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ID sylw: 108185

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

The SWLP’s Housing Needs
2.7 Whilst the PO refers to the housing needs established in the ‘Coventry & Warwickshire
Housing & Economic Development Needs Assessment (HEDNA) (November 2022)’ (“the
HEDNA”), St Philips welcomes the PO acknowledging the SWA’s housing needs under the
revised Standard Method [SM] – see Table 4.
2.8 As the SWAs will be aware, the Government recently revised NPPF and SM for the
calculation of housing needs. The proposed new SM would significantly increase the
housing needs for the SWAs when compared to the HEDNA – as identified in the PO, with
the SWLP having to identify a further c.12,725 dwellings to meet these needs when
compared to the HEDNA’s objectively assessed housing needs [OAHN].
2.9 Notably, paragraphs 234 to 236 of the NPPF are clear that Local Plans that do not reach
Regulation 19 by the 12th of March 2025 and are planning to meet at least 80% of the local
housing need [LHN] figure generated by the revised SM would be required to take full
account of the revised NPPF policies, in addition to the updated LHN figures generated by
the revised SM.
2.10 When taken together, and given the SWA’s working timetable for the SWLP, it is clear that
the SWAs will need to plan for the revised SM figure through the SWLP. This is because the
NPPF is clear that the overall aim of Local Plans should be to meet an area’s identified
housing need in full (Para 61) generated by the revised SM (Para 62), as the SWLP will not
have reached Regulation 19 by the 12th of March 2025. To this end, St Philips considers that
the SWAs should seek to address the c.2,188 dwellings per annum [dpa] LHN generated by
the revised SM – or c.54,700 dwellings over the 2025 to 2050 plan period.
2.11 However, St Philips would also highlight to the SWAs that it is expected that Local Plans
should be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a
housing trajectory has sufficient land supply across the plan period so that it can adjust and
accommodate any unforeseen circumstances, such as a degree of flexibility in delivery rates
and densities. Critically, this means that to achieve a housing requirement a Local Plan
must release sufficient land or allow sufficient ‘headroom’ so that there is an appropriate
buffer within the overall planned supply.
2.12 As such, in due course, it will be necessary for the SWAs to identify suitable land supply in
excess of the SWLP’s LHN-based housing requirement to ensure that there is the flexibility to respond to failures to deliver the required dwellings in the allotted time frames and
across the whole plan period. Importantly, this ‘buffer’ should also be in excess of any
commitments to addressing unmet housing needs from neighbouring authorities –
discussed further below in St Philips’ response to Draft Policy Direction 4. This is because if
any single component of supply does not come forward or falls behind the timescales
implied by the SWAs, this would result in the unmet housing needs not being delivered,
rather than the SWLPs. Therefore, St Philips would recommend that a minimum of c.10-
20% headroom should be incorporated into the SWLP proposed housing supply.

Strategic Growth Locations
2.13 Given the scale of the SWA’s emerging housing needs under the new SM and the need to make a contribution towards the unmet housing needs of the GBBCHMA, St Philips strongly supports the proposed ‘Sustainable Travel and Economy’ Spatial Growth Strategy. This is because it will best promote sustainable patterns of development across the area and align with the sustainability aspirations that are set out in the NPPF and SWLP Vision and Objectives. 2.14 Ultimately, whilst greater levels of development may need to be focussed around the Main Urban Areas, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach, which includes Green Belt release, to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the SWAs to capitalise on opportunities presented by existing or planned infrastructure when considering options for large-scale new residential developments, in accordance with paragraph 77a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent with paragraph 148 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well served by public transport (Paragraph 147); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area in close proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions).

Approach to achieving net zero
2.33 As noted above, St Philips’ Vision for the Site ensures that the development could deliver on
the SWLP’s Vision and Strategic Policy Objectives in relation to delivering sustainable
growth and combating climate change. Further information on how St Philips proposes to
achieve this is set out in detail in the supporting Vision Document (Appendix 1).
2.34 However, in short, the Site could deliver a suite of ecological and green infrastructure
improvements throughout the proposed development, ensuring a 10% Biodiversity Net
Gain [BNG] alongside blue-infrastructure enhancements and a c.9 ha Country Park. When coupled with a fabric-first approach to the build specification that will ensure that new
homes will reduce heat waste and incorporate low-carbon energy generation technologies,
and electric vehicle charging points, the Site is well placed to assist the SWAs in achieving
Net Zero.

Mitigation of issues identified through the SA
2.35 Based on the SA conclusions, SG24 broadly ranks in the middle out of twenty-four SGLs in terms of best and worst-performing SGLs against the Sustainability Appraisal [SA] objectives, set out in the ‘Interim Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Preferred Options Stage’. However, it is considered that these matters are resolvable through appropriate mitigation – indeed, as stated within the SA: “Mitigation has not been considered when ranking the SGLs, given the options requiring less intervention are likely to be more sustainable choices.” However, St Philips have set out below how the Site could mitigate against any of the impacts identified within the SA: [See attachment]
Further technical work can be provided to the SWAs to demonstrate that the Site could mitigate any negative impacts arising from development.