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ID sylw: 108277

Derbyniwyd: 05/03/2025

Ymatebydd: David Kinnesley

Asiant : Fisher German

2.1 The Council’s proposed approach is to meet the provisions of the 2024 NPPF through a flexibility allowance (2,188 dwellings per annum), but the Plan seems to adopt a lower housing requirement of only 1,679 dwellings per annum, which is derived from the HEDNA (November 2022) (which is already out of date having regard for the PPG which allows a 2 year period). For the avoidance of doubt, given the Plan has almost certainly missed the transitional arrangements, the housing requirement must at the very minimum be the Local Housing Need figure of 2,188 dwellings per annum. It is not appropriate or in compliance with the NPPF to cover off Local Housing Need through supply but not the adopted housing requirement, unless the Council is advancing an exceptional circumstances argument.

2.2 Paragraph 11 of the NPPF (2024) affirms “strategic policies should, as a minimum, provide for objectively assessed needs for housing”. Paragraph 69 states that “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment” [our emphasis].

2.3 It is not sound to identify a housing requirement below Local Housing Need (without an exceptional circumstances argument), justified through having sufficient supply to meet Local Housing Need. If there is sufficient supply to meet the housing requirement, it is considered highly unlikely exceptional circumstances could exist which would justify an alternative approach, particularly having regard to historic delivery rates (discussed below) and the impetus on uplifting housing delivery endorsed by the most recent framework.

2.4 The housing requirement must therefore be clear it is a minimum of 2,188 dwellings per annum, or 54,700 dwellings over the Plan period derived from the Standard Method, not the now out of date requirements derived from the HEDNA. This is required as a matter of soundness, not least ‘Positively prepared’, which the NPPF prescribes as “providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs”; but also consistent with national policy having regard for paragraphs 11 and 69 as provided above.

2.5 However, in accordance with the NPPF and PPG, it is necessary to consider whether the housing requirement should be Local Housing Need, or a figure in excess of Local Housing Need. This uplift can be derived for numerous factors, including seeking to increase economic growth, affordable housing delivery, or relating to opportunities arising through the delivery of strategic infrastructure. The Iceni Paper ‘Advice on Housing & Employment Land Needs’ (February 2024) affirms that that 2,808 dpa may be required in South Warwickshire utilising a 5-year migration scenario, and Table 6.10 indicates that at least 2,772 dpa is needed to meet the total affordable housing need. The Council’s own evidence is clear that if there is to be movement from Local Housing Need, it is likely to be higher, not lower as currently proposed.

2.6 The PPG also advised logically that evidence of higher levels of delivery in previous years can be a strong sign of market need and this should be considered as part of setting the housing requirement. It is noted having regard for the Council’s monitoring papers that the Plan area has exceeded the Local Housing Need figure of 2,188 dwellings per annum 6 out of 8 years, including 2016/17, 2017/18, 2018/19, 2019/20, 2021/22 and 2022/23. It is noted the only year since 2015/16 where housing delivered was below 2,188 dwellings per annum was 2020/21, peak covid years and thus clearly could have been impacted by Covid restrictions. In two years the Council delivered in excess of 2,600 dwellings per annum. These figures strongly suggest that the housing requirement should be increased, particularly given the evidence provided above.

2.7 Another crucially important factor to review is a consideration of unmet need, but this is subject of its own question provided below.

2.8 It is noted that the plan assumes windfall delivery of 9,375 dwellings over the Plan period .This equates to circa 20% of the supply proposed. For such high amount of windfall to be assumed, the Council needs strong evidence both on historic delivery, but also in respect of supply. In respect of historic delivery, regard would need to be had for fluctuating delivery rates. It is noted that the AMR (2022/23) indicates windfall delivery varies significantly from almost a thousand dwellings to below 50 in a single year.

2.9 Windfall redevelopment opportunities are ultimately a finite resource and those sites which are easiest and most appropriate for development will likely have been developed, leaving a pool of more difficult sites less likely to be delivered. Whilst there will be a churn in the supply as sites become available, recent years delivery cannot be guaranteed to be sustainable over a long period. The Council’s need to meet the windfall allowance could result in land which may be suitable to stay in employment or community use for example, being forced for redevelopment as residential, thus permanent loss of existing uses. Whilst windfall allowance rates by definition cannot be wholly predicted, clearly the higher the reliance on the windfall delivery, the higher the risk of plan failure is if sites do not to come forward.

2.10 It is noted that the approach adopted by the Council is that that LHN will be met through essentially additional supply or buffer. Notwithstanding our comments above in relation to the soundness of this approach, it is further worthy to note that when the Council adopts LHN or higher as its housing requirement, it will be necessary still for the Plan to contain a buffer to ensure delivery. In accordance with the NPPF, this should be in excess of 5%, but for contingency should be closer to 20%.

2.11 In terms of spatial strategy, the Council confirmed that it intends to proceed with a ‘Sustainable Travel and Economy’ spatial growth strategy, with three ‘priority areas’ for growth identified. Priority 1 is brownfield land. We do not disagree that brownfield land should be used in the first instance. It is noted that the most recent Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – circa 10% of the minimum housing need required over the plan period (54,700 dwellings), lower when a more sensible housing requirement and buffer is applied. Regardless, even with a lower level of requirement the study concludes that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (Page 37). However, this assumes that all such brownfield sites will actually be deliverable and thus it remains this figure may be lower still. Regardless, even if so there remains significant land to be allocated.

2.12 The Council’s approach is that this land should be allocated predominantly on a selection of the 24-strategic growth locations identified in the Draft Plan and utilising a new settlement. We disagree with this approach. This approach results in a significant overreliance on similar typologies of land, does not provide an adequate housing mix, including the NPPF requirement for sites under a hectare to form 10% of the overall requirement. The Council should ensure it has enabled for reasonable growth throughout the spatial hierarchy to ensure the continued vitality of rural communities, and also ensured it has delivered the requisite supply of land on small sites as per paragraph 73 of the NPPF.

2.13 we do not support any strategy which renders sustainable settlements as unsustainable. Failure to enable sufficient rural growth can result in significant harm to the vitality and viability of key services in the rural area, the impact of rural house pricing and the inability for young people to stay in the communities where they have grown up. Growth of a commensurate scale down the spatial hierarchy is considered to have significant social and economic utility, supporting local services to ensure sustainability is retained

2.14 This conclusion has been reached by a number of a different organisations, including the Country Land and Business Association (CLA) whose publications Strong Foundations (July 2017) and Sustainable Communities: the role of housing in strengthening the rural economy (February 2022) outlines the significant issues for rural communities when described as unsustainable by development plan documents, unduly restricting their growth. The lack of affordable or entry level housing means younger people are often unable to find local accommodation, forcing them to move away from their homes to find suitable accommodation. Moreover, the lack of new development including bungalows or other dwellings suitable for downsizing means many older such will instead remain over occupying larger family homes. The loss of younger people and resulting imbalance of the local population can have issues for service and facility viability, including schools, leading to self-fulfilling cycles of decline, as services, facilities, public transport routes are lost due to lack of development, reducing the sustainability of the settlement, thus resulting in further restricted growth.

2.15 To resist such issues, the CLA advocate strongly for planning policy regimes which do not seek to wholly prevent growth in the rural areas, and that commensurate growth is allowed throughout the spatial strategy. This will not be achieved through this spatial option.

2.16 We also consider there to be issues with market absorption which would be compounded by limiting growth to such restricted geographies, as would be the case through the selection of a limited number of growth options only instead of commensurate growth throughout the spatial hierarchy. Through this approach, the Council can also meet the requirement of Paragraph 73 of the Framework. The Council are advised that the NPPF is clear that ‘strong reasons’ are required in terms of justification when not providing sufficient small sites which given the supply of land in South Warwickshire are not likely to be demonstrable.