragraph 61 states that the local housing need figure determines the minimum number of homes needed. Therefore, an uplift can be applied when supported by evidence. As acknowledged within the Issues and Options document, subsequent to the release of the 2014-based projection, based on more up-to-date assumptions about fertility, mortality and household formation rates, the Housing and Economic Development Needs Assessment (HEDNA) applied alternative projections through the framework provided by the standard method. St Philips considers this deviation to be acceptable in principle. Based off of the trend based projections as presented within the HEDNA, the overall housing need within South Warwickshire has increased when compared to the 2014-based projection from 1,239 dwellings per annum (dpa) to 1,679 dpa. In this instance, South Warwickshire will have to provide a greater supply of deliverable sites in order to meet this greater housing need. St Philips considers that the identification of a variety of suitable sites would accord with paragraph 60 of the NPPF which clearly states that: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” As stated above, the use of the HEDNA and the Council’s deviation from the Standard Method is acceptable in principle. As recognised by the Issues and Options Consultation, the standard method framework is the starting point for assessing the housing need. Both the NPPF3 and PPG4 are clear that the LHN figure generated by the standard method is a minimum starting point (i.e. actual housing need may be higher than this figure). Moreover, elsewhere in the guidance, the PPG differentiates between the minimum figure arrived at through the standard method and ‘actual’ housing need which can be higher. Although the HEDNA deviates from the LHN, it is highly likely that an additional uplift will be required as discussed in more detail within the response to question H4 below. It is ‘actual’ housing need that represents the objectively assessed need to which the tests in paragraph 11 of the NPPF apply, and there is also a requirement for the Council to test reasonable alternatives5. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing need. Fundamentally, this is because the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour, nor considers local factors, policy and aspiration which might legitimately mean the Council should seek to plan for more homes than the minimum. The PPG goes on to state that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs. In this regard, St Philips recommends that the SWLP should seek to deliver a greater number of dwellings over and above the housing need figure set out by the HEDNA. As discussed below, the substantial level of demand for affordable housing within South Warwickshire justifies an uplift to the objectively assessed need figure identified within the HEDNA in order to address the worsening affordability within the area. In the context of affordable housing, whilst the Standard Method includes an adjustment to take account of the median affordability ratio, the PPG7 is clear that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. In addition to addressing the affordable housing requirement within South Warwickshire, the scale of the unmet housing needs emerging from within the Coventry and Warwickshire Housing Market Area (C&WHMA) and GBBCHMA (c.78,000 dwellings) are likely to require an uplift to the housing need figure for South Warwickshire as identified by the HEDNA. The requirement to accommodate these needs is set out below within the response to question H4.

The NPPF is clear that: “the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing…)” (Para 62). 2.70 In this regard, the HEDNA sets out new trend-based projections for the sub-region. The HEDNA finds that Stratford-on-Avon will need to deliver a minimum of 868 dpa over the plan period, whilst Warwick will need to deliver 811 dpa. In relation to affordable housing, the HEDNA identifies a total affordable housing need of 547 dpa for Stratford-on-Avon and 839 dpa for Warwick (Table 8.45, HEDNA). The HEDNA is clear that the affordable housing figures should be used for reference purposes and that decisions about an appropriate mix for an individual area will be informed by viability and local priorities. 2.71 Issues regarding affordability are particularly acute within South Warwickshire, with the HEDNA noting “that the areas where the need for AHO [Affordable Home Ownership] is highest (notably Warwick and Stratford-on-Avon) also show a high need for rented affordable housing” (HEDNA, para 8.98). In light of this identified need, St Philips considers that an uplift to the LHN figure should be considered. 2.72 The PPG8 is clear that an increase in the total housing figures included in the plan could help address the affordability of homes, through the delivery of an increased number of affordable homes. It is likely that there will be a substantial level of demand for affordable housing within the area and that an uplift to the LHN figure to help deliver affordable housing would likely be justified, and necessary to addressing worsening affordability. St Philips therefore considers that this is the best approach to increasing the supply of affordable housing in South Warwickshire. 2.73 In regard to the approaches set out by the IO document, St Philips has no preference between Options H2-2a and H2-2b, however considers that Option HS-2c is not an appropriate response. Paragraph 34 of the NPPF is clear that: “Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure… Such policies should not undermine the deliverability of the plan.” As the IO recognises, localised affordable housing requirements can create uncertainty, making it more difficult for developers to predict their costs and harder for Councils to predict delivery of affordable houses. This could undermine the SWLPs ability to deliver on affordable housing targets. St Philips therefore considers that Option Hs-2c should not be considered as it would not significantly increase the supply of affordable housing within South Warwickshire, and indeed, could negatively affect its provision.

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Q-H3: Please select all options which are appropriate for South Warwickshire. The Issues and Options document states that the Council has acknowledged, through public engagement, the request for minimum internal space standards to be applied through a local plan policy. In addition, St Philips notes that it was agreed in response to a Notice of Motion to Council in Warwick District, that the principle of incorporating Nationally Described Space Standards (NDSS) within the SWLP would be considered (see Cabinet meeting for 29 September 2022, Item 09). It is stated within the Issues and Options document that this would be considered as part of the Local Plan Review process. St Philips recognises the importance of including design-based policies within the Local Plan Review in order to enhance the existing character of the District and provide a good quality of life for current and future residents. It is important to note Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” Furthermore, NPPF paragraph 31 states that all policies should be “underpinned by relevant and up-to-date evidence”. In addition, the PPG9 sets out: 2.79 “Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of need, viability and timing”. 2.80 In consideration of the above, St Philips advises South Warwickshire that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. Therefore, it is recommended that the Council should complete further evidence gathering prior to including a policy. Additionally, it is important to note that any policy requirement would also need to be considered and tested through a viability assessment before adoption. This would ensure that the approach is supported and justified by up to date evidence and that the approach can be found to be legally compliant with both the NPPF and the PPG.

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St Philips welcomes South Warwickshire’s acknowledgement of the need to help meet the unmet needs of the C&WHMA and the GBBCHMA. The IO states: “South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. However, South Warwickshire is also within the Birmingham and Black Country HMA… Through the duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs” (page 111). 2.87 In this regard, St Philips notes that within the GBBCHMA there is emerging evidence of an acute level of unmet housing needs. Birmingham City Councils New Local Plan 2020-2042- Issues and Options (“BCCIO”) has recently confirmed that, as of March 2022, Birmingham’s LHN figure is 7,136 dpa (Para 4.7). This includes an additional 35% for the top 20 largest cities in the UK. 2.88 Cumulatively, this would equate to a housing need figure of 149,286 dwellings for the 22-year plan period (2022 to 2042). The BCCIO states that the Council can currently demonstrate a supply of 70,871 dwellings, which includes completions between 2020/21- 2021/22 of 6,624 dwellings. The BCCIO concludes that, at present, there is a shortfall of around 78,415 dwellings to be found through the preparation of the BDP Review (Para 4.15). 2.89 Alongside Birmingham’s emerging unmet needs (c.78,000), another significant source of potential unmet needs is from within the Black Country. It is important to note that the Black Country Plan is no longer being jointly prepared and thus the Black Country Authorities will now prepare individual Local Plans; however, it is highly likely that the unmet need for housing c.28,000 dwellings still remains in the Black Country; albeit, now disaggregated amongst the four Black Country Authorities. As such, the level of unmet housing needs in the GBBCHMA is likely to be severe. St Philips acknowledges that Coventry’s need has been reduced from 3,188 dpa as per the 2014-based projection to 1,964 dpa as per the trend-based projection. Although, it is important to note that an updated housing trajectory has not yet been released for Coventry meaning that the unmet need is yet to be calculated. It is highly likely that South Warwickshire will need to accommodate part of this unmet housing need. Given that Coventry has a very small amount of land that is outside of the urban area and free from constraints (equating to c.2% of the authority’s area) St Philips consider that it is extremely likely that Coventry will require further assistance in meeting its housing needs post-2031. 2.91 In this context, paragraph 11b of the NPPF is clear that: “b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: (i) the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” 2.1 In this regard, the IO recognises that “given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas” (Page 109). The exception to this is noted to be areas within the Green Belt, however these sites would only be considered if suitable, appropriate, and necessary. St Philips considers that areas like South Warwickshire with such a large quantum of available land have a duty to support housing growth and not only address its housing need, but also the shortfall of housing provision within surrounding authority areas. 2.2 Whilst St Philips acknowledges that it is not for South Warwickshire to address these unmet needs in full, given the scale of the shortfall arising from the GBBCHMA, St Philips considers that South Warwickshire must play a significant role. It is important that South Warwickshire makes it clear that it will help address the acute unmet need and should, where possible, be specific in the exact proportion of the unmet need that the upcoming Local Plan can accommodate. 2.3 Indeed, this is particularly pertinent, given the Inspector’s recent findings11 in respect of the Sevenoaks Local Plan where problems of unmet need were not adequately addressed through the duty to cooperate process, resulting in a terminal failure of legal compliance. Unless a proportionate contribution towards the unmet needs identified is accommodated, South Warwickshire risks not fulfilling its ‘duty to cooperate’ with neighbouring authorities, as required by paragraph 24 of the NPPF. St Philips supports South Warwickshire’s acknowledgement of the Duty to Cooperate but also recommends that a proportionate contribution should be made to ensure that the emerging Local Plan can pass the test of soundness. St Philips consider that a functional relationship approach is a suitable strategy and refers to Lichfields’ ‘The Black Country’s next top model’. Lichfields’ model drew on the precedent set in the Coventry and Warwickshire HMA/North Warwickshire and has been again supported by the emerging approach in the Leicester and Leicestershire HMA. Both Stafford Borough Council and South Staffordshire Council reflected on Lichfields’ model in the latest sustainability appraisals for the current consultations, St Philips therefore encourages South Warwickshire to adopt Lichfield’s model in order to sustainably distribute Birmingham’s and Coventry’s unmet housing need. 2.5 The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. 2.6 Such a model takes account of the below trends within the HMA and between authorities with a functional relationship: 1 Migration patterns between authorities; 2 Commuting linkages between authorities; 3 Opportunities to capitalise on sustainable transport links; 4 Affordability pressures; and 5 The degree of environmental and physical constraints. 2.7 The objective should be to create an agreed position with regard to the spatial distribution of housing that is justified based upon technical evidence and which can be used to underpin the preparation of Local Plans. 2.8 This would ensure that as and when a spatial distribution methodology is agreed, South Warwickshire will have in place a sufficient supply of sites which have been tested through an acceptable model and other evidence base documents.

As set out above, St Philips considers that it is imperative that the SWLP assists with meeting the acute housing needs of South Warwickshire’s neighbouring authorities. Given the scale of the unmet need, St Philips considers that there is a need to review the Green Belt within the district. In this context, St Philips welcomes the IO’s recognition that: “A review of the Green Belt across South Warwickshire is an important piece of evidence to underpin the approach taken in the Local Plan. It would consider whether there are any areas which no longer meet all five of the Green Belt purposes and could be removed to allow for the most sustainable development to come forward, including the provision of affordable housing and employment opportunities.” (IO, page 57). 2.10 St Philips is highly supportive that the IOs approach has been ‘blind’ to whether a particular location or corridor is in the Green Belt. This approach ensures that sustainable locations within the Green Belt are not prematurely excluded from consideration. The IO recognises that: “The location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated” (page 56). 2.11 Notwithstanding the above, St Philips acknowledges that the NPPF is clear of the weight attached to the Green Belt by the Government, and that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.” (Para 140). The NPPF sets out that prior to considering whether “exceptional circumstances” exist, local planning authorities should have “demonstrated that it has examined fully all other reasonable options for meeting its identified need for development” and goes onto provide a set of criteria that should be satisfied prior to establishing exceptional circumstances (e.g. a sequential approach of sorts) (Para 141). These include (inter alia) the optimisation of brownfield land, densities and discussions with neighbouring authorities. 2.12 In this regard, the Urban Capacity Study (October 2022) “has established that it is unlikely to be possible to meet currently development needs without significant greenfield development” (Urban Capacity Study, Page 1). There is also a significant, and persistent level of unmet housing need across the GBBCHMA and many of the Council’s neighbouring authorities are already unable to meet their own needs within existing urban areas. 2.13 In establishing the “exceptional circumstances” required to review the Green Belt, St Philips consider that the Council should also have regard to the acuteness of the unmet housing needs within the GBBCHMA, which might reasonably be considered an ‘exceptional circumstance’. Indeed, in the Calverton Parish Council v Nottingham City Council High Court Judgment12, the Judge pointed to the acuteness of the objectively assessed housing needs when considering whether housing need should be considered an exceptional circumstance (Para 51). 2.14 As such, St Philips considers that the acuteness of the unmet housing need arising from the Birmingham HMA can, and in this instance, should, constitute exceptional circumstances, as established in the Calverton case. It is therefore entirely reasonable, and indeed necessary, for the Council to review the Green Belt within the District, to help meet the needs of South Warwickshire and its surrounding neighbouring authorities.