Issue and Options 2023
Search form responses
Results for West Midlands Housing Association Planning Consortium search
New searchThe WMHAPC welcomes the South Warwickshire (“SW”) councils’ recognition of the need to deliver “homes that meet the needs of all our communities…Allowing for the growth in new homes that meet the diverse needs of all our residents, including affordable, student, specialist and self and custom build housing, along with the accommodation needs of our gypsy and traveller and travelling show people communities.” Housing associations are well placed to help the SW councils deliver this strategic objective.
Q-S3.2: Please select the option which is most appropriate for South Warwickshire The WMHAPC supports the option for brownfield development that maximises the delivery of affordable housing in the most sustainable locations. However, it is evident that a level of greenfield development will be required to meet the housing needs of South Warwickshire. Page 36 of the South Warwickshire Urban Capacity Study (2022) shows that there is likely to be a shortfall in the capacity of South Warwickshire to accommodate its housing need on brownfield land of some 10,800 dwellings for the plan period of 2025-2050: “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.” The SW councils should be cautious to a brownfield led approach to development as it may hinder the delivery of affordable housing within the area. It is widely recognised that the development of brownfield land often has cost implications that negatively impact the viability of delivering affordable homes at such sites. In considering the evidence, a balanced combination of a greenfield and brownfield led development should be considered, as explained by the South Warwickshire Urban Capacity Study.
As explained within both the consultation material and Planning Practice Guidance (“PPG”) population projections form the basis of the standard method for calculating housing need (Paragraph: 005 Reference ID: 2a-005-20190220). However, the 2022 HEDNA demonstrates the inaccuracy and over projection of ONS population estimates in comparison to the 2021 Census data across the HMA, this is set out within table 1 below. Table 1: Percentage difference between ONS MYE (2020) and 2021 Census population difference Housing Market Area --------- ONS MYE (2020) -- 2021 Census -- Percentage Difference Coventry ------------------------- 379,387 --------------- 345,300 -------- -9% North Warwickshire ----------- 65,452 ---------------- 65,000 --------- -1% Nuneaton and Bedworth ---- 130,373 -------------- 134,200 -------- 3% Rugby ---------------------------- 110,650 --------------- 114,400 -------- 3% Stratford-on-Avon ------------- 132,402 --------------- 134,700 -------- 2% Warwick ------------------------- 144,909 --------------- 148,500 -------- 2% Coventry & Warwickshire --- 963,173 --------------- 942,100 -------- -2% Similarly, paragraph 5.44 of the 2022 HEDNA at page 90 states: “On the 29th July, ONS published its response setting out a work plan to address the OSR recommendations.19 ONS recognised that there were concerns about population estimates and projections (specifically mentioning Coventry) and that this can have an impact on household projections and therefore calculations of housing need. It is notable that both ONS and the OSR have acknowledged issues with the population estimates for Coventry and its impact on the City’s calculated housing need.” When considering the evidence put forward by the 2022 HEDNA it is evident that circumstances warrant an alternative approach to the standard method as set out by paragraph 61 of the NPPF (2021) in order to better reflect the household populations projections and subsequent needs of both Coventry, South Warwickshire and the HMA more widely: “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 – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” The divergence from the standard method and the use of remodelled projections by the 2022 HEDNA does amount to a significantly lower projected housing needs in comparison to the traditional standard method for Coventry. However, when viewed in the context of Stratford-on-Avon and Warwick a higher housing need figure is calculated, the SW councils should seek to meet this need in full. The WMHAPC welcomes the SW councils’ acknowledgement of their Duty-to-Cooperate in planning for the anticipated unmet housing needs of Coventry within Warwickshire and Stratford-on-Avon. However, it is important to note that it is plausible that through a review of their own Development Plan Coventry City Council could take a different approach to calculating overall housing need which may result in a higher quantum of unmet need for Coventry which would need to be accommodated within South Warwickshire.
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Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire? The WMHAPC supports the option which will allow the greatest provision of affordable homes, in the most sustainable locations. The 2022 HEDNA sets out two separate affordable housing need figures which differ significantly between Stratford-on-Avon (547 dpa) and Warwick (839 dpa). Given the differing housing need within each authority and the existing affordable housing requirements as set out by the development plans of the respective authorities of 35% in Warwick and 40% in Stratford-on-Avon, it is clear that either options 2b and 2c would be the most appropriate to deliver the affordable housing needs of both Stratford-on-Avon and Warwick. In considering the evidence available, paragraphs 8.140 on page 197 of the 2022 HEDNA explains: “Overall, the analysis identifies a notable need for affordable housing, and it is clear that provision of new affordable housing is an important and pressing issue in the area. It does however need to be stressed that this report does not provide an affordable housing target; the amount of affordable housing delivered will be limited to the amount that can viably be provided. The evidence does however suggest that affordable housing delivery should be maximised where opportunities arise.” When taken at face value Option H2-2c would go a long way of increasing the supply of affordable housing at a local level. Option H2-2c acknowledges the importance of recognising the differing house prices and high value areas within both Stratford-on-Avon and Warwick. However, it is difficult to comment on the appropriate option of increasing the supply of affordable until viability testing has taken place. The 2022 HEDNA explains that opportunities for increasing the supply of affordable housing will depend on the viability of the various options put forward. PPG (Paragraph: 001 Reference ID: 67-001- 20190722) supports this position stating: “Strategic policy-making authorities will need to consider the extent to which the identified needs of specific groups can be addressed in the area, taking into account: • the overall level of need identified using the standard method (and whether the evidence suggests that a higher level of need ought to be considered); • the extent to which the overall housing need can be translated into a housing requirement figure for the plan period; and • the anticipated deliverability of different forms of provision, having regard to viability.” Q-H3: Please select all options which are appropriate for South Warwickshire As set out within PPG both Stratford-on-Avon and Warwick District Councils “will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans” (Paragraph: 002 Reference ID: 56-002-20160519). As such, there is a possibility that the need for NDSS will differ between the two local authority areas, this will need to be reflected in any NDSS policy put forward by the South Warwickshire Local Plan. The SW councils need to be cautious on the inclusion of internal space standards within policy where there is not an identified need, the application of NDSS across all residential development could undermine the viability of many development schemes. This will potentially result in fewer homes being delivered as optional technical standards have implications for build costs and sales values, which in turn impacts development viability leading to challenges for the delivery of affordable housing. Whilst for prospective residents it is possible that many eligible households in South Warwickshire may not desire, or require housing that meets the NDSS, as it may result in for example, higher rental and heating costs. As set out by PPG the application of NDSS are not a building regulation and remains solely within the planning system as a form of technical planning standard. It is not essential for all dwellings to achieve these standards in order to provide good quality living. For affordable housing in particular, there may be instances where achieving NDSS is impractical and unnecessary. In line with Option H3b it is recommended that meeting NDSS is not made mandatory unless the SW councils are able to demonstrate a clear need for such a standard in dwellings in both Stratford-on- Avon and Warwick. Similarly, it is also acknowledged that the 2022 HEDNA identifies an estimated need figure for wheelchair accessible dwellings in both Stratford-on-Avon and Warwick. The introduction of such a standard will need to be robustly evidenced and viability tested to ensure it isn’t at the detriment of both affordable housing delivery and overall housing delivery more generally. It is suggested that if the SW councils wish to introduce such policies that the rational for their implementation be fully evidenced, and viability assessed in accordance with PPG (Paragraph: 020 Reference ID: 56-020-20150327): “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.”
Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2: For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? In response to questions Q-S8 1 and 2 it is important that the SW councils recognise the importance of small sites in addressing local affordable housing needs by not only allowing for a level of small scale development that is proportionate to the existing settlement but also through the delivery of Rural Exception Sites. As such, the WMHAPC suggests that the SW councils offer a level of flexibility within policy to allow for the delivery of ‘Rural Exception Sites’ beyond the spatial growth strategy that the Council opt for. It is important to acknowledge the value of ‘rural exception sites’ in delivering affordable housing options that address local needs. Paragraph 78 of the NPPF (2021) explains that “local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs”. It is understood that the Policy H3 of Warwick Local Plan addresses Rural Exception Sites. This policy should be carried across into the South Warwickshire Local Plan to allow for the delivery of affordable housing outside of the SW councils’ spatial growth strategy. However, in its present form Policy H3 is severely restrictive in the evidence required to justify such a scheme, Policy H3 states: a) “The proposal will meet a particular local housing need, as identified in detailed and up to date evidence from a parish or village housing needs assessment, and it can be demonstrated that the need cannot be met in any other way” Following PPG (Paragraph: 012 Reference ID: 67-012-20210524), the WMHAPC suggests that the SW councils reconsider the wording of Policy H3 to allow for sufficient flexibility, whilst also ensuring the affordable housing needs of rural communities are able to be addressed. In line with PPG (Paragraph: 015 Reference ID: 67-015-20210524) the SW councils may wish to strengthen its working relationships with relevant groups to ensure the delivery of rural exception sites. The WMHAPC are well placed to make a meaningful contribution to such discussions.
