Issue and Options 2023

Q-S5.2: Do you think new settlements should be part of the overall strategy? 3.40 RPS wishes to reiterate its position that it does not object to new settlements forming part of the development strategy in principle. Nonetheless, RPS suggests that caution should be applied in considering new settlements as part of a broader strategy for distributing growth in South Warwickshire. This is because unforeseen issues can occur that can delay progress on new settlement / strategic allocations, for example in Stratford-upon-Avon. In this case, the Core Strategy allocated two new settlements at Gaydon/Lighthorne Heath (2,300 homes) and Long Marston (2,100 homes), 30% of the adopted housing requirement of 14,600 dwellings. However, since 2011 (the base date of the current plan) these two new settlements have only delivered 343 dwellings, just 3.4% of the total housing delivered in the district up to April 20228. This is reflective of the lead-in time needed to bring forward larger, strategic sites that is often under-estimated at the forward planning stage. Alternatively, smaller sites which can harness infrastructure already available are not as dependent on the delivery of strategic infrastructure. 3.41 The distribution strategy should therefore also ensure that the needs of local communities can be met through smaller development directed and brought forward at established sustainable settlements that can be delivered relatively quickly, and thus a greater mix of different sized sites should be encouraged to deliver a significant proportion of the required growth in the SW area over the plan period. This includes the Goose Lane, Lower Quinton sites being promoted by Redrow Homes, a national house builder with extensive experience of delivering housing across the Midlands and South Warwickshire. 8 Stratford-upon-Avon Authority Monitoring Report 2021-22, Table 13 Issue S6: A review of Green Belt boundaries 3.42 RPS notes that the IO document does not include any specific question regarding potential for changes to the Green Belt in South Warwickshire. Nevertheless, national policy9 makes provision for alterations to existing Green Belt boundaries through the updating of plans where the need for changes to Green Belt boundaries is established in the strategic policies. This is normally done through a Green Belt review to inform the development of the spatial strategy and identification of site allocations. 3.43 In this respect, the IO document makes clear that to achieve a growth strategy that addresses the vision and strategic objectives for the Plan, a Green Belt study to review the existing Green Belt boundaries would inform and help to refine the growth options that are set out within the issues and options consultation to enable a preferred approach for South Warwickshire to be established. 3.44 Nevertheless, regardless of whether any Green Belt is released is taken forward, there are opportunities outside the Green Belt where growth can be directed. RPS considers that Lower Quinton would be an acceptable settlement for growth that should be taken forward in the SWLP. 9 NPPF 2021 paragraph 140

3.47 RPS has highlighted a number of issues with the CCEE study at a broad level in responses to Issue S5, which are applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) having the highest emissions. 3.48 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050 (or 2055).

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Issue S8: Development coming forward outside of the spatial growth strategy 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? 3.67 In response to this question, RPS does not support any maximum threshold as this could potentially limit the provision of much needed affordable housing and also limits potential to deliver wider benefits from large scale development resulting in better sustainable outcomes. Issue S9: Settlement Boundaries and infill development 3.68 Under this issue, the IO document indicates that there may be a need to alter existing settlement boundaries to take account of a new growth strategy up to 2050. National policy provides limited assistance to local planning authorities or stakeholders in how to deal with setting or amending settlement boundaries. 3.69 The IO document presents two options. Option S9a would save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b would review, within this Part 1 Plan, which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 3.70 The IO document makes clear that this plan review relates to part 1 strategic policies only, including strategic allocations and / or new settlement locations, and not non-strategic policies and allocations. On this basis, RPS would favour Option S9a – settlement boundaries should be reviewed at the Part 2 review stage. Given this option refers to the ‘emerging SAP’ RPS assumes that the SAP is still likely to be progressed and adopted including alterations to some settlement boundaries, prior to an immediate review of those boundaries in short order in the Part 2 SWLP. This is logical as the Part 2 SWLP will need to ensure the settlement boundaries are suitably robust to allow growth to be accommodated up to 2050, as opposed to the SAP which only addresses development needs up to 2031 (and only for Stratford-upon-Avon district). 3.71 Furthermore, in order to provide sufficient clarity and to reduce the risk of ambiguity in the Part 1 version, the next iteration of the SWLP (the preferred option draft plan) should make clear which settlement boundaries will need to be reviewed in light of the quantum of growth to be directed to each respective settlement (to deliver the spatial development strategy) and the capacity of those settlements to suitably accommodate that growth within the existing boundaries. RPS prefers option S9b. Issue S10: Any other development strategy issues Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire: 3.72 The preamble states that Chapter 4 of the IO document sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 3.73 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO document moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 3.74 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7). 3.75 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need and which respond to the needs of both market areas covering the two Districts. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified. 3.76 RPS would also reiterate its previous comments regarding the methodology used for analysing the selected settlements and that moving forward, the next stage of plan-making must be more transparent regarding the choice of settlement and site option.

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Issue H1: Providing the right number of homes Local Housing Need 4.1 As part of the emerging evidence, the IO document refers to an updated Housing and Economic Development Needs Assessment (HEDNA) that has been produced for the whole of Coventry and Warwickshire Housing Market Area (C&WHMA) using the latest information from the 2021 Census. As rightly stated, the HEDNA uses as the starting point for assessing housing need the standard method set out in Planning Practice Guidance (PPG). 4.2 The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. Nonetheless, the HEDNA has modelled an alternative approach based on the Census 2021 early data releases from June 2022, based on apparent issues with estimating and projecting the population in Coventry, particularly relating to potential discrepancies in the estimates of the population that have informed the 2014-based household projections. The alternative need figure is 4,906 dwellings annually across the sub-region. 4.3 Table 9 of the IO document (and Table 15.1 of the HEDNA) shows a breakdown of the overall housing need for each constituent local authority. This is reproduced below for reference. Table 4-1 Local Housing Need – Coventry & Warwickshire LPA -----------------------------2014-based projection ---------------- Trend-based projection Coventry-----------------------3,188----------------------------------------1,964 North Warwickshire---------176------------------------------------------119 Nuneaton & Bedworth------433------------------------------------------409 Rugby---------------------------516------------------------------------------735 Stratford-on-Avon------------564------------------------------------------868 Warwick------------------------675------------------------------------------811 Housing Market Area-------5,554---------------------------------------4,906 Source: C&W HEDNA 2022 4.4 RPS notes that under the alternative ‘trend-based’ (‘revised standard method’) projection the need is higher for both SW authorities compared to the standard method need figures (1,679 dpa under the alternative projection, versus 1,239 dpa using the standard method), an extra 440 homes per annum across the SW area. The trend-based projection is also higher in Rugby, but lower in North Warwickshire and Nuneaton & Bedworth, and substantially lower in Coventry. 4.5 The HEDNA goes to great lengths to explain why an alternative approach to the standard method for estimating local housing need across the sub-region is justified on the basis of ‘exceptional circumstances’, which is required to meet the policy test set out the paragraph 61 of the NPPF. In a nutshell, when looking at population change over the preceding period (2011-2021) the HEDNA claims that a discrepancy exists between the population (mid-year) estimates devised by ONS, and those derived from the Census 2021 population count. 4.6 Table 5.2 and 5.3 of the HEDNA seeks to illustrate this discrepancy. These tables show that population across the sub-region was substantially lower in the Census (942,100) compared to the mid-year estimates (963,173), largely as a result of an over-estimate in the population for Coventry. However, it is also notable that the Census output shows a higher population for both Stratford-upon-Avon and Warwick districts, a total difference of 6,316 extra people residing in South Warwickshire in 2021. This additional number of people will clearly have an impact on future population estimates for the SW area when properly accounted for in future projections. 4.7 On this basis, paragraph 5.105 explains the HEDNA proposes a trend-based projection taking account of the 2021 Census, more recent data around fertility and mortality, analysis of recent migration trends, from which household estimates are then derived (using the 2014-based household formation rates). The remodelled household projections are then fed back into the standard method through the application of the affordability adjustment, to generate the overall housing need figures for each area. 4.8 The local housing need derived from the trend-based projections is provided at Table 5.33 of the HEDNA. Whilst the overall approach is broadly understood, reference is made at paragraphs 5.149-5.150 of the HEDNA to a ‘further adjustment to deal with any suppression of household formation within the projections’ and ‘part return to trend’ analysis based on a refinement of the 2014-based household representative rates (HRRs). The results from the adjusted HRRs is shown in Table 5.34. The figures show a further increase in household growth across the sub-region (by +3,000) compared to alternative trend-based projection, which includes an increase household growth for Stratford-upon-Avon and Warwick districts. However, the HEDNA does not consider the implications this adjustment might have for the estimate of overall housing need across the subregion, or for the South Warwickshire specifically. 4.9 RPS recommends that the adjustment for household suppression presented in the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in south Warwickshire.

4.10 Chapter 8 of the HEDNA includes an analysis of affordable housing need in Coventry & Warwickshire, which is claimed to follow the methodology set out in the PPG14. Table 10 of IO document summarises the assessment of need for the SW authorities (drawn from Table 8.45 of the HEDNA) which is presented below. Table 4-2 Net Affordable Housing Need (per annum) – South Warwickshire only Rented---------------------Affordable Need------------- Affordable Home Ownership Need-----------Total Affordable Need Stratford-upon Avon----419------------------------------129-----------------------------------------------------547 Warwick-------------------582-------------------------------258----------------------------------------------------839 SW area------------------1,007-----------------------------378---------------------------------------------------1,385 Source: SWLP IO Jan 2023, Table 10; HEDNA Table 8.45; RPS 4.11 It is recognised in the published evidence base that affordable housing need is ‘high’ relative to the overall housing need across the C&WHMA (paragraph 4.4 of the HEDNA). RPS agrees. Table 8.14 of the HEDNA illustrates this point when comparing affordable need (rented need only) to the trend-based projections for each authority, including Stratford-upon-Avon and Warwick. The table showing the need across all C&WHMA authorities is represented below. Table 4-3 Net Affordable Housing Need (per annum) – C&W HMA -------------------------------Net Rented Need ---- Adjusted Standard ---- Affordable % ----- Affordable Housing ----- Notional Provision to Meet Rented -----------------------------------------------------------------Method ------------ Standard Method --- Policy Requirement ----- Affordable Need in Full Coventry -------------------1,887--------------------------1,964---------------------96%-----------------------25%-----------------------7,548 North Warwickshire-------131-----------------------------119---------------------110%--------------------30-40%----------------------374 Nuneaton &-----------------407-----------------------------409---------------------100%----------------------25%-----------------------1,628 Bedworth Rugby------------------------407-----------------------------409---------------------100%--------------------20-30%---------------------1,628 Stratford-on-----------------419-----------------------------868----------------------48%-----------------------35%-----------------------1,197 Avon Warwick---------------------582-----------------------------811----------------------72%-----------------------40%-----------------------1,455 Warwickshire-------------1,946--------------------------2,942---------------------66%----------------------------------------------------6,282 C & W----------------------3,833--------------------------4,906---------------------78%---------------------------------------------------13,830 Source: C&W HEDNA Table 8.14 4.12 The figures show that the rented affordable need as a proportion of the overall need for housing in the SW authorities is between 48-72% (or 60% across the two combined). Across the C&WHMA as whole, the proportion is 78%. When adding in the affordable home ownership need, the proportions increase from 60 to 82% for the SW area, and from 78 to 91% for the C&WHMA. It is clear that the proposed policy targets will only deliver a fraction of the homes needed even if the policy requirements are met in full (which is unlikely). Affordable housing need therefore represents a significant proportion of overall need which needs to be addressed in the SWLP, and across the HMA as a whole, when considering future housing targets for the area. This is particularly the case in Warwick, but is nonetheless still an important factor in Stratford also. 4.13 In addition, the scale of affordable need as a proportion of total need shown above is, to a large extent, due to the need emanating from Coventry, which is 96%. The HEDNA (at paragraph 8.72) recognises that, in setting overall housing targets, the viability of development and the availability of funding are realistically constraints on the level of provision which can be achieved. If Coventry is to make any significant contribution towards meeting its own housing needs, of all tenures, then additional allocations will be needed. This will require a considerable focus on delivering more housing on previously-developed sites within the city’s boundaries and the push for higher policy targets. However, the focus on brownfield land and higher policy standards will inevitably raise concerns with the viability and deliverability of lower value housing. This is evident because Coventry has failed to deliver its affordable housing policy targets since 2011, achieving 2,562 affordable homes against a policy target of 3,828 (2011-2022)15, or 232 homes per annum. 4.14 On this basis, in devising an overall housing requirement in the SWLP, if the SW authorities are serious about addressing affordable housing delivery then consideration should be given to how the delivery of affordable can be maximised across the C&WHMA in order to deliver sufficient affordable homes to meet local needs, in line with national policy16. The best way to increase the supply of affordable housing across South Warwickshire is therefore simply to allocate more land in sustainable locations within the area. This is best achieved through the development of mixed-tenure private sector-led development in areas where viability is less of a problem, notably in South Warwickshire, relative to metropolitan areas such as Coventry. 14 PPG ID-2a-018 to 2a-024 15 Coventry City Authority Monitoring Report 2021/22 Published 21st November 2022, Figure 9 16 NPPF 2021, paragraph 20

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Issue H7: Other Comments Q-H7 Response to Issue H7: Please add any comments you wish to make about delivering homes in South Warwickshire 4.15 This chapter of the IO document provides a commentary on a range of factors relating to policies for the provision of housing, including the scale (or need), type, size, and tenure of new homes to meet the needs of local communities. 4.16 As a general comment, this chapter is the first point at which the overall growth strategy for housing is considered in any detail in the IO document. This is after the IO document has already considered the spatial options for growth in chapter 4 (under Issue S7). This approach runs the risk of predetermining the distribution of growth before establishing the level or scale of growth that should be planned for. As highlighted in response to Issue S10, RPS recommends that the SWLP considers a different approach to devising the strategic policies relating to planning for the growth needs of the area by presenting the case for growth before considering distribution, rather than the other way round. This will ensure the SWLP is presented in a logical and coherent manner where distribution of development is properly considered in light of the scale of growth needed in the area.