Issue and Options 2023

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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Q-H3: Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: '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.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: This is discussed in answer to Question H1-1. Q-H5: As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area. In addition to a percentage delivery on large sites. It is also considered appropriate to make policy provision for smaller sites, exclusively for custom and self-build, to be delivered within or on the edge of individual settlements where appropriate. Not all Custom self-build demand is for properties on larger residential schemes, that are otherwise being delivered by national housebuilders.

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Q-C4.1: If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal Q-C6.1: Whilst the value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and/or mortgagees will own the properties. It is unclear how units once occupied would be required to share information in respect of energy use, air quality and overheating risk data with a third party, where the developer no longer holds ownership and therefore does not have responsibility of maintaining the property. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.

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Q-C9.1: Corbally Group are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

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Q-D2: In principle, the introduction of design guides and design codes would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). 6.2. The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. 6.3. Corbally therefore agrees that the principle of Design Codes/Design Guides to guide development is acceptable. 6.4. However, the development of such policies should be justified in terms of the nature of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites or those with particular design considerations, rather than being a default requirement for all sites. 6.5. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up much needed development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could be encouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies.

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The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.

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Q-B3: Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no national basis in policy or support, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary.

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Q-B8.1: Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.

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There is no in principle objection to the proposed list of policies as set out in the Issues and Options consultation. However, in developing a robust and justified evidence base the Plan should not rule out identifying sites for development that are not ‘strategic’ in the Local Plan Part 1. This could assist in facilitating the delivery of sites in advance of the Local Plan Part 2 and would also come out of the settlement boundary review that these representations suggest is required to inform the Local Plan Part 1. This would clearly fall within the remit of allocation of other sites as necessary for short-term development. 8.2. There is a degree of overlap between the proposed content for the Part 1 and Part 2 Plans, particularly regarding strategic allocations and smaller and non-strategic site allocations which effectively appear in both. The Plan will need to be clear which sites are being proposed for allocation now, what is being left for Part 2, why this has been done and the justification for this approach.