Issue and Options 2023

Introduction 1.1. These representations are made by Pegasus Group, on behalf of Catesby Estates in response to the Issues and Options consultation for the South Warwickshire Local Plan. Catesby Estates have land interests at Oaks Farm, Kenilworth which total 24.8 hectares which are considered to be suitable for residential development of up to approximately 300 homes. 1.2. The site is identified on the Site Location Plan at Appendix A and is on the south western edge of Kenilworth, immediately adjacent to the built-up urban area. 1.3. The Site was promoted through the 2021 Scoping and Call for Sites consultation and is identified on the Council’s interactive map (South Warwickshire Local Plan: arcgis.com) with Site ref: 140, noted as being a residential proposal. 1.4. The detail of the Site is not repeated within these representations but specific comments are made where appropriate to respond to the questions identified in the Issues and Options consultation. Notwithstanding, the Vision Framework for the Site that accompanied the previous consultation is included in these representations at Appendix B. In addition, Catesby Estates have commissioned a Transport Appraisal and Heritage Assessment to support the proposed development of the Site. These are set out at Appendices C and D and referred to within these representations as appropriate. 1.5. These representations have had regard to the published consultation document and questions set out therein, accompanying documentation forming the current evidence base, and the national planning context. 1.6. The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework 2021 (NPPF), para 35: • Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; • Effective – deliverable over the Plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 1.7. These tests of soundness, along with other legal and procedural requirements associated with the Plan-making process provide a contextual framework for these representations. It is noted that the proposed changes to the National Planning Policy Framework published in December 2022 propose to remove the requirement for Development Plans to be ‘Justified’ in order to be found sound. However, at the time of writing and submission of these representations that change has not been enacted and these representations therefore still take this test into account. 1.8. These representations refer directly to the specific questions set out in the Issue and Options consultation document and also respond to the following evidence base documents where appropriate: • South Warwickshire Local Plan Part 1 Stage 2: Issues and Options Consultation, January 2023 • Sustainability Appraisal (SA), November 2022 • Housing and Economic Development Needs Assessment (HEDNA), November 2022 • Urban Capacity Study, October 2022 • South Warwickshire Settlement Analysis, January 2023 • Evolving the Spatial Growth Options – The Story so Far – Topic Paper, August 2022 Summary 9.1. In addition to these representations and those submitted to the previous 2021 Scoping and Call for Sites consultation, and with reference to the guidance in the NPPF, Catesby Estates' land interests on land at Oaks Farm, Kenilworth are suitable, achievable and deliverable for proposed development. Suitability 9.2. The Vision Framework and Masterplan indicates how a scheme of 300 dwellings can be achieved on the site having regard to its constraints and opportunities. 9.3. The site is in a sustainable location and well placed to meet the housing needs of the joint Local Plan with access and enhancements to the site's accessibility being appropriate. 9.4. The site is not subject to any statutory nature or heritage designations and is within Flood Zone 1. 9.5. There are not known constraints which would prevent development of this site. Deliverability 9.6. Catesby Estates are in control of the site and are promoting it as set out within his document. The Site has already been submitted as part of the Call for Sites exercise associated with the 2021 Scoping Consultation and accompanying representations were also submitted. 9.7. Catesby Estates has an excellent track record in the delivery of housing, as set out in Table 1 below: Table 1: Catesby Track Record of Delivery 9.8. A planning application for the development of the site could be submitted immediately should it be allocated for development and the site could deliver 40 dwellings per annum. Availability 9.9. Catesby Estates control this land and are actively promoting it for development. The site is immediately available and could start to deliver housing within the next 5 years. 9.10. Catesby Estates welcome the opportunity to comment at this early stage of the plan preparation. If the Council require any further information in respect of the site to assist in further assessment this can be provided upon request.

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Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? Q-V3.2 If no, please indicate why 2.1. As set out in response to the Scoping and Call for Sites consultation, Catesby Estates supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Catesby Estates supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The Plan’s Vision seeks to “meet` South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented as it accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of homes and jobs does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation document goes onto talk about the delivery of growth an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.

The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. The SA prepared in support of the Issue and Options consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no.new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA: The principle and broad approach of the SA is supported but the alternatives it considers are limited in scope and do not assess specific sites. Catesby Estates' land interests fall within two of the Broad Locations in the SA, Kenilworth South and Kenilworth West. The Site itself sits across the eastern edge of Kenilworth West and western edge of Kenilworth South and as such, applying a blanket 'area' approach to the land is not appropriate. Rather, a site specific approach should be undertaken when pursuing the Plan further. 3.7. An assessment of the Site against the SA Objectives shows that it could positively deliver development in a sustainable manner. SA Objective 1 Climate Change: The site would deliver 300 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs with regard to the development surrounding. SA Objective 2 Flood Risk: The site is within Flood Zone 1 at a low risk of fluvial flooding. Some small areas at risk of surface water flooding within the site could be accommodate within a sensitive design response. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: Hedgerows and tress along field boundaries provide ecological value and create opportunities for sheltering and foraging wildlife as well as green corridors to allow the movement of animals and will be retained where possible. Surface water attenuation features can increase overall habitat diversity and mitigation measures to protect species on Site will be developed should the site come forward for development. A landscape and green infrastructure strategy could provide an increase in the biodiversity values of the Site, in line with the mandate of the Environment Bill. The Masterplan has embodied such principles and Catesby Estates are committed to the delivery of at least 10% biodiversity net gain as part of the development of this site. SA Objective 4 Landscape: The site is within immediate context of urbanising influences such as residential development along Rounds Hill (north) and properties off Hunt Paddocks (adjacent to eastern part of site). Existing mature trees and hedgerows help define the site and its boundaries and will be retained and strengthened where appropriate. Proposals can come forward (as set out in vision Framework) with a strong green infrastructure and multifunctional open space framework to provide a sensitive transition between urban and countryside. A positive green infrastructure and open space strategy would also inform an emerging Green Belt boundary to the west. SA Objective 5 Cultural Heritage: No archaeological heritage is evidently present on site. The site is within 1km of an Ancient Monument and the curve of Rouncil Lane to the south east forms part of the Wedgenock Old Park (nearly 500m away), a Medieval Deer Park that was attached to Warwick Castle. Similarly, there are no built heritage assets present within the site. A Heritage Assessment has been undertaken to support the proposed development of the Site and has principally considered assets including Kenilworth Castle Grade I listed building, Kenilworth Castle Registered Park and Garden and Oak Farmhouse Grade II listed building. Matters relating to heritage do not comprise a major constraint to the deliverability of the site for the proposed development. Importantly, the site is beyond the Registered Park and Garden and has limited intervisibility with the castle. The setting of the castle and RPG assets is not considered to be a major constraint to the deliverability of the site. Likewise, the setting of the Grade II Listed Oaks Farmhouse is not considered to be a major constraint to development within the site, which is little visible from the asset, views from which are focused to the west of the site. SA Objective 6 Pollution: It should be noted that mitigation is achievable for air quality impacts, including for example additional tree planting, installation of electric vehicle charging points and increased use of public transport through sustainably located development, such as at this Site. SA Objective 7 Natural Resources: The site is shown on Natural England mapping as Grade 3 agricultural land of good to moderate quality and immediately adjacent to land the is predominantly in urban use, being Kenilworth urban area. SA Objective 8 Waste: A development of 300 houses would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. SA Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. SA Objective 10 Health: The site is accessible by modes of transport other than the private car which provide sustainable access to health services and facilities. There would be open space on site, and retention of the existing public right of way and enhancements for pedestrians and cyclists would be incorporated. SA Objective 11 Accessibility and 12 Education: The site is accessible by all forms of transport and development of the site could support and enhance bus services. There are also various local services and facilities in the immediate surrounds as referred to. Oaks Farm would be within 1km of facilities including two primary schools, a sixth form, local retail facilities including a post office and allotments. There would also be opportunities to enhance connectivity by bus to and from the site, which will be explored as part of preapplication discussions with the Local Authority and relevant operators, which may include the diversion of existing bus services into the site. SA Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Kenilworth in the immediate vicinity and also beyond through transport links.

Q-I2: Please select the option which is most appropriate for South Warwickshire: A: Set out infrastructure requirements for all scales, types and location of development B: Focus on strategic infrastructure relating specifically to the growth strategy 3.8. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.9. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: A: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan B: Each District to produce its own Levy 3.10. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.11. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.12. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage. As intimated at NPPF para 58.

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Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 2A: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be provided that the development is in a sustainable location or would increase the sustainability of the area. 2B: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location. 2C: None of these. 3.13. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.14. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan and as set out below a Green Belt review will also be required. Issue S6: A Review of Green Belt boundaries 3.21. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.22. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.23. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.24. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.25. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. 3.26. The release of Catesby Estates' land interests at Oaks Farm, Kenilworth would not harm the purposes of including land within the Green Belt as follows: • To check the unrestricted sprawl of large built-up areas – The development would result in an extension to the existing urban area of a scale appropriate to Kenilworth's role as a Main Town, where a defined built-up urban area would be expected. • To prevent neighbouring towns merging into one another – Development would not result in the merging of Kenilworth with any other settlement. • To assist in safeguarding the countryside from encroachment – Whilst the land is currently of a countryside character a strong green infrastructure network and provision of open space would created a robust defensible Green Belt boundary to land beyond. • To preserve the setting and special character of historic towns – Development of the site could be accommodated without harm to the significance of identified heritage assets, as set out in the Heritage Statement undertaken for the Site (see Appendix D) Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.35. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. 3.36. Beyond this, to be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan.

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Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes 3.15. Warwick focuses development around its four main urban areas (of which Kenilworth is one), whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in the most sustainable locations. For example, additional development around Kenilworth would allow for positive transport and housing impacts, delivering sustainable development that encourages modes of transport other than the private car and which allows for development with access to a range of services and facilities. 3.17. Kenilworth, as an identified Main town is a sustainable location for development and development at Oaks Farm would allow for a sustainable development near to shops, services and public transport whilst also delivering significant public benefits, compensatory green belt and ecological enhancements. 3.18. As set out in the Sustainability Appraisal at Section 4.6, development within the Broad Locations at 'Kenilworth South' and 'Kenilworth West' would be within 800m of public transport links, a GP, a primary school, a local shop and public green space accessibility, when considered based on development of up to 35 dwellings per hectare. More specifically, Catesby Estates' land interests at Oaks Farm would be within 1km of facilities including two primary schools, a sixth form, local retail facilities including a post office and allotments. In terms of access there is a public right of way through the Site linking to existing development to the north east, and there are a number of bus stops within 1km of the Site. The train station is within 2km of the site and the site is easily accessed from the main road network including the A452 and the A46 linking to Coventry and the M42 motorway. Pages 13 and 15 of the Vision Framework demonstrates the Site's locational context and sustainable location (Appendix B) and the Transport Appraisal prepared by DTA (Appendix C) sets out the existing and proposed accessibility options for the development of the Site. 3.19. It is clear that this Site is located in an entirely sustainable location and should be positively considered as a location for growth. Q-S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on. 3.20. The Site falls within Kenilworth South for the purposes of the Settlement Design Analysis which forms part of the Council's evidence. It is within Parcel 18 which scores a C in terms of accessibility (amber) and it has existing rights of way through the site and development to the north and east with potential to connect to the highways network. It is not identified as having any landform constraints and has retail, jobs and economy, places to meet, open space. Leisure, recreation and wellbeing, and education facilities within 800m, therefore scoring highly on access to facilities.

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Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. 4.2. The Planning Practice Guidance (PPG) (para 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. 4.3. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. 4.4. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. 4.5. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. 4.6. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. 4.7. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix E) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear." 4.8. It is important to stress that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further. NPPF REF

There is an acute recognition in the Issues and Options consultation documents of an affordability problem across South Warwickshire Plan area, where those on low incomes and young people struggle to access the housing market. 4.10. Warwick District Council’s latest ‘Authority Monitoring Report’ (AMR) (for the period 2020- 2021) indicates that against an annual requirement of 280 affordable dwellings since the beginning of the currently adopted Plan period in 2011 (within its own area), the Council have delivered 841 affordable dwellings (out of a total requirement for 2,800), 30% of the target. 4.11. Stratford-on-Avon’s latest AMR for the period 2021-2022 (published December 2022) identifies that in the current Core Strategy plan period of 2011-2031, 3,204 affordable dwellings have been provided out of a total 10,019 dwellings (net) built. This equates to 37% of all dwellings and is just above the Plan’s affordable housing policy requirement of 35% of all dwellings to be affordable. 4.12. Notwithstanding Stratford-on-Avon’s marginal reported over delivery, the HEDNA considered the affordability issue across the District further. It identifies at Table 8.45 that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. 4.13. Whilst it is recognised that these are ‘net’ figures and not ‘newly arising need’, PPG paragraph 2a-024 makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need: “The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.” 4.14. The Issues and Options consultation recognises that the area has an acute affordability problem and it is suggested that to address this, the Plan could consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing.

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