BASE HEADER

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ID sylw: 108058

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

With regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire. Therefore, opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

. The policy direction suggests that there are 17,068 existing commitments which will form part of the supply over the plan period.
In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.40-year housing land supply at the present time.
Stratford District Council claim to have a 24.65-year housing land supply as of 1st April 2024, as set out in their Information Sheet dated 16th October 2024. We strongly dispute the assertion that the Council can demonstrate this level of supply at the present time.
If the Core Strategy is out of date, the five-year housing land supply for Stratford needs to be measured against the housing need calculated using the Standard Method, in accordance with the PPG. The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase).
4.14. Regardless of the current land supply Stratford have published, for the emerging SWLP, there is a minimum local housing need of 1,126 dpa, which equates to a need for at least 5,630 homes over the period 2024-29. The latest assessment by Stratford suggests that 3,505 homes will be delivered from 2024-2029, meaning there is a demonstrable substantial need for 2,125 homes irrespective of the housing land supply position. It also equates to a five year supply of just 3.11 years if the published land supply figures are taken as read.
. It is also important to emphasise that both Stratford and Warwick’s calculations are based on a number of assumptions regarding deliverability. The housing land supply figures may reduce further if sites do not deliver as expected, permissions expire without being implemented, or fewer windfall sites come forward than expected.
When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply (3.11 years and 4.40-years respectively), and as such the presumption in favour of sustainable development will apply, which may lead to a substantial number of speculative planning applications in locations which the Councils do not consider favourable for growth under the selected spatial strategy. Any under-delivery which may occur would result in an even lower supply. Specific and deliverable sites must be allocated for housing across South Warwickshire to ensure that there can be a steady supply of housing in Stratford and Warwick over the plan period, and certainly for five years following adoption, in line with Paragraphs 72 and 78 of the NPPF.
The Councils express a preference to concentrate growth on brownfield sites, Priority 1 areas, prior to considering development elsewhere. However, it is important to emphasise that there is insufficient previously developed land within South Warwickshire to accommodate the level of housing required. Indeed, the Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – just 11% of the minimum housing need required over the plan period (54,700 dwellings). As such, the study concludes (on page 37) that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (emphasis added).
The identification of a myriad of Priority 2 and 3 areas, where development can occur in accordance with the spatial growth strategy, is supported, to ensure that needs can be fully met. Proportionate growth directed away from brownfield sites to settlements which are comparatively smaller than Stratford, Warwick, and Leamington Spa will also support their viability and vitality, whilst providing opportunities to enhance sustainable travel options at these locations, resulting in positive impacts on transport and accessibility (SA Objective 11), as acknowledged in Appendix E of the SA, paragraph 3.1.6.
Twenty-four Strategic Growth Locations are identified, twenty-one of which would accommodate housing. It is stated that these locations could accommodate development which exceeds South Warwickshire’s housing need; The Councils suggest that allocations will not be made in all areas given that this exceeds their housing requirement. It is agreed that allocating land for 74,521 dwellings would be excessive, since the evidence is unlikely to justify this, and the plan must be deliverable. Notwithstanding, the Councils clearly have an opportunity to allocate some additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher-growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.