Issue and Options 2023
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New searchRe: South Warwickshire Local Plan – Issues and Options Consultation Thank you for the opportunity to comment on the South Warwickshire Local Plan (SWLP) Issues and Options (IOP) consultation. Bellway Strategic Land (part of Bellway Homes Limited – ‘Bellway’) is promoting land north of Loxley Road, Stratford upon Avon, a site we own freehold and which was previously promoted by Rosconn Strategic Land. The site was submitted through the initial Call for Sites process and has been recorded as Site 471 on the Interactive Map. Bellway have the following comments, which we trust the Councils will find helpful and fully consider in informing the subsequent Preferred Options stage of the SWLP.
Bellway generally support the approach of the November 2022 Sustainability Appraisal (SA) in its identification of a range of alternative growth options from broad distribution scenarios down to small settlement growth locations [E5]. In shaping the reasonable alternative options, the Councils have been guided by the 20-minute neighbourhood concept which aims to minimise carbon emissions by guiding development to locations where there is sustainable access to every day services and facilities as well as travel options other than the private car [section 3.1]. We consider this to be a sound basis for framing the alternatives explored. In terms of the Broad Locations (BLs) identified at Stratford upon Avon, Bellway would agree with the conclusions that the BLs identified for this settlement are logical as they avoid strategic constraints whilst being favourably located in respect of established services and facilities. Bellway would also firmly agree with the assertions in section 4.15, which cumulatively at paragraph 4.15.1 point to Stratford upon Avon East (B.25) as being the best performing option out of the five alternatives assessed for the town as it is the least constrained in terms of environmental receptors. Bellway’s land north of Loxley Road, Stratford upon Avon falls within Stratford upon Avon East (B.25).
We have reviewed the Urban Capacity Study by Arup dated October 2022. Net of outstanding commitments and windfalls, it identifies an overall capacity of 1,231 dwellings. For the sake of comparison, the Housing and Economic Development Needs Assessment (HEDNA) identifies a base annual housing need in South Warwickshire of 1,432 dwellings per annum (dpa). As such, even if all of these sites were to come forward at the assumed densities, their contribution to meeting housing need would be minimal. Bellway also have concerns about the robustness of some of the sites identified as contributing towards urban capacity. For example, The Greens South of Alcester Road in Stratford-upon-Avon is assumed to have a capacity of some 80 units but was refused planning permission for 57 dwellings by the Council on heritage amongst other grounds. It is clear therefore that many of these sites may not proceed beyond the land availability assessment. Bellway recognise that the Urban Capacity Study may not have looked at rural brownfield sites although given the sustainability challenges associated with such sites, they will likely make a negligible contribution. Accordingly, the evidence base shows that whilst brownfield development could always be prioritised, it will only make an, at best, minimal contribution towards meeting housing need on the Councils’ own evidence.
Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes. Sustainable settlements, particularly Mian Towns such as Stratford upon Avon, should accommodate growth not only to bring about a balanced and deliverable spatial strategy but also to ensure their continued viability and vitality. As the Councils will be aware freestanding new settlements take a long time to commence development and are often reliant on funding entirely new infrastructure which can be challenging to realise in practice. In addition, the Councils will need to identify sites that are capable of coming forward in the early years of the plan period to establish a five-year housing land supply. Sites on the edge of existing settlements are best placed to meet this need provided they can mitigate their own impacts on local infrastructure. Q-S4.2: Please add any comments you wish to make about the Settlement Analysis. Bellway’s site falls within Stratford South East within the Settlement Design Analysis and Bellway therefore have the following comments to make in this respect: • We welcome that the land north of Loxley Road (Area 2) has been graded ‘B’ in terms of Connectivity and note that only one other site on the periphery of the town performs slightly better (Area 2, Stratford South West graded AB). It is also noted that Loxley Road also forms the route of National Cycle Route 41, a long-distance cycle route providing localised linkages to Leamington, via Wellesbourne amongst others. We consider this to therefore be a generally accurate reflection of the situation on the ground where land to the south east of the town benefits from reasonable proximity to key services and facilities. Clearly, if part of a proposed urban extension, a range of on-site facilities and supporting infrastructure can be delivered to improve accessibility to more day-to-day needs. • We note that the Landform Analysis confirms Bellway’s site identifies no notable or significant gradients on site or the route to key services and facilities that could impact on the ability of using active modes of travel. Similarly, there are no areas at risk of flooding within or near the site. An area of Green Infrastructure (golf course) is identified immediately to the west of the site, providing opportunities to secure connections to extend existing GI. • In terms of the Density Analysis, it is noted that the exercise has not included the recent developments at Consilio and Tudor Gate to the west of the Bellway site which are likely to have been developed at a slightly higher density to the areas identified in the assessment. However, we are confident that an appropriate density of circa 30-40 dwellings per hectare would be appropriate in the context of the surrounding area. • In terms of the Heritage and Settlement Sensitivity Assessment’s commentary about the heritage assets at Stratford upon Avon, it concludes that from a heritage perspective, new development should be restricted to the northwest, east, south and west of the town, avoiding the more sensitive areas to the northeast and southwest.
Q-S5.3/5.4: We are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? If not, what approach would you take? In part yes, but as per our response above, Bellway consider that there should be a broad approach to co-locating development with existing railway infrastructure including proportionate growth on the edge of existing settlements which have these facilities, rather than concentrating all or most rail-focused growth on only a handful of locations, particularly those that currently have no existing stations and associated infrastructure.
Q-S5.2: Do you think new settlements should be part of the overall strategy? No. Bellway understand the rationale for and the benefits of new settlements where there is suitable and deliverable land available for them. For example, there was spatial logic to the Long Marston and Gaydon/Lighthorne Heath new settlements identified through the adopted Stratford District Council Core Strategy as one was partially previously developed land and the other near a strategic employment site. However, the new settlement options identified in the SWLP appear to lack such robust logic. Half are located in the Green Belt and whilst we are generally supportive of releasing Green Belt land to meet development needs where there is a strong sustainability case to do so and where harm to the Green Belt can be minimised or mitigated, the creation of freestanding new communities within the Green Belt will have a considerable impact on its openness. The Green Belt new settlement options also happen to be the only locations which have existing train stations. The other options outside the Green Belt are reliant on new stations being built which is a considerable undertaking and there is no evidence at present to indicate, notwithstanding the size of any given potential new settlement, that these would be viable or could be operationally accommodated in a timely manner within the existing network. Bellway understand the rationale for focusing growth around railway stations and corridors to make best use of public transport options to address climate change, but we consider the same benefits could be achieved through more proportionate release of land around a greater number of existing settlements with rail and other public transport connections. We do not consider that a railway and public transport-led strategy must be weighted in favour of new settlements and there is a lack of evidence to indicate that this is a sustainable or viable option. Issue S6: A review of Green Belt boundaries Whilst Bellway support a general review of Green Belt boundaries, national guidance should be carefully considered to ensure that all opportunities outside the Green Belt are examined fully, as required by paragraph 141 of the NPPF (2021). We agree that avoiding the Green Belt entirely will not generate a sustainable pattern of growth in view of the scale of likely growth required across the 2 Councils, as envisaged by the emerging SWLP.
Q-H1-1: Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Bellway reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and Warwickshire. The NPPF sets out that “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” . National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. On the basis of the above, Bellway consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28-year plan period. In line with the NPPF, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance; for example, in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness, which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, Bellway consider that the SWLP will need to plan for a level of housing growth as set out in the below Table in the order of at least 43,000 dwellings Table – SWLP Housing Requirement and Supply Calculation Housing Requirement South Warwickshire Minimum Housing Need Derived from the HEDNA (1,679 x 28 Years) 47,012 dwellings Uplift to Minimum Housing Need TBC – further work required to determine whether an uplift is appropriate Contribution Towards Unmet Needs of Coventry and Birmingham & Black Country TBC – engagement with Birmingham/Black Country and Coventry required but suggest increase of at least 21,000 dwellings possible (circa 11,000 towards Coventry and at least 10,000 towards Birmingham) Total Housing Requirement 68,000 dwellings + Housing Supply Sites with Planning Permission at 1st April 2022 (with 5% lapse rate applied) 14,360 dwellings Outstanding Local Plan Allocations at 1st April 2022 5,579 dwellings Windfall Allowance TBC – 4,840 dwellings assumed in line with UCS however this requires further justification / compelling evidence Total Housing Supply 24,779 dwellings Indicative Housing Requirement to be found by the SWLP 43,000 dwellings +
It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. Bellway consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (i.e. Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Bellway consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050, leaving a potential shortfall of circa 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.
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