Issue and Options 2023
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New search2.1 The NPPF at 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).’ 2.2 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.’ 2.3 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.
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. Dependent on the results of the urban capacity study, it could be that brownfield development forms a part of our development strategy. Brownfield sites are frequently found within towns and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. However, instead of developing all brownfield sites, this option looks to prioritise brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area. In some instances brownfield redevelopment can exacerbate issues and result in development occurring in unsustainable locations. This option aims to reduce such development. Option S3.2b: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location This option looks to prioritise the redevelopment of all brownfield land irrespective of whether the site is in a sustainable location. Whilst redevelopment of brownfield land is, on the whole, a sustainable approach, locating redevelopment in unsustainable locations can sometimes exacerbate issues within an area, and this is a risk of prioritising all brownfield sites for redevelopment. Option S3.2c: None of these 2.4 It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, 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.’ 2.5 Therefore, the Council(s) evidence base clearly demonstrates the need for the release of greenfield. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes | No | Don’t Know 2.6 Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 2.7 South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-upon-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. 2.8 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 (of all categories). 2.9 Wilmcote is categorised as a ‘Category 2 Local Service Village’ in Policy CS.15 of the adopted Stratford-upon-Avon Core Strategy. 2.10 Wilmcote offers a large range of services and facilities, including a pub; social club; church, primary school; play area. There are several bus stops in the village and there is a train station to the east of the village. The village is relatively close to Stratford-upon-Avon. 2.11 The site is located immediately adjoins the built-up area boundary of the village. The promotion site would be well connected to the built-up area of and would constitute sustainable development. 2.12 Given the pressing need for additional housing within the Stratford-upon-Avon District, Wilmcote 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. Q-S5.2: Do you think new settlements should be part of the overall strategy? 2.14 The Bird Group does not object to the consideration of new settlements as part of the Council’s Growth Option. 2.15 A range of sites varying in scale and size should be explored in order to secure the delivery of new homes. The expansion of existing settlements and new settlements allocated in the Local Plan should also be explored further to see whether there is capacity to be extend these further. Smaller sites are likely to have no significant infrastructure or utility constraints. The site can be accessed off public highways, the site is in the control of a developer (the Bird Group) which makes it a deliverable site Q-S9: Please select the option which is most appropriate for South Warwickshire 2.23 A higher limit is appropriate for individual sites this will ensure flexibility and a subsequent increase in housing delivery. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 2.24 All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-upon-Avon and Warwick Districts, out of date boundaries can be reviewed which and there could be a subsequent increase in housing delivery.
2.13 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.’
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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? Yes 2.25 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. 2.26 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). 2.27 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. 2.28 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. 2.29 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. Option H2-2b: Separate affordable housing requirements for Stratford-on Avon and Warwick Districts 2.35 We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-upon-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. Q-H4-1: Do you 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? Yes 2.36 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. 2.37 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. 2.38 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-upon-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. 2.39 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. 2.40 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-upon-Avon District. 2.41 Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by either 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.
2.30 The Local Plan needs to address the key strategic issue of housing and affordability. The main approach of dealing with this issue is by facilitating housing growth to ensure a balance of demand and supply which will be the only means of driving housing prices down. The allocation of sites will also facilitate the delivery of affordable housing. Since the adoption of the Core Strategy, national policy has developed following first the Housing White Paper, Fixing the Broken Housing Market (February 2017), and then latterly the Revised NPPF (2021), which build on that original document. 2.31 The key messages of national policy have therefore been ensuring faster delivery, diversification of supply and consequent strong support for small and medium housebuilders and smaller sites in sustainable rural locations. NPPF paragraph 20a emphasises the importance of a comprehensive strategy in respect of housing delivery, which in turn reflects section 19(1B)-(1C) of the PCPA 2004. 2.32 NPPF paragraph 60 continues to emphasise the importance of boosting supply. This is reinforced by NPPF paragraphs 74 to 77, which collectively set in place a requirement to ensure a healthy, rolling 5 year housing land supply. 2.33 NPPF paragraph 69 reflects the need to ensure a range of small and medium sized sites, as these can be built out quickly on the importance of choice and competition and paragraphs NPPF 78-79 in respect of delivering supply at villages). These are all key components of soundness under NPPF paragraph 35. 2.34 A number of these principles are reflected in the most recent Housing White Paper: Planning for the Future (August 2020) and Changes to the Current Planning System (August 2020), which represent a clear direction of travel for national policy in the early part of 2021, and thus during the examination of the new Local Plan.
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Q-D3: 2.43 A flexible approach to density in new development, which is consistent with national policy which states that Council’s should avoid unnecessary prescription or detail, and should set out their own approach to housing density to reflect local circumstances (paragraphs 123 of the NPPF).
