Issue and Options 2023
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New search2.2.2 1.4 of the I&O documents states that: “Part 1 of the Plan will establish a robust and flexible framework which will set out where and how much development should take place across South Warwickshire.” At present the strategy (and associated optioneering) appears too focused on the main towns and needs to include other settlements within the plan area – reflecting the polycentric nature of both districts, in order to ensure that rural communities, equally with urban communities, can become more sustainable in the future. 2.2.3 As noted above, Paragraph 11 of the NPPF highlights the need for plans to promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. To comply with paragraph 11 of the NPPF, the SWLP needs to provide a comprehensive spatial strategy that seeks to: meet the development needs of the whole area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. In relation to the spatial strategy the I&O document is too limited in scope and overly focused on the main towns. It is also crucial that the Part 1 Plan provides a coherent strategy for LP2s and updates to Neighbourhood Plans, rather than leaving it to Part 2 Plans to establish the strategy. The Adopted Stratford Core Strategy states (quoting the former Commission for Rural Communities: “Our challenge is to chart a course by which rural communities, equally with urban communities, can become more sustainable in the future”.
2.2.4 Question P2.1 asks if there are any areas where equality and inclusivity in planning needs further attention. We suggest that this is the case for rural communities where issues such as housing affordability should be addressed via a clear spatial strategy that provides for the needs of rural areas as well as for urban areas.
Green belt considerations 2.2.7 It is noted that the I&O document states at page 58 that, at this stage, the spatial growth options are presented with Green Belt policy “off.” 2.2.8 The vision and spatial objectives should be clear that the principle of the Green Belt remains, and it will continue to shape new development, especially with regard to its fundamental aim of preventing urban sprawl by keeping land permanently open (NPPF paragraph 137). The key purposes of preventing sprawl and merging of settlements (NPPF paragraph138) is a critical issue on the fringes of the Greater Birmingham conurbation and Coventry. Paragraph 141 of the NPPF states: “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.” (emphasis added) 2.2.9 The sequential approach to the consideration of locations for growth should also be reflected in the evaluation of the growth options. This applies to consideration of sites for need arising within the districts and any shortfall arising from outside of South Warwickshire (referenced at QH4-3). Any future consideration of spatial options should therefore include a Green Belt policy “on” appraisal.
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2.3.1 The housing and employment needs that the SWLP needs to respond to should be clearly set out in future consultations. The I&O document is heavily focused on the results of previous consultations (which could have been reported on separately to help focus the main document on the proposed content of the Local Plan) and the spatial strategy. The I&O document puts forward some potential options for growth but does not set this within the context of how much additional growth needs to be accommodated to supplement existing commitments– including the potential for a significant amount of growth arising from the Greater Birmingham and Black Country Housing Market Area (HMA), over the period 2031 to 2050. Future needs from Coventry will also need addressing. Any consultation about how best to meet needs is potentially premature when the scale and origin of that need, allowing for existing commitments, is not clearly set out.
2.4.1 The Urban Capacity Study (Arup, October 2022) includes consideration of windfalls as a source of supply for housing across the plan area. The proposed windfall allowance is based on historic trends and suggests that 4,480 dwellings could come forward between 2028 and 2050. Additional information is required to ensure that assumptions associated with windfall rates are robust. 2.4.2 Paragraph 71 of the NPPF notes: “Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.” 2.4.3 It is considered that in order to comply with Paragraph 71 of the NPPF authorities must provide additional evidence in relation to the sources of supply that windfalls will come from over the plan period, trend data may not be appropriate if historic sources of supply are coming to an end. This observation is consistent with the recommendation from Arup’s review of SHLAAs undertaken in 2019 in Greater Nottingham. The review highlighted the NPPF’s emphasis on both past evidence and future trends, and to allow a more nuanced and robust allowance it was suggested this could be carried out on a use class basis.1 2.4.4 It is also noted that Arup, in undertaking an analysis of windfall rates for the SWLP, recommended a review of windfall assumptions through the HELAA process (page 31 of the Urban Capacity Study). The windfall assumptions provided in the Urban Capacity Study should therefore be treated with caution until additional work on future trends associated with anticipated source of supply is undertaken. 2.4.5 The Urban Capacity Study considers the potential for additional housing development within existing settlement boundaries. The majority of identified capacity is associated with sites with planning permission that are not yet fully built out (5,878 dwellings) and allocated sites without planning permission (7,655 dwellings). 2.4.6 The Urban Capacity Study helpful in illustrating that urban capacity in the settlements reviewed is limited, some of the potential sources of supply that are identified (including existing town centre car parks) and employment sites serve an important role in helping to maintain the vitality and viability of centres and local employment and may not therefore be suitable for development and the study concludes that only two sites with potential capacity for 104 dwellings should be considered (if found to be suitable, available and achievable in the forthcoming HELAA). The study rightly emphasises the need for greenfield allocations in appropriate locations. 2.4.7 The Arup study demonstrates that there is limited potential for new sites to come forward within the boundaries of the settlements considered. This reflects not only the limited supply of brownfield land that is available, but also the inherent development constraints that are associated with many of these historic settlements due to their intrinsic character and sensitivity to change. Policies which encourage intensification are not therefore considered to offer a realistic avenue to meet any significant share of future development needs (S2c). 2.4.8 Brownfield development should be encouraged where it contributes to a sustainable pattern of development and is consistent with other objectives of the Local Plan, e.g. relating to the protection of employment land. The agent of change principle will also be important and could be reflected in any policy (S3.2a). 1 https://www.gnplan.org.uk/media/3371770/review-of-greater-nottingham-shlaas.pdf
2.5 The Role of New Settlements in Meeting Future Needs (S5.2 and S5.3) 2.5.1 New settlements could have a role in helping to meet future needs but there is a need to ensure that they form part of a coherent spatial strategy for the whole plan area, are in sustainable locations, are deliverable, viable and will contribute to housing land supply over the plan period. 2.5.2 The options considered include several locations that are presented as new settlements. These all appear to have been appraised on the basis that they could provide up to 6,000 dwellings. As information has not been provided on the sites it is not clear if this assumption about the capacity of the identified locations is appropriate and therefore whether or not development on this scale represents a reasonable alternative at each location. The assumptions about the capacity of sites promoted by landowners/developers should be made clear in the evaluation of any location. Any revisions to the assumptions about new settlements as a source of supply should be reflected in the Sustainability Appraisal. 2.5.3 Paragraph 68 of the NPPF states (our emphasis): “Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.” 2.5.4 The above emphasises the need to consider locations for growth that are developable. To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged, Annex 2 of the NPPF. 2.5.5 Any proposals for new settlements that are taken forward into the Local Plan will also need to demonstrate compliance with paragraph 73 of the NPPF, which requires new settlements to be “well located” and “supported by the necessary infrastructure and facilities (including a genuine choice of transport modes)”. Paragraph 73 of the NPPF goes on to state that Councils should “identify suitable locations for such developmentwhere this can help to meet identified needs in a sustainable way” through considering “opportunities presented by existing or planned investment in infrastructure”. 2.5.6 Paragraph 73 of the NPPF states that policies for new settlements should “ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed and beautiful homes to meet the needs of different groups in the community”. 2.5.7 Paragraph 106 of the NPPF requires planning policies to be prepared with the active involvement of local highways authorities and other transport infrastructure providers and operators so that strategies and investments for supporting sustainable transport and development patterns are aligned. 2.5.8 The Inspector for the examination into the Tunbridge Wells Local Plan raised concerns around the treatment of large scale strategic allocations in the submitted Local Plan in his initial findings. 2 The Inspector raised concerns regarding the adequacy of the evidence base in relation to the new settlement at Tudeley Village (new settlement of 2,800 dwellings), as well as in relation to aspects of the growth at Paddock Wood (3,500 homes and 11 ha employment). 2.5.9 In relation to Tudeley Village the Inspector highlighted the need for the Local Plan evidence base to include additional information in relation to infrastructure requirements, including funding and phasing and the relationship between delivery rates and viability. 2.5.10 In the absence of this information the Inspector concluded that the Local Plan required modification to make it sound and capable of adoption. He also concluded that providing additional information in relation to Tudeley Village would not be a quick or a straightforward exercise. Modifying the policy could also add significant delays to the examination process. The third option he presented was to delete the allocation and make consequential changes to the Local Plan. 2.5.11 Similarly, the Inspectors Report into the Shared Strategic Local Plan for North Essex 3 concluded in relation to the Garden Community proposals that they need demonstrate a reasonable prospect of being viably developed, setting out clear details of phasing of necessary infrastructure linked to a delivery timetable and that any garden community proposals must be clearly shown to be financially viable. 2.5.12 Supplementary Planning Documents (SPDs) are sometimes seen as a mechanism for resolving matters associated with planning for new settlements. While SPDs have a potential role in helping to bring sites forward they cannot allocate land for development, as an SPD does not form part of the development plan, which means that decisions around the location of a local centre, employment or other specific uses will need to be made as part of Local Plan preparation so that these can be identified on the Local Plan proposals map. 2.5.13 Where options for new settlements are taken further the assessment of sites should also consider likely lead in times and anticipated delivery rates and how these will impact on the delivery of housing, particularly during the earlier stages of the plan period – the Lichfield Report (From Start to Finish)4 includes an analysis of delivery rates and a rate of 160 homes per annum is typical for sites over 2,000+ homes. The report highlights the significant lead in times that can be associated with larger development (i.e. sites of over 500 homes) from the date at which an outline application is validated, the average figures can be 5.0 to 8.4 years for the first home to be delivered. 2.5.14 Question S5.3 asks specifically about rail corridors as a location for growth. This approach to spatial development is considered too simplistic and might not necessarily lead to a more sustainable development strategy over alternatives. This is because not all settlements that are currently served by rail are located in accessible locations for non-rail based movements. Furthermore, not all of these settlements currently have existing services, social and community facilities etc and therefore would only be a sustainable location for growth if major development was focused at such settlements with requisite supporting infrastructure. It is considered best to have a blended spatial strategy and if rail represents a viable option implement this in a staged way over more than one Local Plan period. 2.5.15 Any development adjacent to an existing railway station that requires expansion of rail facilities will also clearly have to demonstrate that issues around viability and deliverability of new rail related infrastructure have been addressed. Network Rail is the licenced, regulated manager of the rail network, its guidance clearly and repeatedly states the need for, and benefits of, early engagement with industry, including Train Operating Companies (TOCs), Rail Freight Operating Companies (FOCs), Department for Transport (DfT) and other industry stakeholders. Any such matters would be potentially complex but would need to be satisfactorily resolved prior to submission of the Local Plan because they fall under the duty to co-operate. 2.5.16 All of the above highlights the importance of the Local Plan front loading relevant issues and the associated evidence base in relation to the delivery of any new settlements that are included in the SWLP, particularly of the scale envisaged, even if delivery is envisaged later in the plan period. 2 https://forms.tunbridgewells.gov.uk/__data/assets/pdf_file/0007/434392/ID-012-Inspectors-Initial-Findings.pdf 3 https://www.braintree.gov.uk/downloads/file/2940/examiners-report-on-the-examination-of-nea-s1-10th-dec-2020 4 https://lichfields.uk/content/insights/start-to-finish
