Issue and Options 2023

Yes

42. Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 43. Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 44. 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. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 45. Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g. Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 46. In light of the above considerations, we agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District.

47. Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by increasing the growth proposed for Option 5: Dispersed. Housing targets should be minimum ones in light of the wider Housing Market Area issue and the need to address the Birmingham and Black Country HMA unmet housing needs.

selected

selected

selected

selected

selected

selected

52. NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. 53. The site will seek to deliver a biodiversity net gain, alongside other on-site habitat provision and enhancement, the site provides a wide range of opportunities for good quality habitat creation., however this should not be higher that the incoming 10% target.

selected

selected

selected

No answer given

selected

selected

selected

selected

selected

selected

selected

selected

selected

selected

5. The 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).’ 6. It is noted that the SA in the conclusion for the Sustainability Appraisal 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] 7. As the Issue and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and no mitigation has not been considered.

Yes

17. The settlement analysis does not consider all settlements in the Districts, it should also consider ‘networks of villages’ which can provide local amenities for new residential development. The settlement analysis should therefore be updated to include all settlements in the District, to do so would be in line with Paragraph 79 of the NPPG (2021) which 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. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

Nothing chosen

Nothing chosen

Nothing chosen

Nothing chosen

Appropriate strategy